ML20248D157
| ML20248D157 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle, 05000000 |
| Issue date: | 09/13/1989 |
| From: | Bitel J COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20248D092 | List: |
| References | |
| CE-1-A, CE-1-A-R56, NUDOCS 8910040141 | |
| Download: ML20248D157 (46) | |
Text
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i LISTING COVERING REVISION OF.
.o TOPICAL REPORT CE-1-A j
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- l Below is a listing'of Revision 56 changes to the-Commonwealth Edison Company Quality Assurance Program Topical' Report'CE-1-A dated 9/13/89:
=., r a Rev. Content Pages 1-4; Appendix A, Pages A-2, A-3 and A-5; Pages-1-1, 1-3. 1-4, and:1 1-52; 2-1 and 2-7; 3-4;'
4 4-5; 5-1; 6-2; 7 7-4; 8-1; 9-1; and 18 18-3.
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Approved:
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/f9fnager of Quality Assurance /-
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Nuclear Safety 9/13/89 9518M y
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CONTENTS TITLE EAGE REY.
DATE IN!RODUCTION 1-1 56 09/13/89
- 1. ORGANIZATION A. Basic Organization Responsibilities 1-1 56 09/13/89 1-2 55 03/27/89 B. Organizational Responsibilities for Major Activities 1-3 56 09/13/89 1-4 56 09/13/89 1-5 55 03/27/89 1-6 55 03/27/89 1-7 55 03/27/89 1-8 55 03/27/89 1-9 55 03/27/89 1-10 55 03/27/89 1-11 55 03/27/89 1-12 56 09/13/89 1-13 56 09/13/89 1-14 56 09/13/89 1-15 56 09/13/89 1-16 56 09/13/89 1-17 56 09/13/89 1-18 56 09/13/89 1-19 56 09/13/89 1-20 56 09/13/89 1-21 56 09/13/89 1-22 56 09/13/89 1-23 56 09/13/89 1-24 56 09/13/89 1-25 56 09/13/89 1-26 56 09/13/89 1-27 56 09/13/89 1-28 56 09/13/89 1-29 56 09/13/89 1-30 56 09/13/89 1-31 56 09/13/89 1-32 56 09/13/89 1-33 56 09/13/89 1-34 56 09/13/89 1-35 56 09/13/89 1-36 56 09/13/89 1-37 56 09/13/89 1-38 56 09/13/89 1-39 56 09/13/89 1-40 56 09/13/89 1-41 56 09/13/89 1-42 56 09/13/89 Page 1
of 4 Date:
9/13/89 Rev. 16
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3 4-CONTENIS e
TITLE EAGE rey;
-DATE FIGURES' 1-0.
Organization Chart Related To Q. A.
1-43 56' 09/13/89 1-1
. Organization Chart - Quality Assurance /
1 56 09/13/89'
. Nuclear Safety Policy and Oversight Dept.
1-1-1 Quality Programs and Assessment Department 1-45 56 09/13/89 1-2:
Engineering and Construction Department 1-46 56 09/13/89-1-2.1 CECO Nuclear' Generating Station Site 1-47 56 09/13/89 Organization Interface Relationships
'l-3 Projects Organization and Nuclear 1 56 09/13/89 Engineering. Department.
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.1-4 Projects Department:(For Future Project -
1-49 56 09/13/89 i'
' Currently Inactive);
h 1-5 System Operational Analysis Department
.1-50 56 09/13/89 l
.and System Materials Analysis Department 1-6 Production-1-51 56 09/13/89 1-7 Station Production Department Organization 1-52
.56 09/13/89
- 2. QUALITY ASSURANCE PROGRAM 2-1 56 09/13/89 2-2 51 07/07/88 2-3 55 03/27/89 2-4 55 03/27/89:
2-5 55'
.03/27/89' 6 55' 03/27/89-2-7 56 09/13/89 2-8 55 03/27/89
- 3. DESIGN CONTROL 3-1.
55 03/27/89 3-2
' 55 03/27/89 3-3 55 03/27/89 3-4 56 09/13/89
- 4. PROCUREMENT DOCUMENT CONTROL 4-1 56 09/13/89 4-2 56 09/13/89 4-3 56 09/13/89 4-4 56 09/13/89 4-5 56 09/13/89
- 5. INSTRUCTIONS, PROCEDURES AND DRAWINGS 5-1 56 09/13/89 5 55 03/27/89 5-3 36 06/19/85
- 6. DOCUMENT CONTROL 6-1 32 10/05/84 6-2 56 09/13/89 6-3 55 03/27/89 Page _Z_ of 4 Date:
9/13/89 Rev. 56
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N CONTENTS h > ; *...-, J.
TITLE I2GE REY.
DATE
- 7. CONTROL OF PURCHASED MATERIAL,- EQUIPMENT' AND SERVICES 7-1 55 03/27/89 7-2 56 09/13/89 7-3 56-09/13/89 7-4 56 09/13/89 7-5 55 03/27/89 l
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7-6 55 03/27/89 l.
8.-IDENTIFICATION AND CONTROL OF MATERIALS, i
L PARTS AND COMPONENTS 8-1 56 09/13/89 1
8-2 55-03/27/89 l
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- 9. CONTROL OF SPECIAL PROCESSES 9-1 56 09/13/89' I
9-2 55 03/27/89 9-3 55-
~03/27/89
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- 10. INSPECTION 10-1 55 03/27/89:
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10-2 55 03/27/89~
10-3 33 03/13/85
- 11. TEST CONTROL 11-1 15 01/02/81 11-2 55 03/27/89 11-3 55 03/27/89 11-4 55 03/27/89
- 12. CONTROL OF MEASURING'AND TEST EQUIPMENT 12-1 42 11/21/86 12-2 55 03/27/89 12-3 55 03/27/89
- 13. HANDLING, STORAGE AND SHIPPING 13-1 26 12/10/83 l
13-2 55 03/27/89 1
13-3 55 03/27/89
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- 14. INSPECTION, TEST AND OPERATING STATUS 14-1 55 03/27/89 j
14-2 26 06/19/85 i
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- 15. NONCONFORMING MATERIALS, PARTS OR COMPONENTS OPERATIONS 15-1 26 12/10/83 15-2 55 03/27/89 15-3 55 03/27/89
- 16. CORRECTIVE ACTION 16-1 55 03/27/89 16-2 55 03/27/89 16-3 15 01/02/81
- 17. QUALITY ASSURANCE RECORDS 17-1 51 07/07/88 17-2 55 03/27/89 Page _3_ of 4 Date:
9/13/89 Rev. E5
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a CONTENTS TITLE EAGE REY.
DATE
- 18. AUDITS 18-1 56 09/13/89 18-2 56 09/13/89 18-3 56 09/13/89 I
APPENDIX A Quality Assurance Program Manual Index A-1 45 06/30/87 1
Quality Assurance Procedures Manual A-2 56 09/13/89 Index (Engineering and Construction)
Quality Assurance Procedures Manual A-3 56 09/13/89 Index (Operations)
A-4 50 04/08/88 l
A-5 56 09/13/89 l
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D CMM7 fjnagerofQualityAssurance/
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Nuclear Safety l
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I Page 4 of 4 Date:
9/13/89 Rev. 55
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s l EXPLANATION OF CHANGES FOR TOPICAL REPORT -'REV. 56-
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COMMONWEALTH EDISON COMPANY PROGRAM TOPICAL REPORT CE-1-A e.
K PAGE NO.
EXPLANATION-h Appendix A,-.Pages A-2,-
'These revisions are'being made to make
- A-3 and~'A-5;.Pages.1-3, minor organizational changes and to 1-4, 1-12'- 1-43, and update the Quality Assurance Program-1-52; 2-1 and 2-7;.3-4; to meet the current organization.
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- 4 4-5;; 5-1; 6-2;;
- 7-2
.7-4; 8-1; 9-1;-
and;18 18-3.
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'Ouality Requirements l
15.0 Nonconforming Materials, Parts or Components 16.0 Corrective Action
- 17. 0 Quality Assurance Records 18.0 ' Audits-l 0
Appendix B, 10CFR50, " Quality. Assurance Criteria for j
Nuclear Power Plants" i
0-Station Quality Assurance Manual for Construction, l
Maintenance, Modification, In Service Inspection and Stores Activities QUALITY ASSURANCE PROCEDURES MANUAL INDEX (ENGINEERING & CONSTRUCTION)-
1 1
Quality Procedures 2 Procedure for Revision of the Quality Assurance Manual I
2 Training of Personnel to Meet Quality Assurance Requirements 3-1 Design Control and Maintenance and-Modifications Control 3-2 Design Change Control' 3-3 Classification of Systems, Components, Parts and Materials 4-1 Request for Bid, Proposal Evaluation and Recommendation 4-2 Evaluation of Vendor's Quality Assurance Program j
i 5-1.
Quality Instructions and Procedures 6-1 Distribution of Design Documents 6-2 Procedure for Engineering and Construction Department and Substation Construction Department Design Document Control 7-1 Control of Procured Material and Equipment - Receiving and Inspection 7-2 Off-Site Contractor Inspection A-2 Rev. 56 9/13/89
w Qual.i.ty Procedures 9E 8-1.
' Identification and Control of' Materials, Parts ~and Components
.9 Control of-Contractor Special Processes q
l-10-1 On-Site Contractor Inspection'or. Substation Construction Department i
10-2 -Quality l Assurance Mandatory' Hold /
11-1 ~ Development, Performance, Documentation and Evaluation Of
. Construction Tests 11-2 Development.. Performance, Documentation and Evaluation of l
Preoperational and Start-up Tests
.i 12-1 Calibration Control of Commonwealth' Edison Test and l
Measurement Equipment 12-2 Calibration and Control of Station Instrument' tion and
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Control Equipment d
12-3 Review of Vendor / Contractor Calibration Activities and '
j Quality Control Records' i
13-1 Site Handling, Storage,. Preservation, Maintenance and.
Shipping of Material, Equipment and Components.
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14-1. Inspection and Test j
15-1 Reporting Quality Nonconformances During' Construction and Test 15-2 Reporting Significant Deficiencies that Occur During j
Construction and Tests i
16-1 ~ Corrective Action for Reportable. Deficiencies & Quality Nonconformances that Occur During Construction and Test 17-1 Quality Assurance Records 18-1 Quality Program Audits 18-2 Surveillance of Contractor and Vendor Quality Assurance / Control Activities i
i 18-2 ATTACHMENT A Quality Assurance Department Surveillance of l
Construction Activitter QUALITY ASSURANCE PROCEDURES MANUAL INDEX (OPERATIONS)
QUAjity Procedure 2-52 Quality Assurance Program for Operations - Training
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2-53 Quality Assurance Program for Operations - Classification of Structures, Systems and Components A-3 Rev, 56 9/13/89
.e Quality Procedures 13-51 Handling, Storage and Shipping for Operations - Control of Equipment, Materials and Nuclear Fuel 13-52 Preparation and Shipment of Radioactive Materials 14-51 Inspection, Test and Operating Status for Operations 15-51 Nonconforming Materials, Parts and Components for Operations - Spare Parts and Materials 15-52 Nonconforming Materials, Parts or Components for Operations
- Deviations and Comments 15-53 Nonconforming Materials, Parts and Components for Operations - Inspection and Test 16-51 Corrective Action for Operations - Corrective Action System 17-51 Quality Assurance Records for Operations - Control of Station Records 18-51 Audits and Surve111ances for Station Maintenance, Modifications and Operation - Quality Assurance Program Audits 1
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QUALITY ASSURANCE DURING DESIGN, CONSTRUCTION AND OPERATION Introduction This Topical Report has been prepared to delineate the requirements governing the Commonwealth Edison Company Quality Assurance. Program for its nuclear generating stations.
Implementation of the Program with Quality Procedures provides the degree of quality assurance commensurate with the requirements of ASME Section III, Division 1 and Division 2 for concrete containment and other applicable codes, Nuclear Regulatory Commission requirements and Federal Regulations governing design, procurement, construction, testing, operation, refueling, maintenance, repair and modification of Commonwealth Edison Company's-nuclear power generating facilities. The scope of this Report covers the total Quality Assurance Program for the life of the Commonwealth Edison Company. nuclear generating plants and is described in the ensuing 18
- 95 sections of this Report.
1.
Organization A.
Basic Organization Responsibilities Commonwealth Edison Company is ultimately responsible for the assurance of quality in all phases of the design, procurement, construction, modification, testing and operation of the Station.
Edison executes this responsibility in accordance with the program set forth in the Company Quality Assurance Manual and' described herein and assigns areas of ultimate responsibility to specific Edison organizations and individuals.
Inherent in the delegation of responsibilities is the assignment of corresponding authority required to execute the responsibilities.
Edison has delegated the responsibility for certain phases of.the work to the Architect Engineer and the NSSS Supplier, both of whom act as Edison's agents in the assigned areas.
Edison maintains overall control of the efforts of these organizations by various mechanisms such as design evaluation and audits.
Edison has prime responsibility for controlling the quality of on-site work by field contractors. Also, Edison retains overall responsibility for procurement, design, construction, modifications, and operation of the plant including certification and stamping in accordance with the ASME Code.
1-1 Rev. 56 9/13/89 Commonwealth Edison
The Commonwealth' Edison Company Quality Assurance Program o
6-for nuclear generating stations covers the organization arrangement whereby'the. corporate policy and the performance of off-site audits
'for the-area of Quality Assurance involving nuclear and the. corporate policy for Nuclear Safety are the. responsibility of the Manager of
-Quality Assurance / Nuclear. Safety, who reports to the Chairman and CEO. Also, the Assistant Vice President (Quality Programs and Assessment), and, in turn, the Nuclear Quality Programs. Manager, direct the quality assurance activities for the design, procurement, construction, and operation of the Company's nuclear power facilities and interface activities with the Nuclear Regulatory Commission, ess
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Office of Inspection and Enforcement, Region III, and the Jurisdictional Authority.
The Assistant Vice President (Quality Program and Assessment) reports to the Senior Vice President (Nuclear Operations), and functions independently of PHR (Pressurized Water Reactor) and BHR (Bolling Water Reactor) operations.
The Construction Manager, supported by Site Construction Superintendents, is responsible for administration of the contracts and for verification that construction activities carried out by site contractors conform to procurement document requirements which include performance and quality related functions. Also, the construction site group has responsibility for reviewing site contractor quality control procedures, preparing checklists for witnessing inspection notification points at vendor plants, inspection and designation of. status of incoming material at the site, reviewing inspection procedures and monitoring quality control activities of contractors at the site.
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The Quality Assurance site group is responsible for assuring that the quality requirements are fulfilled and for final approva.1 of.:
(1) quality assurance procedures of site contractors: (2) the program, including checklists and reports, for inspections and audits ~at contractor plants; (3) site receipt inspection of materials performed by others; and (4) for audit of contractor inspection activities at the site.
Independent Inspection Agency inspection and testing I
activities performed directly for Commonwealth Edison are under the direction and responsibility of the Site Quality Assurance Superintendent and such Agency shall be staffed with qualified personnel acceptable to Quality Assurance.
Such Agency has responsibility to identify unacceptable or nonconforming work occurring on-site and, when assigned, at off-site supplier's plants.
An Independent Inspection Agency is assigned responsibilities for inspection and testing, to deterti.ine and report whether the item conforms to design, test and specification requirements and to reject unsatisfactory materials, equipment and other items.
Such rejection by an Independent Inspection Agency will be the basis for action by the Commonwealth Edison site organizations to carry out necessary steps to assure repair, rework or processing of a nonconformance report in accordance with the Quality Assurance Program.
The Commonwealth Edison Company Ouality Assurance Program ir,cludes the quality assurance requirements for operating nuclear b
power stations.
The Program covering operations shall comply with the 18 Criteria of the " Quality Assurance Criteria for Nuclear Power Plants" of Appendix B to 10CFR50 for maintenance, modification and i
refueling activities and with Criteria 1, 2, 5, 6, 10, 11, 12, 14, 15, 16, 17 and 18 for operating activities. As supplementary Criteria to the 18 Criteria described above for Appendix B to 10CFR50, the Program also complies with Regulatory Guide 1.33 " Quality Assurance Program 1-2 Rev. 55 3/27/89 Commonwealth Edison
w requirements (Operations)" as an acceptable method of complying alth the Commission's regulations with regard to overall quality assurance program requirements.
The Program shall apply to the
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quality-assurance activities affecting the' safety-related structures, systems and components.
The Program is applicable to the maintenance, modification, operating and refueling quality assurance activities from the time the Operating License is issued
-to the end of the operating life of the items. Repairs are performed as maintenance activities and alterations as modifications.
The Program covering operations, including quality control, is planned and implemented in accordance with procedures necessary to provide Commonwealth Edison Company adequate confidence
.that a safety-related structure, system or component performs satisfactorily in service.
B. Organizational Responsibilities for Major Activitin Design Control of design quality.is essentially a four-stage process.
Designs originated by either the.NSSS Supplier or Architect Engineer are subjected to internal review by the designer and an independent internal party (or parties). The NSSS Supplier and Architect Engineer designs are evaluated by each other as well as by personnel from one or more Edison departments.
These steps constitute the primary design evaluation for all safety-related and ASME Section III items in the Station. Appropriate document distribution and control'has been established to permit an effective effort in this. area. Comments on designs resulting from these evaluations are presented in letter form, by telephone (with written follow-up) or in meetings with published minutes. -Edison has final authority with respect to decision making on designs.
Procurement Procurement control and follow-up for NSSS components is established and maintained by the NSSS Supplier.
Edison and the Architect Engineer evaluate the NSSS Supplier procurement specifications, and Edison audits and inspects the NSSS Supplier control measures.
Procurement of and follow-up on non-NSSS components and services are directly controlled by Edison, based on the Architect Engineer specifications which have been evaluated by Edison.
The Architect Engineer is used to assist in this effort, as Edison's agent, as requested by Edison.
Construction Construction quality assurance is an Edison responsibility.
Edison exercises managerial control of all site construction activities.
The site Quality Assurance Group maintains close surveillance of on-site contractor's and other associated construction quality assurance activities.
The NSSS Supplier furnishes technical and Quality Control assistance for on-site activities relating to the NSSS. On-site contractors' quality assurance programs are evaluated by Edison Quality Assurance.
- 56 1-3 Rev. 56 9/13/89 Commonwealth Edison
Pre-service Testing-u-
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Pre-service testing, consisting of preoperational and start-up testing, is controlled by Edison. The Architect Engineer and the NSSS Supplier furnish rough draft test procedures to Edison.
Based on these, a final draft is written by Edison.
This final draft is subjected to internal Edison evaluation and evaluation by the Archi-tect Engineer or the NSSS Supplier as appropriate.
The tests are managed and performed by Edison with technicpl assistance from the
-NSSS Supplier as appropriate..The evaluation of the test results is performed.by Edison and confirmed by independent internal Edison evaluations.
Further independent. evaluations by the Architect Engineer or the NSSS Supplier are performed as required by Edison.
Doerationi Commonwealth's managerial and administrative control of the Quality Assurance Program for operating nuclear stations, as illus-trated in figures 1-0, 1-1, and 1-6 includes review and approval of procedures by the personnel described in this document.
Quality Procedures and revisions thereto for the Company Manual are concurred with by the principally involved departments.
The Nuclear Quality. Programs Manager, reporting to the Assistant Vice President (Quality Programs and Assessment), verifies that the Quality Procedures used by, or under the direction of, the station staff for operating, maintenance, modifications, in-service inspection and Stores activities contained in the Company Manual or Station Quality Procedures comply with the policy described in this document.
The Manager of Quality Assurance / Nuclear Safety approves the Quality Procedures covering operating, maintenance, modifications, in-service inspection and Stores activities for use in the Station.
Station Procedures and instructions and revisions thereto for the Station Procedures Manual are reviewed and approved as provided in the Technical Specifications.
The Station Quality Assurance Engineers or Inspectors covering station operating activities and~ reporting to the Station Quality Assurance Superintendent provide surveillance of the preparation and revision of the station procedures and instructions for operating to assure compliance with the policies contained in the Quality Assurance Program.
The Quality Assurance Engineers or Inspectors for maintenance, reporting to the Station Quality Assurance
- ss Superintendent, provide surveillance of the preparation and revision of procedures and instructions for maintenance, modifications, in-service inspections and Stores activities to assure compliance with the policy contained in the Quality Assurance Program.
Temporary changes to station operating procedures which do not 1-4 Rev. 56 9/13/89 Commonwealth Edison
yA i.
al. 4 ' Enoineerina abd Construction'Responsibilittei
- 1.4.1 Nuclear Enoineerina Manaaer.
The Nuclear Engineering Manager has overall engineering responsibility and, as applicable,; assigns responsibilities to cognizant NED (Nuclear Engineering Department) engineers for specific modification-work at-the generating stations. -The cognizant engineers have the responsibility to specifically supervise the electrical, mechanical, structural, instrumentation and controls and nuclear engineering activities involving the plant modifications.
These responsibilities' include ~
the'following:
a.
Review and control the design work: involving the electrical, mechanical, struttural and instrumentation and control designs of the NSSS vendor and, Architect Engineer-to verify that applicable Safety Analysis Report (SAR),
regulatory requirements, ASME Code requirements, and design bases are properly translated.into specifications, drawings, procedures and instructions.
b.
' Review and accept the~ specifications and drawings
.for electrical, mechanical and structural material, equipment and erection work, prepared by the Architect' Engineer and NSSS vendor,'to verify
. inclusion of inspection, testing and acceptance criteria.
c.
Analyze bids, make purchase recommendations,
- SS control expenditures, and assure that necessary-quality requirements are included in purchase orders and contracts.
d.
Disposition of electrical, mechanical and structural design changes, e.
_ Review the Architect Engineer's evaluation of fabricator's and erector's detailed designs, drawings and work instructions for reasonableness l
and completeness.
f.
Review and approve resolution of nonconformances relating to electrical, mechanical and structural portions of the generating station.
g.
Establish the plans for the modification test programs.
h.
Provide modification test acceptance criteria for modifications designed by Nuclear Engineering.
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Evaluate discrepant modification test results for modifications designed by Nuclear Engineering.
1-11 Rev. 55 3/27/89 Commonwealth Edison l
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1.4.l' (Continued)
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Perform detailed design activities and issue design documents in accordance with approved procedures.
k.
Responsible for engineering design implementation and overseeing the Site Architect-Engineer field group (at those locations where one is' established), review and comment on on-site contractor quality
-instructions and procedures, and review and' approval of CECO. Non-Conformance Reports.
The Nuclear Engineering Manager has overall. owner's responsibility for the Form N-3 Data Report and other CECO. N-type Data Reports, including stamping responsibility for ASME Section III, Division ~1 and 2, covering' concrete containments.
- ss 1.4.2-The Nuclear-Quality Programs Engineer assigned to the
- 56 Engineering and Construction Department has the responsibility to assure that the following quality assurance activities are performed.
(Also see 1.4.7.1.A) a.
Development of: quality procedures to be used by the Engineering and Construction Department in conjunction with the Commonwealth Edison Quality Assurance
- Program, b.
Review of purchase documents (i.e.,
- ss specifications, drawings, procedures and instructions) for assurance of the inclusion of quality requirements.
Review of fabricator and erector work instructions for inclusion of nondestructive and electrical testing requirements.
1.4.3 The Architect Engineer is responsible to the Engineering and Construction Department for the mechanical, structural and electrical design of the plant and for the quality of that design (except for those portions of that design included within the scope of the Nuclear Steam Supply System (NSSS)).
In this context, the Architect Engineer performs an independent evaluation of vendor proposals, designs, vendor and contractor procedures, test reports and design reports.
The Architect Engineer further performs an independent evaluation of the NSSS design.. The Architect Engineer is assigned responsibility for the document distribution for Phases I, II and III of the job.
1-12 Rev. 56 9/13/89 l
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' 1.4.4'> System Electrical-Enaineerina Denartment'
,TheLSystem Electrical Engineering Department will provide. electrical engineering technical assistance to.
4 the Engineering and Construction Department as requested
- or' assigned.
-1.4.5 Construction-I Quality-related activities in the construction area are delegated to BWR and-PHR Projects. Managers,cthe
. Construction Manager, and the. Director of Technical Services, all of whom report to the Manager of Engineering and Construction.
1.4.5.1 Constr.uction Manager
-The Construction Department is organized
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with a Construction Manager, Superintendents, and Construction Field Engineers.
The Construction Manager, who
. reports to the Manager of Engineering and; Construction, assigns the cognizant Construction Superintendent the following responsibilities:
a.
Advisor to Nuclear Engineering and to the cognizant Projects Manager for design suitability from a construction viewpoint.
b.
Coordinate requests for field revisions.
.c.
Receipt of designated items including
' furnishing necessary storage facilities.
d.
Direct and manage contractors performing maintenance and modification work which is assigned to.the Engineering and Construction Department.
e.
Verify conformance and completeness of contractor's installation or erection to specification' requirements.
f.
Supervise and approve mechanical and structural construction tests.
g.
Coordinate and provide assistance for electrical construction tests.
1-13 Rev. 56
- 56 9/13/89 Commonwealth Edison
1.4.5.1 Construction Manaaer (Cont'd)
The Manager of Engineering and Construction is assigned ASME Section III, Division 2 constructor responsibilities.
This Manager, when applicable, has the responsibility for maintaining a Level III person on staff responsible for personnel development and qualification and for the performance to the requirements for concrete inspection, as required by rules established in Section III, Division 2, of the ASME Code.
1.4.5.2 Proiects Manaaer(s) (PHR and BWR)
The Projects Manager (s) (PHR and BWR), who report to the Manager of Engineering and Construction, are delegated the authority to coordinate and manage maintenance and modification work performed under the supervision of the Construction Department.
The Projects Managers are also responsible for coordinating the engineering aspects of the modification work designed by engineering which is installed by station personnel.
The Projects Managers responsibilities include budget, schedule, defining the scope of work, and resolution of issues with engineering, purchasing, the station operating, maintenance, and technical staffs and other departments which have input to or impact on the maintenance and modification work being performed at the stations. The Projects Managers have overall responsibility to initiate those actions which are required to ensure that the assigned work is completed on schedule, in accordance with technical and design requirements, and within authorized budgets.
1.4.5.2.1 Project Managers The Project Managers, who report to the Projects Managers are delegated the authority to direct and control the on-site project groups which have scope, schedule and budget responsibilities for modification, plant addition projects, and maintenance activities which are assigned to the Engineering and Construction Department.
The Project Managers perform specific limited design activities delegated to them by the Nuclear Engineering Manager.
1-14 Rev. 56 9/d3dO8onwealth Edison
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- A 1.4.5.3 Q,irector of Technical Service.3 h..C
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.The. Director of-Technical Services, who-reports
~o to the Manager of-Engineering and Construction, L
is delegated the authority to direct and control the Technical Services Department which provides technical. support services to all Engineering and Construction departments. The' Director of Technical Services-has-responsibility for developing craft labor specifications, providing estimating-services, providing drawing management 1 services, coordinating the assignment of technical specialists, providing Quality Control services, providing performance-assessments of' contractor work, maintaining procedures, coordinating training, and providing special studies.
1.4.5.3.1 Senior Suoervisina Enaineer-Specifications The Senior Supervising Engineer-Specifications, who reports to the Director of Technical Services,-is responsible for the preparation and processing of.
Safety-Related and Regulatory-Related
-specifications for the award of service contracts for maintenance or modification work.
The Senior Supervising Engineer-Specifications performs technical evaluations of service contractors for placement on the Edison Approved Bidders List.
1.4.5.3.2 Ouality and Reliab111tv_ Superintendent The Quality and Reliability Superintendent, who reports to the Director of Technical Services, is delegated the authority to direct and control the Engineering and Construction Quality and Reliability group which provides Quality Control services and training program coordination to all Engineering and Construction departments.
The Quality and Reliability Superintendent administers the Edison Quality Control Inspector Qualification and Certification Program, oversees contractor Q.C.
certification procedures and
- 56 coordinates Non-Destructive Examination Certification Programs with System Material Analysis Department.
1-15 Rev. 56 9/13/89 Commonwealth Edison
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1 4.6-System Operational' Analysis Deoartment and System Materials Analysis Department l
The System Operational Analysis Department and_ System Materials Analysis Department-are organized as shown-in_ Figure 1-5.
1.4.6.1 The System Operational Analysis Manager has the.following responsibilities including functional control of the Division
,0perational Analysis Departments assigned to Construction:
a.
Participate in review of design specifications to verify the inclusion of' adequate electrical testing _
requirements as directed.
4 b.
Prepare procedures and conduct electrical Construction tests as directed.
,c.
Participate in the preparation and review of preoperational and start-up test procedures, as directed.
- d.. Participate in and coordinate
_preoperational and start-up. testing, as directed.
e.
Maintain Commonwealth Edison Company off-site testing facilities-and equipment required to fulfill the Department responsibilities.
f..
Provide specialized testing services and equipment analysis such as instrument and equipment calibrations (traceable to national standards).
1-16 Rev. 56
- s6 9/13/89 Commonwealth Edison
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The System Operational-Analysis Department f
.1 provides specialized field: testing services
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through its' technical staff specialists, U
L standardizing and calibration. services and f'
retention of related quality assurance l
documentation. Also, the Department is L
' responsible for. inspection and proof testing of
')
l
' electrical generation. transmission and I
distribution equipment.
'l.4.6.2-The-System Materials Analysis. Manager has.the following responsibilities involving chemistry, metallurgy,' nondestructive' examination and vibration activities:
a.
Participate in review of 'esign d
specifications.to verify proper selection of materials as directed.
.l l
- b. _PrepareJprocedures and conduct or contract tests as directed.
c.
Maintain SNT-TC-1A Level III NDE person on staff responsible for personnel and procedure development and qualification to ASME Code requirements for nondestructive j
examination.
j d.
Maintain Commonwealth Edison Company l
off-site testing facilities and equipment required to fulfill the Department l
responsibilities.
]
e.
Provide necessary assistance and expettise 3
'for baseline and in-service inspection.
i f.
Provide or contract specialized testing services and equipment analysis such as for
{
evaluation of materials.
The System Materials Analysis Department i
provides or contracts specialized chemistry, metallurgy, nondestructive examination and vibration analysis services and materials expertise through its technical staff specialists.
The Company Level III NDE person is assigned to this Department.
l 1.4.6.3 The Nuclear Quality Programs Engineer assigned
- s6 to the System Operational Analysis and System l
Materials Analysis Departments has the responsibility to assure that the following quality assurance activities are performed-1 1-17 J
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3 -Calibration is performed on test and measurement equipment as required.
-. I -
i b.. Auditing.is performed of destructive and nondestructive testing as directed.
'c.
Nondestructive test personnel
. qualifications' records are maintained.
1.4.6.3.1 Genera [jiarghouse-Stores and Materials
- s6 Manacement DeDartment The Nuclear Quality Programs Engineer
- ss is also assigned to the General Warehouse and is responsible for assuring that safety-related materials and items are procured,~ stored, and released in accordance with the applicable quality requirements.
Additionally, he maintains surveillance of the maintenance, storage, and release of the related quality documentation and materials.
- ss l '. 4. 7 tluclear Ouality Programs Manager In the case of Engineering-Construction activities, the Nuclear Quality Programs Manager reporting to the Assistant Vice President (Quality Programs and Assessment) is responsible for administration of the Commonwealth Edison Company Quality Assurance Program Requirements and Procedures established for the design, procurement, and construction organization-related activities for the-nuclear power generating stations.
Specifically, he has responsibility for the construction organization-related Quality Assurance activities and directs the Nuclear Quality Programs Engineer
- S6 assigned to the-Engineering and Construction Department.
He maintains a cognizance of the portion of the Quality Assurante Program used by, or under the direction of, the station staff for operating, maintenance, modifications, in-service inspection and Stores activities to determine that it interfaces with the design, construction and station modification quality assurance phases.
He, or-a designee, shall serve as liaison with the quality assurance organization of the NSSS Vendor, Architect Engineer, Authorized Inspector and contractors - as necessary - to verify that compliance with the applicable Codes, Standards and Regulations is met.
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For application /to activities involving the operating
'l,~*,.
~
' nuclear power generating stations,' including design, r
- S c a f...
operation,. maintenance, modification, in-service inspection, Stores and other nuclear l'
operations-related technical and administrative
' activities, the Nuclear Quality Programs Manager will L
direct the efforts of the Station Quality Assurance l
Superintendents, as well as. design, construction, and
- ss i
operations' specialists and other Quality Assurance Engineers and Inspectors responsible for quality Lassurance activities at the nuclear generating.
stations and Nuclear, Division support departments.
-The. Nuclear Quality Programs Manager.will regularly inform the Assistant Vice President'(Quality Programs and' Assessment) and the Manager of Quality Assurance / Nuclear Safety of significant quality l
assurance developments and problem areas.
The l
Nuclear Quality Programs Manager has sufficient l
authority to identify problem areas and require l
corrective action.
1.4.7.1 Site Ouality Assurantg_Synerintendent (Engineering-Construction)
The Site' Quality Assurance Superintendents (and the-Station Quality Assurance Superintendents
.at the operating stations, for the work' relating to-the construction organization-related quality assurance activities) report to the Nuclear Quality Programs' Manager and are responsible for the quality activities within their specific
' department.
Each is responsible to observe and inform the Nuclear Quality. Programs Manager of any deficiency involving-required Safety.
Analysis Reports,. Quality Assurance Manual Reports, design reports, construction reports and test reports.
Reporting to such Superintendents, where established as site activities' deem necessary, are the Site Quality
- S6 Assurance Supervisors.
The Site Quality Assurance Superintendent or other established lead person, as applicable, is responsible for reviews and audits to assure that the above requirements are met and thct nonconformances are resolved.
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A.
'Inaineerino - In addition to thel h'
responsibilities stated.herein, under Section 1.4.2, the~ Nuclear Quality Programs
- . 56 Engineer. assigned to the Engineering Department
.is responsible for surveillance and audit of-engineering activities involving construction projects and operating nuclear plants for c.
I conformance to requirements.
He maintains
-surveillance of required documentation of-
-modifications activities at operating stations-where Engineering Department responsibility is-p L
involved. ~His responsibilities are achieved through project review, surveillance and audit L
activities,. continued monitoring and day-to-day L
involvement and by support, involvement and action by the Nuclear Quality Programs Manager and by the Assistant Vice President'(Quality.
Programs and Assessment).
B.
Syitegi OoeratioDAl Analysis and System Materials Analysis - The Quality, Assurance Coordinator.
assigned to the System Operational Analysis Department and the System Materials Analysis Department is. responsible for assuring that calibration procedures _-and records are maintained for Nuclear Station test and measurement equipment.
He also maintains-surveillance of required-documentation of their respective testing and inspection activities.
His responsibilities'are achieved essentially.in the same manner as stated for the Quality
' Assurance Coordinator assigned to Engineering.
C.
Construction Site - The Site Qualit'y Assurance Group will vary with the volume of quality oriented activity at the site. Generally, the-number will vary from one to twenty or more; although, in the pre-construction and early and closing stages of construction, a Supervisor Quality Assurance or a Site Quality Assurance Coordinator or Engineer.may perform these activities alone.
1-20 Rev. 56 9/13/89 Commonwealth Edison
q, ;. 5,x The Site Quality Assurance Superintendent.or 4-
..other site Quality Assurance designee is 4
responsible for-assuring.necessary procurement requirements are provided in CECO-site.
.I procurement packages involving safety-related and ASME Code purchases, off-site vendor; L.
inspections and surveillance, surveillance of-site contractor quality activities, compliance of material and equipment with procurement document requirements, maintenance of quality records filed at the site and direction of the site. quality assurance group activities.
These responsibilities will be achieved using Quality Assurance Engineers or' Inspectors through review. surveillance and audit activities, continued monitoring and day-to-day:
involvement. The Site Quality Assurance:
Superintendent and, in turn, the Quality
- 56 Assurance Supervisors reporting to such Superintendent have the responsibility that the following quality assurance activities are performed:
a.
Development and approval of site contractor construction quality control procedures.
b, Review-and approval of site contractor quality assurance programs including.
site procedures.
c.
Advise the appropriate Engineering organization of bidder Quality Assurance capabili~ ties when requested, d.
Maintain surveillance of site contractors to verify conformance to approved quality control programs and procedures by review, surveillance and audits.
e.
Assure accumulation, filing and maintenance of quality assurance documents and records required for site construction by surveillance and audit.
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- _ - _ _ _ _ _ = _ _ _ - _ _ _ _ _ _ _ _
' f.
Review and acceptance of nondestructive-test documentation.
F
- g..Ident'ification and maintenance of files'for
-site nonconforming items and follow-up and monitor of corrective action required for disposition of site.nonconformances.
h.
Maintenance of calibration records for test
=
equipment involved in site construction' activities'through surveillance and audit, i.
Safekeeping of quality assurance documentation during construction by.
surveillance.
j.
Surveillance and approval by Quality Assurance of material receiving reports including assurance required corrective actions are completed.
k.
Review by Quality Assurance of.on-site contractor surveillance reports for quality problems and completion of corrective actions.
l.
Quality Assurance audit of on-site contractors.
m.
Review and approval of site procurement packages involving safety-related and ASME.
Code purchases to assure necessary require-ments are provided and.the' proposed vendor (s) is acceptable.
n.
Results of electrical construction tests are reviewed.
i i
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i ji 1.4.8 -Station Ouality Assurance Superintendent The Station Quality Assurance' Superintendent assigned to the operating nuclear stations reports to the Nuclear-Quality-Programs Manager on quality assurance activities involving operating, modifications, maintenance,
{
in-service inspection and Stores activities involving l
operating nuclear power stations.
The respective-Quality Assurance'fngineers or Inspectors assigned to the station report to'the Station Quality Assurance Superintendent.
i A.
Quality Assurance Engineers or. Inspectors assigned L
to a station to cover operating activities have-authority and responsibility for the surveillance
.and audit of:
l a.
The preparation and revision of the station-procedures for administration and operations.
b.
Implementation of the Operations portion of the Quality Assurance program.
c.
The completion of documentation showing that the required inspections and tests were performed.
d.
The completion of reported corrective action.
e.
The incorporation of approved engineering 1
-changes into station operating procedures.
B.
Quality Assurance Engineers and~ Inspectors assigned to the station to cover maintenance, modifications, in-service inspection and Stores activities have authority and responsibility for surveillance and audit of:
a.
Implementation of the modification and maintenance portion of the Quality Assurance Program.
b.
The preparation and revision of the Station Procedures for the modification and maintenance, c.
The completion of documentation showing that the required inspections and tests were performed for modification, maintenance and material receipts.
They shall also review and approve receiving inspection documentation.
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~
d.
The proper and-satisfactory completion of modification,. maintenance and reported corrective action. They.shall also review and approve such completion and corrective action.
e.
The incorporation of approved' engineering changes into maintenance.and operating procedures.
f.
Completion of ASME Code requirements.
g.
In-service inspection and Stores activities.
h.
. Adherence to Technical Specification requirements where involved with modification, maintenance and in-service inspection activities.
1.5 Nuclear Operations Responsibilities Nuclear Stations Division 1.5.1 Vice Presidents (BWR and PHR Operational The Commonwealth Edison Company nuclear stations are
- s6 divided into two groupings.
The one consisting of the three Pressurized Water Reactor nuclear stations and the other of the three Boiling Hater Reactor nuclear stations.
The respective Vice Presidents in charge of
- ss
.each grouping of stations in the Nuclear Division are responsible for the safe and reliable operation and maintenance of the plants assigned to them.
- ss The Vice Presidents (BWR and PHR Operations) report to the Senior Vice President (Nuclear Operations) and have responsibility for managing the nuclear generating stations associated with their respective station grouping.
The Vice Presidents (BHR and PHR Operations) are responsible for approval of requisitions for the procurement of parts, components and materials, support services and work assistance functions involving maintenance, modifications and special tasks from vendors and contractors.
The Manager of Engineering and Construction has responsibility for like approvals for the Engineering and Construction organization l-activitities involving the nuclear generating stations.
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'1 5 1 1' General Manager (BHR and'PHR Ooerations) 4 1,
.y The two General Managers (BHR and PHR Operations) are 1:
shown in Figure 1-6.
These General Managers report to the respective Vice Presidents (BWR and PHR Operations) and'each'has responsibility, as assigned, for functionally directing their assigned nuclear generating stations, through the respective Station' 1
Manager, in a safe and efficient manner and in i
accordance with Company procedures. NRC Technical Specifications and governmental regulations.
As assigned by the Vice President, they have functional control responsibility for coordinating station policies, providing support to operating station personnel, coordinating unit outages with Power Supply, and providing functional direction to the Station Managers regarding day-to-day matters.
They also act on the behalf of the cognizant Vice President for other items as delegated to them and during periods when the cognizant Vice President is unavailable.
They are also functionally responsible for obtaining and authorizing the use of services, or for required liaison or interface with other Commonwealth Edison Company departments such as: Accounting, Nuclear
. Engineering, Construction, Nuclear Services, Quality Programs and Assessment (including Nuclear Licensing),
Industrial Relations, Quality Assurance / Nuclear Safety, System Materials Analysis and System Operational Analysis.
Where assigned, they provide liaison between the Regional Nuclear Regulatory Commission's Director of the Office of Inspection and Enforcement and the respective Nuclear Division Departments.
They are involved functionally, through the Station Manager of each assigned station, in the direction'of such activities as operations, maintenance, station security, refueling, authorization of modifications performed at the Station, performance monitoring and investigation, compliance with procedures, regulations and licenses -personnel selections, training and related activities.
Their responsibilities include coordinating operating and maintenance policies and providing functional direction regarding day-to-day matters.
They maintain industry contacts with nuclear stations of other companies and transmit information from them regarding operating problems to Commonwealth Edison's Nuclear Stations.
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h 1.5.1 1 General Manaaers (BWR and PWR Qoerati Bil (Cont'd) 9
~
For common equipment and system problems, they e;
communicate such problems among stations in a timely l
manner. They have Deviation Report events, Quality L
Assurance' audits, NRC inspection reports and other L
significant events and functions reviewed for trends, effects on other units and corrective actions.
.1.5.1.2.1 STATION MANAGER Each nuclear generating station is managed, through the Production Superintendent, the Technical Superintendent, the Services Director and the Industrial Relations Supervisor, respectively, by a Station Manager who is responsible for the management of the station including industrial relations, planning, coordination, direction of the operation, maintenance, refueling and technical activities. The Station Manager is responsible for Phase III and IV and compliance with the Station's NRC Operating license, government regulations, ASME-Code requirements and the Company Quality Assurance Program.
He also authorizes the use of procedures contained in the Station Procedures Manual, and is responsbile for final approval and distribution of station reports.
He may delegate these responsibilities as appropriate to the appropriate Superintendents.
Prior to issuance of the operating license, the Production organization provides personnel to support activities of an operating nature where the preoperational test activities, including reviews of test data, are assigned to a separate organization in Projects at the construction site.
Repair and equipment maintenance needing technical review for substitution of equipment are reviewed by the Station Technical Staff and completed as maintenance activities under station management.
He supervises the Station's on-site review. function as provided in the Administrative Section 6.0 of the Technical Specifications. During periods when the Station Manager is unavailable, he shall designate this responsibility to an established alternate who satisfies the ANSI N18.l' experience requirements for plant manager.
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C 1.5.1.2.1.1 Industrial Relations Supervisgr I
The Industrial-Relations Supervisor reports to the Station Manager and performs.various personnel, employment, safety and industrial hygiene I.
activities.
i 1.5.1.3.0 Production Superintendent Reports to the Station Manager. Manages operating, maintenance and work planning
)
activities including the day-to-day operations-of the station, both during operating and-during outages. The Production Superintendent authorizes approved modifications to the Station after the issuance of an' operating license and completion of preoperational testing. He, or his designee, forwards-requests for modifications to the Project H
Hanager for transmittal to the Nuclear Engineering. Department. Also, the Production Superintendent is responsible for controlling the in-plant work of non-station personnel.
Reporting to him are the Assistant Superintendent of Operating, Work Planning Assistant Superintendent and Assistant Superintendent of Maintenance.
1.5.1.3.1 Assistant Superintendent of Doerating q
Responsibility for_the day-to-day operating and refueling activities for the station is delegated to the Assistant Superintendent of Operating.
Reporting to him are the Station Operating Engineers and Shift Engineers who.
have reporting to them the fuel Handling Foremen, Procedures Group, Radwaste Coordinator and Foremen, Station Control Room. Engineers, Shift Foremen, and the Stationmen Foremen.
j l
1.5.1.3.1.1 Doeratina Enaineers The Operating Engineers are responsible for the operation of the mechanical and electrical equipment and certain common plant systems, such as fuel handling and radioactive waste processing, assigned to them by the Assistant Superintendent of Operating. They are responsible for recommending maintenance for such equipment and for authorizing functional acceptance tests to be conducted by Operating and l
Technical Staff personnel.
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.o l'5.1.3.1 2: Shift Enainggr 6
- 1 The Shift Engineer on duty is
$3 responsible for operating the plant in compliance with the station Operating License and the station operating procedures.
During his shift. the Shift Engineer is in charge of-the r
entire plant operation and is responsible for the plant being operated in'a safe and reliable condition.
He reports to the Assistant Superintendent of Operating.
He receives direction from the Operating Engineers.
1.5.1.3.2-Assistant Superintendent of Maintenance The Assistant Superintendent of Maintenance reports to the-Production Superintendent and is responsible for directing plant modifications and the maintenance, including repair, of the mechanical and electrical equipment including instrumentation.
His responsibility includes planning work, providing on-the-job training of maintenance personnel, maintaining calibration listing for maintenance, arranging for the maintenance work and its inspection to be performed and initiating requisitions for the procurement of tools, materials, equipment and parts from vendors and services from contractors.
Reporting to him are the Master Mechanic, Master Instrument Mechanic, Master Electrician and Maintenance Supervisor.
1.5.1.3.2.1 Master Instrument Mechanic The Master Instrument Mechanic is responsible for calibrating, maintaining and repairing instrumentation at the station.
His responsibility includes planning work, providing on-the-job training of instrument personnel, setting up instruments for tests, maintaining listing of calibrated instruments, arranging for the instrument maintenance work and its inspection to be performed and initiating requisitions for the procurement of instruments and parts from vendors and services from contractors.
The Master Instrument Mechanic reports to the Assistant Superintendent of Maintenance.
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1.5.1.3.2.2 Master Mechanic 1
The Master Mechanic is responsible for maintaining and repairing mechanical equipment and structural equipment at the station.
His responsibility includes planning work, providing on-the-job l
training of mechanical maintenance personnel, arranging for mechanical maintenance work and its inspection to be performed, and initiating requisitions for the procurement of mechanical and structural parts and components from vendors and services from contractors.
The Master Mechanic reports to the Assistant Superintendent of Maintenance.
1.5.1.3.2.3 Master Electrician The Master Electrician is responsible for maintaining and repairing electrical equipment at the station.
His responsibility includes planning work, providing on-the-job training of electrical maintenance work and its inspection to be performed, and initiating requisitions for the procurement of electrical parts and components from vendors and services from contractors.
The Master Electrician reports to the Assistant Superintendent of Maintenance.
1.5.1.3.3.0 Work Plannina Assistant Superintendent l
The Work Planning Assistant Superintendent is responsible for preplanning outages, for coordinating and administering the execution of station outages, including j
providing schedules and monitoring progress, and for conducting post-outage reviews.
i 1.5.1.4.0 Technical superintendent The Technical Superintendent reports to the Station Manager and is responsible for the day-to-day Chemistry, Health Physics, Technical Staff, Quality Control and Regulatory Assurance Departments' activities at the station.
The Supervisors of the respective departments report to him.
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-,c 1.5.1.4.1 Technical Staff Suoervisor The Technical Staff Supervisor reports to the-Technical Superintendent and provides technical
-support.for plant operations, refueling, maintenance, modifications and in-service inspection and evaluates process data and.
equipment performance and adequacy of station i
procedures.
He has the responsibilities and authority as described in Section 6.0 of the l'
Technical Specifications for implementation of the on-site review function.
He is also responsible ~for the following:
i a.
Hitnessing of assigned testing for verifying completion of modifications and l
equipment maintenance.
b.
Verification of incorporation of approved engineering changes into station I
maintenance and operating procedures.
c.
Verification of completion of reported j
corrective' action.
1.5.1.4.2 Ovality Control Suoervisor The station Quality Control Supervisor reports to the Technical Superintendent and l
is responsible for the quality control activities at the Station such as:
reviewing drawings, specifications.
l Maintenance / Modification Procedures and requests'for purchase for. inclusion of applicable quality requirements; performing reculving' inspection for ASME and safety-related incoming materials and items and inspection of fabrication and installation activities; and having nondestructive examination and other testing performed as required.
1.5.1.4.3 Chemistry Supervisor The Chemistry Supervisor reports to the Technical Superintendent and is responsible for directing Chemistry and Radio Chemistry activities.
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1.5.1.4.4 Realth Physics Supervisor i
I The Health Physics Supervisor reports to the Technical Superintendent and is responsible for directing the Health Physics activities.
He is responsible for the implementation of a Station Radiation i
Protection Program to maintain radiation I
exposures as low as reasonably achievable (ALARA).
1.5.1.4.5 Regulatory Assurance Suoervisor The Regulatory Assurance Supervisor reports to the Technical Superintendent and is responsible for tracking of commitments; authorizing and analyzing LER's and DVR's, including trending; directing the process of preparing and approving correspondence, reports and responses involving Deviation Reports (DVR's) and Licensee Event Reports (LER's), Quality Assurance deficiencies, NRC correspondence and responses, OPEX's, Technical Specification changes, FSAR updates, and INP0 and Authorized Nuclear Inspection evaluations, and monitoring regule. tory compliances and performance.
1.5.1.5 SSr_Ylrefi._Dhedcc The Servir?s Director reports to the Station Manager and manages intra-station services and coordinates Services provided to the station from outside the station.
Reporting to him are the Stores, Training, Office, Accounting, Security ar,d M75 (Management Information System) Supervisors.
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1~5.1.5.1 Sintes Suoervisor-The station Stores Supervisor reports to the Services Director. The station Stores Supervisor receives-functional direction, b}
which includes all Stores Instructions, from the Director, Stores and Materials ess Management Department. The Stores.
Supervisor.is responsible.for the administration of the Station Storeroom including all procurement, receiving inspection, storing and issuing of capitalized spare parts, materials, supplies and equipment. His responsibilities include :oding of all stocked items; verifying the receipt of Quality Assurance documents specified in the procurement documents for spare parts, welding materials, other materials and equipment; maintaining inventory records
'for all stocked items at the station; and complying with special handling and storage instructions.
1.5.1.5.2 Offia_Suoervi sor.
The Office Supervisor reports to the Services Director and is responsible for directing the activities of the station's clerical staff and for maintaining files'of quality assurance documents assigned to him.
1.5.1.5.3 SECRrjtv Suoervisor n
The Security Supervisor reports to the Services Director and is responsible for.
directing the station's security plan activities and supervising the on-site security activitias.
1.5.1.5.4 Trainino Suoervisor The Training Supervisor reports to the Services Director and is responsible for the training and retraining of operating, technical support and maintenance personnel.
His responsibility includes planning, schedu' ling, preparing, presenting and documenting completion of training.
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1.6 Equality P_tocrami and Assessment p
1.6.1 Assistant'Vice President (Ouality Proarams and Assessment) u
.The Assistant Vice President (Quality Programs and Assessment) reports to_the Senior Vice. President (Nuclear Operations.) and has responsibility for management of all Quality Verification activities for the Nuclear Operations-Division..The primary responsibility of the Assistant Vice President (Quality Programs and Assessment) is to direct the conduct of the Nuclear Quality Program and Independent Safety Engineering Group activities, through the Nuclear Quality Program and Safety Assessment Departments.
In addition, the Assistant Vice President 1
implements a technically expert, integrated Quality.
Verification Program focused on the quality of overall nuclear. performance including planning, implementation, corrective. actions, and review for effectiveness of all Nuclear Operations. Program activities related to the safe and reliable generation of nuclear power.
This Quality
' Verification Program is implemented through the integration of the activities of the Nuclear Quality Program, Safety Assessment, Performance Assessment, Nuclear Licensing and Performance Improvement Departments.. The Assistant Vice President also directs the activities of a staff which develops programs, plans, information management systems, and training programs to support the activities of Quality Programs and Assessment Departments.
^1. 6,1,1 Nuclear _LLcensina Manaagr The heclear Licensing Manager reports to the Assistaat Vice Presidant (Quality Programs.and Ashr;ssment) and ha3 responsibility 3 for acquiring tnd maintaining Nuclear Regulatory Comn.ission (US 4RC) and Illinois Department of Nuclear Safety (IDNS) licenses and oermite.
The Nuclear Licensing Manager assures timely reporting on matters related to these licenses'and permits to appropriate levels of raragement and supports tne integration of these activities with related l
Quality verification activities in the Quality Programs and Assessment Group.
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1.6.1.2 Performance Assessment Manaaer The Performance Assessment Manager reports to the Assistant Vice President (Quality Programs and Assessment) and directs non-reguitory.
performance assessment activities within the nuclear division and supports the integration
.of these activities with related quality verification activities in the Quality Programs and Assessment Group.
He maintains a staff of highly qualified technical experts in key areas, and through their efforts, identifies areas of weakness and recommends.necessary corrective actions.
He coordinates followup to evaluate the effectiveness of corrective actions in addressing identified weaknesses and ensures that appropriate information is communicated to other potentially affected nuclear stations.
He provides advice and technical guidance for the resolution of generic and plant specific performance problems.
1.6.1.3 Nuclear Ouality Programs Manaaet The Nuclear Quality Programs Manager reports to the Assistant Vice Presider;t (Quality Programs and Assessment) and is responsible for administration of the Commonwealth Edison Company Quality Assurance Program Requirements and Procedures established for the operating phase of nuclear power generating stations.
These activities include administration of the Ouality Assurance Program for design, cperation, maintenance, modification.1, in-service inspection, Stores, and other nuclear operations related technical and administrative activities.
Specifically, he will direct the efferts of the Site and Station Quality Assurance Surserintendents, as well as design, construction, and operations
- 56 specialists and other Quality Assurance Engineers and Inspectors responsible for quality assurance activities at the nuclear l-generating stations and Nuclear Division support departments.
The Nuclear Quality Programs Manager will regularly inform the Manager of Quality Assurance / Nuclear Safety of significant quality assurance developments, activities and problem areas.
He has the authority and organizational freedom to identify problems, to initiate, recommend and provide solutions, and initiate work stoppage actions as deemed needed.
The Quality Assurance organization is independent of the groups and individuals directly responsible for performing specific activities to which such quality assurance is applicable.
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.v 1.6.1.4 Safety Assessment Manager
~-i The-Safety Assessment Manager reports to the Assistant Vice President (Quality Programs and Assessment) and directs the oversight of.
assessment activities related to operating experience developed from inside and~outside the Company in order to. support Nuclear Operations in identifying. actions to improve nuclear station performance and, through the Onsite Nuclear Safety Groups, to review and evaluate station safety-related operating events and observe operating and maintenance activities in the station.
The Onsite Nuclear Safety Groups (ONSG's) perform the role of Independent Safety Engineering Groups (generical_1y referred to as-ISEG's) which are required by NRC regulation at.
all nuclear stations licensed after the Three-Mile Island incident.
The Manager also. directs the activities of the onsite nuclear safety support group, which serves as the ONSG offsite group. The support group provides technical assistance and coordinates resources for the ONSG's.
1.6.1.5 Ettfars nce IR4rovement Manager' ine Performance Improvement Meaper reportc to the Assistant Vice President (Qun?lty Programt anrf Assessment) and directs the.cqtisition of external performance assessment information and provides recommendations and assistance to nuclear station and corporate management to promote improved station and. corporate performance.
The Performance Improvement M1 nager assures that ind.ntry and generic regulatory issues are aosquately reviewed and monitored and advises corporate management of impending actions, tracks operating activities to detect possible declining trends, investigates selected events to identify root causes and recommend corrective actions, and i
provides support.to other Quality Programs and Assessment Departments.
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1.7.1 General Manaaer of Nuclear Services I
The General Manager of Nuclear Services., who reports to the Senior Vice. President (Nuclear Operations), directs
-I and controls.the activitics of the' Nuclear Services Department, including health physics, chemistry, radioactive waste management and emergency preparedness for the Nuclear. Operations area.
He also.is delegated the authority to provide timely technical support to the' Nuclear Operations area for training, nuclear fuel services, and management services.
In the execution of this delegated authority he will.be responsible to the Senior Vice President (Nuclear Ooerations) for organizing, planning and executing the elements of nuclear support services in an effective and efficient manner.
The General Manager of Nuclear Services is the primary Company participant in industry groups and' task forces in the areas of waste compacts and low level waste disposal.
'1.7.1.1 Production Trainina Manager The Production Training Manager, who reports to the General Manager of Nuclear Services, provides direction and control for the activities of.the Production Training Department (PTD), located at the Production Training Center.
Production training includes four major working groups.
These are Operations Tr61ning, Technical and Maintenance Training, Program Development, and Support Services.
The PTD develops and periodically revises training programs designed to meet the overall needs of the Nuclear Operations area. The PTD also coordinates training programs for production management, and develops and implements instructor training programs. To ensure that the training effort is fully effective, the PTD also designs and implements training program evaluation plans.
1.7.1.2 Director of Manaaement Services The Director of Management ~ Services, reporting to the General Manager of Nuclear Services, directs and controls the activities of the Management Services Department including Management Information Services, performance analysis, office management, minority business, I
and special services.
The department is a source of general administrative guidance and services to the entire Nuclear Operations area.
In addition, the Management Services Department provides daily staff support to the Senior Vice President (Nuclear Operations) and to the nuclear stations.
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l.7.1.3 Nuclear Fuel Services Manaaer g
The Nuclear Fuel Services Manager reports to the General Manager of Nuclear. Services and is L
delegated the authority for the direction and control of the Nuclear fuel Services Department (NFS).
NFS provides in-core nuclear fuel management, safety analysis, and technical support to station personnel and other departments regarding fuel and other reactor core issues.
The NFS organization includes Computer. Methods Development, Nuclear Design, Safety Analysis, Plant Support, Fuel
-Reliability, and Core-Materials Technology.
The Department is accountable for the development of analytic methods and for the performance of reactor.neutronic, transient and safety analysis studies to support licensing.
and plant operations.
1.7.1.4 Emeraency Preparedness Director The Emergency Preparedness Director, who reports to the General Manager of Nuclear Services.. supervises the activities of the Nuclear Operations Emergency Preparedness Department.
This Department has control of the environmental radiological'and meteorological monitt, ring programs; the Nuclear Station Emergency Planning (GSEP) program; and the maintenance of six emergency response facilities and six warning stren networks Additionally, the Emergency Preparedness Director performs a liaison function betweer.
1111nois, Iowa, and Wisconsin emerger.cy services groups and the Vice Presidents (PHR and BWR Operations).
1.7.1.5 Rid 11 tion Protecilon Directg The Radiation Protection D' rector reports to the General Manager of Nuclear Services and is-delegated authority for the development, l
Implementation, and control of Corrpany radiation standards and procedures and the corporate ALARA program. Additionally, the Radiation Protection Director provides functional control over the station Radiation Protection Departments.
L 1.7.i.6 Chemistry Services Directu l
The Chemistry Services Director, who reports to L
the General Manager of Nuclear Services, supervises a staff which supports the nuclear stations in the areas of analytic chemistry, chemical engineering, radiochemistry, process chemistry control, radioactive wastes, and applicable computer software.
1-37 Rev. 56
- ss 9/13/89 Commonwealth Edison
1.8 Director Corocrate Security - Nuclear Security This Director for Nuclear Security reports to the President and
~
.4 Chief Operating.0fficer. The Director is responsible for insuring that security programs at the nuclear power stations.
effectively meet all. commitments to, and the regulations of, the Nuclear Regulatory Commission.
1.9. System Power Sucolv Department D
The System Power Supply Manager reports to the. President and Chief Operating Officer, and is responsible for managing the l
bulk power system with the objectives of safe operation, reliable service and efficient utilization of Company-owned o
production. facilities.
1.9.1 The System Power Supply Manager has the following responsibilities:
a.
Scheduling power generation.
b.
Purchase and sale of power-from and to other utilities.
c.
Coordinating the operation of the Commonwealth system with the Mid-America Interconnected Network and other interconnected utilities.
d.
Final scheduling of outages for generating stations for corrective and preventative maintenance.
l.10 Stores and Materials danacement Deoartagni
- ss The Director for this Department has the following nuclear-associated Stores activities responsibilities:
- i. Control of spare parts inventory; b.
Coordinating procurement of spare pr.rts and materials and-assuring that technical.nnd quality assurance requirements are specified in procuremer,t documents; and c.
Liaison with t.c.npany stations and departcants, manufacturers and other utilities on spare part matters.
The Support Services staff of this Department, in particular, review station purchase requisitions for safety and ASME Code related spare parts, material and equipment to assure that requirements for Quality Assurance are specified as required and that Stores Code Numbers are assigned to spare parts to be stored 'at the station.
1-38 Rev. 56 (9/13/89)
Commonwealth Edison n
y~
{
J-1.11 Ouality Assurance / Nuclear Safety Policy and Oversicht Deoartment
. hereinafter referred to as " Quality Assurance / Nuclear Safety
- S6
(
L **
Department")
~
1.11
'Manaaer-of Ouality Assurance / Nuclear Safety The Manager of Quality Assurance / Nuclear Safety reports to the Chairman and CEO. This Manager manages the
'Off-Site Review and Investigative. Group, the Central Committee for Quality Assurance Policy, and the Off-Site Audit Group.
The primary responsibilities of'the Manager of Quality Assurance / Nuclear Safety are to:
a.
Develop and. implement Corporate Policy for quality assurance and nuclear safety activities for the design,' procurement, construction, and operation of the Company's nuclear power facilities and interface activities with the Nuclear Regulatory Commission, Office of Inspection and Enforcement, Region III., and the Authorized Inspection Agency.
b.
Promptly report any unsafe plant conditions or.
practices to the Chairman and CEO of the Company.
c.
Assure that findings resulting from off-site audits and recommendations of:the Off-Site Review Group are satisfactorily resolved.
d.
Assure implementation and consistency of the Quality Assurance Program through control of the Quality Assurance Manual.
e.
Review the varicus phases of nuclear safety (design, construction, optration, and maintenance) to provide for integration of all safety-relt.ted considerations.
f.
Initiate recommen6ations to improve safety at r,uclear plants.
.l g.
Establish spectf f e audit training requiremer.tr and issue auditor and lead auditor certification for l
individuals who have successfully completed those auditor training programs and met Standards requirements.
h.
Establish qualification requirements and issue
. qualifications and/or certifications to such requirements, as required by Standards and Regulatory requirements, for individuals performing Quality Assurance inspection, surveillance and audit activities.
1-39 Rev. 56 (9/13/89)
Commonwealth Edison
h 1.11.1.1 Suoerinteadent of Off-Site Re91ew
~
The Superintendent of Off-Site Reviet reports to~the Manager of Quality Assurance / Nuclear
. Safety and.is appointed by the Manager of
~ Quality Assurance / Nuclear Safety with approval by the Chairman and CEO.
.=
The Off-Site Review Participants are appointed by the Superintendent of Off-Site Review.
Each operating nuclear station has two reviewers assigned to it in the Off-Site Review Group.
They are identified as the " Senior-Participant", assigned fu111 time to the designated station, and as the "Other Participant".
Primary responsibilities of the Superintendent of Off-Site Review are to:
a.
Provide direction for.the review and investigative function.
b.
Appoint the Senior Participants and their alternates.
(
c.
Select other participants for the function.
p t.s found necessary.
'd.
. Select participants to provide appropriate interdisciplinary coverage for the subject i
under review.
e.
Independently review the findings and recommendations of the participants to the L
review.
f.
Approve reports of the Off-Site Review and l-make recommendations as appropriate.
I' g.
Approve and report, in a timely manner, findings of noncompliance with NRC requirements to the Station Hanager, Vice President (BWR or PWR Operations), Manager of Quality Assurance / Nuclear Safety, Assistant Vice President (Quality Programs L
and Assessment), and the Senior Vice l
President (Nuclear Operations).
1.11.1.2, Superintendent of the Ouality Assurance Central Committee The Superintendent of the Quality Assurance Central Committee reports to the Manager of Quality Assurance / Nuclear Safety and is appointed by, and reports to, the Manager of Quality Assurance / Nuclear Safety with approval by the Chairman and CEO.
1-40 Rev. 56
- S6 9/13/89 Commonwealth Edison
..I d' Ths primary responsibilities of thel i
Superintendent of the Quality Assurance Central Committee are to:
s a.
Develop strategic Corporate Qual 1ty-Assurance. policy for the_ design, L-procurement, construction, and operation of L
the Company's nuclear and fossil power l
' facilities.
b.
Develop.and obtain approval of inter-departmental agreement documents'to facilitate the implementation of Quality Assurance and Nuclear Safety policies.
c.
Assess potential Quality Assurance problem
. ss areas through review of both Company internal and external documentation.
d.
Maintain, in an up-to-date condition, the Quality Assurance. Manual for both the nuclear and fossil divisions.
e.
Assist Company personnel in the use and 1
implementation of the Quality Assurance
- s6 Manual.
f.
Develop and maintain the training program requirements and issue certification documents for all personnel filling the position of a quality assurance function.
- 56 except audit activities.
9 Report difficulties in the implementation
~
of the Quality Assurance Program or. Quality Assurance Policy developed by the Central Policy Committee directly to the Manager of Quality Assurance / Nuclear Safety.
'l.11.1.3
- Suoerintendtat_c" OffSSite Auditi Tne Superintendent of Off-Site Audits reports to the Manager of Quality Assurance /Nucleer Safety with approval by the Chairman and CEO.
The responsibility'es cf the Superintendent of Off-Site Audits are:
a.
Managing the corporate off-site vendor audit program.
b.
Managing the Off-Site Audit Program of the various organizations of the Nuclear and Fossil Stations Divisions to obtain an independent assessment of the implementation of the Quality Assurance Programs for these two Divisions.
c.
Managing the Off-Site Audit Program of the Nuclear Steam Supply System (NSSS) Vendors and Architect Engineers (AE).
1-41 ReS.orgronwealth Edison 9/13/89
g d.
Managing the. evaluation program.of vendor
-quality assurance programs (fossil and nuclear).
I e.
Maintenance of the Quality Approed Bidders List for both fossil and nuclear vendors.
p f.
Develop and maintain the. training program requirements for all personnel actively L
participating in audits, g.
Represent the Company in joint utility
- 56 audit efforts and manage internal programs for utilization of said joint audits.
h.
Managing the annual assessment of Company adherence to the Quality Assurance Program.
1.
Report significant problems identified during the audit process to the Manager of QA/NS.
1.11.1.3.1 Nuclear Fuel Fabrication-Insoector The Nuclear Fuel' Fabrication Inspector reports to the Superintendent of Off-Site Audits and has the resp'onsibility for.
surveillance inspection and audit of fuel fabrication at vendor's plant, overview of the fuel control at the nuclear stations and keeping abreast of fuel assembly problems and concerns.
1.12 Purchasino Responsibilities-1.12.1 Manaaer of Fuel The Manager of Fue) is responsible for Commonwealth's procurement of nuclee.r fuel to specifications furnished by the Nuclear Fuel Services Department.
He reports to a Vice Prt.sident on matters involving such fuel.
Diy15 S0_Q9fntinns Reroordtilitiei 2.0 I
2.0.1 Substation Construction Departuent The Substation Construction Department performs electrical modification at nuclear generating stations as directed by the Production Superintendent, or designee, or the Engineering and Construction Department Construction Superintendent, or designee, and in accordance with the provisions of this Quality Assurance Manual.
Substation Construction Site Specific Procedures are used to control specific processes and procedures unique to electrical construction and installation.
1-42 Rev. 56 9/13/89 Commonwealth Edison
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- '""3 to Maintenance Dept.
gsme gg a (s.............. >
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Dresden &. Zion
(
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9/13/89 t a c...*' 3 Rev. 56 1-52
- 2. QUALITY ASSURANCE PROGRAM 2.1 General The Commonwealth Edison Company has extensive experience with the development, scheduling, design, construction and operation of electric generating facilities.
It has pioneered in commercial nuclear power. Commonwealth Edison Company and its consultants and vendors have established designs and specifications for compliance with applicable regulations, ASME Code and National Standards to assure installations of utmost safety and reliability.
Commonwealth Edison Company has attained qualified equipment vendors and contractors through experience, evaluation at vendor plants and site surveillance during plant erection.
These efforts provide assurance that compliance with applicable design specifications and codes is maintained and a high level of reliability is achieved.
2.2 Policy It is the policy of Commonwealth Edison Company to assure a high degree of functional integrity of the equipment, structures and safety-related systems of its nuclear generating facilities, the performance of which are essential to the prevention of nuclear accidents that could cause undue risk to the health and safety of the public, or to the mitigation of the_ consequences of such accidents in the unlikely event they should occur.
These systems, equipment, and structures will.be identified, designed, fabricated, erected, tested and operated to the criteria and requirements of ASME Boiler and Pressure Vessel Code Sections III and XI, as referenced in the SAR applicable to a specific unit at the time of engineering, construction and major modifications, Appendix B to 10CFR50, Subpart H to 10CFR71, and the mandatory requirements of ANSI /ASME NQA-1-1983 (Regulatory Guide 1.28 Rev. 3 Dated 8/85) with the provision that CECO suppliers / vendors maintain a quality assurance program which satisfies ANSI /ASME, NQA-1-1986,. ANSI N45.2 Standards not covered by ANSI /ASME NQA-1, and
- ss N18.7 Standards (or the ANSI /ASME N45.2 series of standards for previously accepted non-ASME quality programs).
The commitments to Regulatory Guides and Standards shall apply to each respective station as listed below.
Also, Commonwealth Edison commits to comply with 10CFR Part 21
" Reporting of Defects and Noncompliance" and with the Regulatory position of the following Regulatory Guides and the requirements of the following ANSI Standards as listed for each station.
2-1 Rev. 56 9/13/89 Commonwealth Edison
a L I.
Dresdan, Quad Cities and Zion Nuclear Power Stations b
'1.28;- Rev.
3, 8/85; 1.30 (Safety. Guide 30 - 8/72); 1.33' 41 (Safety' Guide 33 - 11/72); 1.37 3/73; 1.38 - 3/73; 1.39 -
3/73; 1.54 - 6/73; 1.8 (Safety Guide'8 3/71); ANSI.N45.2.8-74
-(Draft.2, Rev.
3, 4/74); ANSI N45.2.5-73 9 Draft 3, Rev.
1,
.g 1/74)
II.
LaSalle County Nuclear Power Station 1
1.28
.Rev.
3, 8/85; 1.30 - Rev.
O, 8/72; 1.33 - Rev. 2; 1.37
- 51
- Rev.
O, 3/73; l'.38 - Rev. 2; l.39 - Rev. 2; 1.54 - 6/73; 1.8
- Rev. 1-R; 1.94 - Rev. 1; 1.116 - Rev.
0-R, 6/76 III.
Byron-and Braidwood Nuclear Power Stations gg 1.28 - Rev.
3, 8/85; 1.30 - Rev.
O, 8/72; 1.33 - Rev. 2; 1.37
- Rev.
O, 3/73; 1.38 -'Rev.
2; 1.39 - Rev. 2; 1.54 - 6/73; 1.64 - Rev. 2; 1.8 - Rev. 1-R; 1.94 - Rev. 1; 1.116 R, 6/76 41
' Exceptions or alternatives to this Topical Report for specific plants identified in the Safety Analysis Report or Technical Specification will take precedence over commitments in this Topical Report.
.It is also the' policy of Commonwealth Edison Company to assure a high degree of functional integrity for its generating facilities so as to achieve high availability of these facilities for the production of electrical power and to maintain overall quality levels which will achieve the foregoing in'a safe, effective and economic manner.
The Quality Requirements and Quality Procedures of the Company Quality Assurance Program Manual (see Appendix A for Program Manual Index) as described herein, document the written policies and procedures of the program and are augmented by other written Depart-ment and Station procedures and instructions.
In the Quality Assurance Department controlled Quality Assurance Department instructive, directive and procedural type documents are used to further explain in specific detail certain department activities as deemed needed.
Such documents may cover items such as training, training' program,' review of procurement documents, personnel qualification and certification, maintenance and updating of ASME Code
.inforroation on the computerized Quality Approved Bidders List, etc.
In addition, Site Quality Assurance Departments may have controlled Site instructions to prcvide detailed explanations and methodologies l
for implementing the Qus]ity Requirements and Quality Procedures, and L
to provide instructions for other site quality activities as necessary.
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Construction, Quality Assurance and Engineering areas, as necessary,
'for reference. Distribution of and revisions to this listing are controlled and approved by the Nuclear Engineering Department.
The requirements in ASME Section III Article NCA-4000.shall' be applied to Section III systems and components including concrete containments.
The 18 Criteria of Appendix B of 10CFR50 will be applied to safety-related systems and components for design, construction, maintenance,-refueling, in-service inspection, repair and station modifications.
Criteria 1, 2, 5, 6, 10, 11, 12 and 14 to 18 and Regulatory Guide 1.33 will be applied to operation of safety-related systems and components.
The Manager of Quality Assurance / Nuclear Safety will be responsible for assuring a regular review of adequacy of the Quality Assurance Program. Periodic written reports will be provided to upper management covering activities and problems involving the requirements of the Quality Assurance Program. Also, an overall report will be made annually to upper management for their assessment as to scope, status implementation and effectiveness of the Quality Assurance Program to assure that it is adequate and complies with 10CFR50, Appendix B Criteria.
Ar. Independent management audit for upper management shall be conducted on a two year cycle to evaluate the status and adequacy of the Quality Assurance Program..This annual assessment is preplanned and
' documented.
Recommendations for corrective action are identified
- M and tracked.
The Quality Assurance Programs in the Commonwealth Edison Company Quality Assurance Program Manual and revision thereto are approved and controlled by the Manager of Quality Assurance / Nuclear Safety and may only be revised with his approval. The Quality Requirements and Quality Procedures shall be revised in concert with addenda to reflect revisions in Section III of the ASME Code.
Such revisions to the Quality Requirements involving ASME Section III shall require acceptance by the Authorized Nuclear Inspection Agency and notification plus evidence of such acceptance to the Authorized Nuclear Inspector prior to issuance. Concurrently, a copy of the updated Corporate Quality Assurance Manual shall be made available to the Authorized Nuclear Inspector at stations where Code work is being done.
Programmatic changes to the Program are submitted to the NRC Repon for acceptance prior to imple:nentation, Organizational changes are submitted within thirty days of the effective date. Changes which do not reduce commitments must be submitted to NRC at least annually for changes affecting operati-onal stations, and within 90 days of implementation for changes affecting.
stations under construction. Changes which reduce commitments must be submitted to and approved by NRC before being implemented.
These requirements also extend to the " principal contractors"--the Architect-Engineer and the Nuclear Steam Supply l
System vendor for each project.
Initial assurance that the current j'
Q.A. program description for each of these contractors has NRC approval, either as a part of the Safety Analysis Report or as a separate Quality Assurance Topical Report applicable to the respective projects, will be established by audits.
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audits will also assure:that each principal' contractor has audited its subcontractors, so that. changes in those firms' respective programs have not abrogated. commitments in.the principal contractors' programs.and that such programs. continue to meet 10 CFR I
50 Appendix 1B requirements. Quality. Assurance Procedures involving engineering, construction, operating, maintenance,' modification, in-service inspection and Stores activities, and. revisions thereto, are signed by the Head of the principally involved department (s) and
- 55 approved by;the Manager of Quality Assurance / Nuclear. Safety.
Approval of the Quality Assurance Program Manual Indexes indicates approval of respective changes to the individual pages of the Corporate Quality Assurance Manual.. Sections 2, 5 and 18 of the Quality Procedures provide the procedures for implementing this section of the Quality Requirements.
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appropriate corrective action shall be taken. The Projects Engineering-
- 55 Manager, where established, prior to plant start-up, and'the Nuclear Engineering Manager..after plant start-up for plant modifications, or by
-* ~ ' *
.the Nuclear Fuel Services. Manager for fuel or in-core related matters for plant operations, or their respective agent or designee shall certify that a review of the Design Report / Load Capacity Data Sheets has
~been conducted to assure that all the Design Specification and applicable Code requirements have been considered. Copies of the certification shall be attached to the copies of the Design Report, design drawings, stress calculations and Design and Construction Specifications and Reports which are made available, as applicable, to the Authorized Nuclear Inspector for review and certification and the enforcement authorities having jurisdiction over the nuclear power plant installation as provided by ASME Section III of the Code for Classes 1, 2, 3, CS, MC and CC.
Design information transmitted across interfaces shall be documented, controlled, and include the status of the information or document.
3.2 Desion Changes Changes to drawings used for construction.from the corresponding drawing used for stress analysis shall be certified, by the person or organization responsible for the stress analysis calculations, to have been satisfactorily reconciled with those calculations.
Design changes are controlled through document revisions resulting from design change requests and/or design change notices and are reviewed and evaluated in the same way as the basic design documents.
Site and Station design change requests will be reviewed by the Site Quality Assurance Superintendent, or designee, Station Quality Assurance Superintendent, or designee, Technical Staff Supervisor, Projects Engineering personnel or Nuclear Engineering personnel after
- 55 plant start-up for plant modifications, and/or Architect Engineer, as applicable, and will be approved by Projects Engineering or the Nuclear
- 55 Engineering Department after plant start-up for plant modifications after which the approved change will be incorporated in design documents, approved, released and distributed.
The extent of the evaluation will be determined by the complexity of the change and its safety-velated function with respect to the original design. Coordir.ation of review and evaluation of design changes will be by Projects Engineering or the Nur.ierr Engineer'at
- 65 Department after plant startup #or piert modifications.
The rc; trol of documents will tr. maintainej within the sy; tem described in Quality R
Requirement 6.0, "Decument Contro)."
Plant modifications will be evaluated to accordance with the requirements of 10CFR50.59 and to the requirements of the ASME Boller and Pressure Vessel Code Section III and will et submitted to the Manager of Quality Assurancc/Muciear Safety. Superintendent of Off-site
- L5 Review and the Froduction Superintendent.
Also, for Code work thfe modification will be reviewed w*th the Aothorized NJclear Inspector who will then stipulate the inspections he intends to make prior to implementation of the modification work.
The Production Superintendent authorizes the modification.
The Technical Staff Supervisor reviews and 3-3 Rev. 55 3/27/89 Commonwealth Edison
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's approves'the proposed modification and is responsible for verifying that operating procedure changes are accomplished as to station modifications.
The' station Training Supervisor 1s responsible that required training concerning plant modifications is accomplished for responsible plant personnel where the performance of their duties may be affected. Quality Assurance assures such training is completed.
The Superintendent of Off-Site Review reviews and
- SE approves proposed modifications to plant systems and components involving a revision to the Technical Specifications or a previously_
unreviewed safety question.
Evaluation and approval of the substitution of equipment is performed by the Technical Staff Supervisor and either the Production Superintendent. Assistant Superintendent of Operating or Assistant Superintendent of Maintenance.
Projects Engineering, Nuclear. Engineering or equipment vendors provide engineering analysis as required by the design specification.
Projects Management or Nuclear Engineering shall assign an organization to verify installation.of modifications in accordance with design and quality assurance requirements. When modifications cannot be completed in accordance with drawings and specifications, a review for disposition will be requested of the cognizant Engineering Department.
The verifying or checking of design features and modifications is done by qualified individuals or organization other than those who prepare the original design or design modification but who may be from the same organization.
The assigned installation department furnishes Projects Engineering and, after plant start-up for modifications, the Nuclear Engineering Department, as-built information to review as to correctness and to issue as-built drawings.
Test data required by Projects Engineering involving initial construction and by the Nuclear Engineering Department involving modification to verify the satisfactory installation of components is obtained by organizations designated by them.
After completion of construction, station operating personnei and station Quality Control personnel verify the satisfactory final testing of aystems required by Projects Engineering or huclear Engineering. Also, where applicabie. before
(
the component or appurtenance is placed in service, copiet ef the
(
appropriate ASME Data Reports and Certified Design and Cor.struction Reports and Design and Construction Specifications are fi'ed at the location of the installation and nade available to the Authorized Nec1 Ear Inspector and the State of Illinois enforcement authorities having jurisdiction. Comcieted Data Report Form N-3, however, shall be filed by CECO with such enforcement authority having jurisdiction.
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- 4. PROCUREMENT DOCUMENT CONTROL The procurement documents include equipment specifications or specifications for services, each of which are reviewed or evaluated as described in Section 3 for design and construction, and design and construction for modifications. Changes to procurement documents are subject to the same review and approval requirements as the original documents. Contract or purchase order documents are reviewed by the NSSS Supplier for NSSS items and by Edison and the Architect Engineer for non-NSSS items to insure that all requirements have been incorporated specifically or by reference.
Records pertaining to the review and evaluation of procurement documents involving initial plant installations and plant modifications will include, in whole or in part, minutes of meetings, comment letters, design review records, project quality assurance audits and a copy of the original design document marked with comments or latest revisions.
These records will be kept in vendor files and/or applicable Commonwealth Edison Company department files during the Engineering, Construction and Operation phases of the generating station.
The quality assurance and engineering requirements including documentation requirements, will be stated, as applicable, in the bid package, contracts and purchase orders for safety-related and ASME Code related procurement. Also, the review for suitability of application of commercial grade or previously approved materials, parts and equipment that are safety-related will be imposed on vendors. Where material, equipment, systems or services require contractors to adhere to ASME Code requirements or have ASME Certificates of Authorization, these requirements will be contained in the procurement documents. Quality Assurance Program requirements, as well as requirements for subtier procurement, are included as regulatory, code, standard and design requirements.
Similarly, the required methods of identification, preservation and packaging, and methods of controlling conformance to acceptance criteria are covered by these documents. Quality Assurance Program requirements are included in initial procurement contract and rev8.ewed for acceptability by Quality Assurance to provide for i
implementation of the accepted quality assurance program, vendor
- 56 evaluation, inspection and test planning, vendor surveillance, witnessing of inspection control points and inspection documentation.
Also, requirements for vendor documents, such as 4-1 Rev. 56 9/13/89 Commonwealth Edison
Instruction,_ procedures, drawings, specifications and vendor quality l
assurance records to be prepared, submitted or made available for review or approval are included.
In addition, included in the procurement documents are provisions for right-of-access to vendors'
. facilities and work documents for inspection and audit and for vendor reporting and disposition of nonconformance from procurement requirements.
Procurement control is by_ CECO with procurement of major L
l equipment and items being purchased by the General Office Purchasing L
Department and procurement of standard type materials and items being L
performed by its satellite purchasing organization, where established i
at certain sites.
For procurement initiated by Projects Engineering or i
Nuclear Engineering, the cognizant Project Manager or Design Superintendent / Supervisor, or designee, as applicable, prior to submittal of the Engineering Proposal Request to the Director of Procurement, prepares a suggested list of prospective biddg; ; for each specification from the applicable Approved Bidders' List using input from the Architect Engineer and the cognizant Purchasing Department Buyer.
The Bidders lists are established using such factors as past experience, experience of other utilities, or specific qualification surveys.
For Code work, the desk survey shall be limited to determination that a supplier or contractor is the holder of a valid Certificate of Authorization for.the scope of work involved or for determining if a supplier or contractor is potentially qualified.
The final list of prospective bidders, as l
well as the person agreeing to the list as indicated on the Nuclear Proposal Request (NUPR), is approved by the cognizant Project Manager or the Nuclear Engineering Manager for modifications or designated alternates.
The persons agreeing to the list are key representatives of Projects Engineering and Projects Construction, or the Nuclear Engineering Manager and the Engineering and Construction Department after plant start-up for modifications, BHR/PHR Nuclear Operations, the Purchasing Department and, when requested, the Architect Engineer. Where bids are obtained from prospective Lidders other than those listed on the Quality Approved Bidders' List maintained by i
the Quality Assurance / Nuclear Safety Department for the Purchasing
- ss Department, such bids shall be indicated as trial bids and shall be treated as trial bids until the bidders are evaluated and approved as acceptable prior to award.
Upon completion of the evaluation of the proposals from approved bidders for either original plant or plant modification items or services, the responsible Project Manager or Design Superintendent / Supervisor shall have prepared and, after final review and approval indication by the cognizant ENC Nuclear Quality Programs
' 95 Engineer, shall have transmitted to the Purchasing Department a letter of recommendation and a purchase requisition.
The purchase requisition and/or letter will 4-2 Rev. 56 9/13/89 Commonwealth Edison l
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incorporate, by reference, those documents such as specifications, drawings, proposals, etc., and any conditions of award which form the basis for the evaluation and award.
Purchasing, based on the recommendation letter, its own evaluation and the purchase requisition, shall conduct necessary negotiations and clarifications and make the award to the' successful bidder. Any changes evolving from the procurement activities involving technical or quality assurance matters, either for the original purchase or subsequent
. change orders, shall be approved by the originator of the purchase or change order requisition.
The Engineering and Construction Manager will assign authority for technical evaluation of the vendor quality assurance program to the Director of Technical Services.
The quality evaluation of the vendor's quality program will be the responsibility of the. Superintendent of Off-Site Audits. Quality
- S6 Assurance / Nuclear Safety Department shall evaluate and accept all such vendor quality assurance programs. All evaluations shall be e
completed prior to fina? award of the contract or purchase order.
The Superintendent of Off-Site Audits is responsible for assuring that the evaluation is carried out and for auditing the manuals of bidders being recommended as acceptable for award as to resolution of comments received by Engineering. As part of the vendor quality assurance program evaluation, the Superintendent of Off-Site Audits
- S6 will assure all vendor quality assurance program deficiencies are resolved.
If the vendor program deficiencies are minor and/or may
- S6 be corrected by specific procedures for the work to be done, the resolution mayEfollow an award'and shall be a. condition of the award.
For procurement performed at certain construction sites by the Purchasing Department satellite organization involving safety-and Code-related items, the preparation of the necessary procurement documents is the responsibility of Projects Construction.
Procurement by the site Purchasing organization are under the control and management of the General Office Purchasing Department and associated procurement documentation packages are formulated from specifications and drawings issued and approved by Engineering.
The cognizant Field Engineer or, as applicable, the Projects field Engineering Manager, prepares the suggested list of prospective bidders for each procurement package from the Quality Approved Bidders' List with direction from the site Purchasing Department Buyers. The final list of prospective bidders and procurement bid package is approved by the site Projects Construction Superintendent or Projects Engineer or their designated alternate.
In addition, such procurement bid packages involving the purchase of ASME Code and safety-related materials and items are 4-3 Rev. 56 9/13/89 Commonwealth Edison
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required to be reviewed and approved by the Site Quality Assurance Superintendent, or designated alternate, verifying that the necessary technical and Quality Assurance requirements are included-and the proposed bidders are acceptable.
The bids are evaluated by Projects Construction and an award recommendation plus a purchase requisition is prepared and transmitted to Purchasing via the Site Quality Assurance Superintendent, or designated alternate, for final review and concurrence indication.
Site Purchasing, based on the recommendation of Projects Construction, its own evaluation and the purchase requisition, conducts necessary negotiations and clarifications and make the award to a bidder on the Quality Approved Bidders' List. Any changes evolving from the procurement activities involving. technical or quality assurance matters, either for the original purchase or subsequent change orders, shall be approved by the originator of the purchase or, change order requisitions as well as Quality Assurance.
The Manager of Fuel is responsible for the preparation of nuclear fuel bid documents, for the evaluation of bids received and for the purchase of nuclear fuel. The Nuclear Fuel Fabrication
-Inspector provides quality assurance assistance.
The Nuclear Fuel Services Manager, and others as necessary, furnish technical assistance to the Nuclear Fuel Agent during the preparation of bid documents and the evaluation of bids.
When the Assistant Superintendent of Maintenance or Technical Staff Supervisor orders spare parts, material and equipment for safety-related items, components and modules to applicable engineering and quality assurance requirements, they specify the quality assurance documentation requirements equivalent to or better than the original installation.
When' spare parts, material and equipment are ordered by part number or nomenclature without-special engineering requirements being specified, appropriate statements are included in the purchase order to assure they are at least equivalent to the original equipment. The Quality Control Supervisor shall review and verify that quality assurance, specification, ASME Code and other applicable codes and standards requirements and special requirements are included in the Request for Purchase.
The procurement documents are reviewed and processed by the Support Services staff in the Stores and Materials Management
- ss Department. Coded part numbers are assigned to spare parts.
The Support Services staff and the Manager of Quality Assurance / Nuclear Safety, or designee, or Nuclear Quality Programs Manager review and
- S6 approve that the quality requirements for documentation of spare parts, welding materials, material and equipment as outlined above, are included in the procurement request documents and that the items are ordered from the original equipment supplier or an evaluated and approved alternate supplier.
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The bid package and the resulting contracts or purchase-order will clearly reference applicable revision dates of appropriate drawings and specifications for the item or service being procured. Appropriate revisions of ANSI, ASME or other applicable codes'and/or standards will be considered a part of the design requirements and be referenced in the bid package, contract or purchase order.
The bid. package and resulting contract or purchase order will contain the requirements for inspection, testing and inspection i
documentation.
Commonwealth Edison Company, its vendors and sub-vendors
- ss will be responsible for their respective programs by which an appropriate review and audit will determine that the requirements of this Section have.been met.
Procurement documents will identify which records indicative of quality will be transmitted to Commonwealth Edison and the method of dispositioning those which the vendor retains.
The bid _ package and resulting contract or purchase order
' 95 will contain, as applicable, the requirement for the vendor to have and implement a quality assurance program which has been accepted by CECO for purchased safety-related and ASME Code materials, equipment and services-to an extent consistent with their importance to safety and will' state-the controls which will exist between the purchaser and seller in requesting and accepting changes under the purchase order or contract. Also, revisions to such quality assurance programs shall be submitted to CECO for review and acceptance during the term of the contract or order.
Procurement of spare parts or replacement items will be subject to controls at least equivalent to those used for the original equipment.
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- 5. INSTRUCTIONS, PROCEDURES AND DRAHINGS The quality assurance actions carried out for design, construction, testing, and operation' activities will~be described in documented instructions, procedures, drawings, specifications, or
. checklists.
These. documents will assist personnel.in assuring that important activities have been performed.' These documents will also reference applicable acceptance criteria which must be satisfied to assure that the. quality related activity has been properly carried out.
Activities affecting quality are required by the Edison quality program to be prescribed by documented instructions, procedures or drawings.
Procurement documents and the corporate guality assurance programs of Edison, the NSSS Supplier and Architect Engineer reflect this requirement.
Each. Edison Department involved in safety-related.and ASME Code work shall have documented procedures to implement their
- ss responsibilities.
Quality Procedures as part of the Commonwealth Edison Company Quality Assurance Manual will be written for design, construction, testing, operations, maintenance and repair activities. Where appropriate, these procedures will include checklists containing the necessary elements of operation to be observed or measured. These checklists will.be used to the maximum extent practical to document the i
actions performed.
l Generating Station operations, procedures and instructions will be provided by the Station Manager and will be included in the Station Procedures Manual in a timely manner consistent with NRC license requirements for administering the policies, procedures and instructions from the time that the Operating License is issued through the life of the station.
These procedures and instructions include: Administrative Procedures, Overall Station Procedures, System Operating Instructions, Chemical Control Procedures, Emergency Operating Procedures, Surveillance Procedures Maintenance Procedures, Instrumentation Procedures, Radiation Control Standards and Nuclear Operations Directives. Also, a Station Quality Assurance Program for Maintenance Modification, In-Service Inspection and Stores Activities will be provided.
The procedures 5-1 1
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l include specifications and acceptance criteria as well as vendor
' documents,. Complex procedures include checklists as part of the procedure and caution notes applicable to specific steps in the' procedure are-included.
The current revision of the Station Procedures Manual is Lavailable in the Station Control Room and is additionally provided to key operating and management personnel.
l Maintenance and repairs to structures and equipment after construction and testing is completed are the responsibility of each Assistant Superintendent of Maintenance and are performed in accordance
- SS with applicable drawings, procedures, instructions, and/or checklists for Code and safety-related work. When ASME Code work is involved, these documents shall be submitted to the Authorized Nuclear Inspector for insertion of his hold points.
Drtwings procedures, instructions and/or checklists are used for maintenance and repairs outside the scope of normal station craft maintenance capability. When procedures and/or checklists are not available for work outside the scope of normal station maintenance craft capability, an outline of the steps to be followed will be prepared to assure proper completion and testing of the maintenance or repair work.
These procedures and/or checklists or outlines are supplemented as necessary by instructions from the personnel responsible for directing the specific maintenance or repair. work. Maintenance, modification and inspection procedures and other quality assurance related documents are reviewed by Quality Assurance personnel to assure the need for inspection, identification of inspection personnel' and documentation of inspection results plus necessary inspection requirements, methods and acceptance criteria is provided.
Each Station Manager or his designee is also responsible for
- 55 preparation of= procedures to assure the safe operation and refueling of the Station in accordance with requirements of the NRC operating license.
The Vice Presidents (BWR and PWR Operations) provide direction
- 55 for the preparation of necessary instructions and procedures to accomplish the station activities in a uniform and systematic manner.
Procedures and instruction supplementing the Quality Procedures of the Quality Assurance Manual will be prepared, as required, reviewed and approved within this individual departments, generating stations and construction sites responsible for the activities involved as the need arises and their use monitored by Quality Assurance administration. Any CECO departmental group involved with nuclear plant design, procurement, construction or operation may propose procedures as necessary to meet regulatory, ASME Code or other applicable code requirements.
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- 6. DOCUMENT CONTROL A document control system will be used to assure that
~
documents such as specifications, procedures, instructions, and
- 32 drawings are reviewed for adequacy and approved for release by authorized personnel.
Also, this system includes as-built drawings and provisions to assure as-built drawings are kept updated,
- properly maintained, and controlled. Such documents will be distributed to and used at the locations where the prescribed activity is performed. Changes to these documents will be handled
~
similarly and will be reviewed and approved by the same organization that performed the original review and approval, unless delegated by-the originating organization to another responsible organization.
Documentation will identify design documents, provide a schedule for completion, define. design milestones or other control points, and identify design responsibilities with particluar attention to the definition of organizational interfaces Design documents will include ASME Code, seismic and other analysis reports, drawings, equipment specifications, work instructions, test procedures, etc., necessary to achieve proper procurement, installation, start-up and operation _of systems and components in accordance with engineering requirements. Document control will include documents containing requirements for materials, fabrication, special processes, testing, inspection, cleaning, packaging, shipping, storage, maintenance, refueling, operations, and plant modifications, as applicable.
The fundamental control vehicles for documentation relating to Safety Category I systems, structures and components are project distribution lists and periodic document status reports. The Architect Engineer acts as the general distribution agency for project documents (except for internal Edison Quality Assurance Procedures) and carries out the distribution in accordance with a list furnished by Edison for specific types of documents.
Both the Architect Engineer and the NSSS Supplier publish periodic 6-1 Rev. 32 10-05-84 Commonwealth Edison
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- 6 si status reports identifying those documents currently-in force, o
These reports are distributed to all involved parties.
Each document recipient is responsible for insuring that only the latest authorized documents are in use and that void documents are so identified.
Periodic inspections and audits by Quality Assurance are employed as a final check to assure.that the latest authorized documents are in use.
Master distribution lists will be used and will designate recipients of document copies.
This listing shall include document changes,. distributions for comments, and/or distribution for'use. Quality Assurance Manual distribution and revisions, thereto, are controlled by Quality Assurance / Nuclear Safety
- ss Department using a master distribution list.
Design. document distribution lifts applicable to each project shall be developed by the Projects Engineering Manager or the Nuclear Engineering Manager, as applicable, and will be coordinated with other CECO personnel as deemed appropriate by the cognizant Project Manager or Design Superintendent / Supervisor, as applicable.
Each list will include an issue date, revision date, and number, project identification, types of design documents, listing of various document recipient positions and the number of copies of each position.
Each list will be distributed to the Architect Engineer and to all recipients identified on the list
.and will be accessible to the Authorized Nuclear Inspector for review and use.
The distribution of documents will be made by the Architect Engineer, or respective Project Manager or Design Superintendent / Supervisor, as applicable, in accordance with the distribution list for each project.
Each recipient listed on the distribution list shall, upon receipt of new documents, destroy or segregate and clearly mark all superseded documents.
Each receiving office or area shall have a controlled method for checking receipt of new or revised documents, and assuring that the latest revised document is in use.
Status reports will be issued periodically by Projects Engineering or Nuclear Engineering, as applicable, Architect Engineer.ar.d NSSS Supplier to all parties on the distribution list stating the latest revision of documents to assist recipients in maintaining up-to-date files.
Each document recipient on the distribution list is responsible for insuring that only the latest authorized documents are in use and that void documents are so identified.
The responsible Projects Department Project Manager or the Nuclear Engineering Department Design Superintendent / Supervisor shall periodically have the document status reports reviewed to confirm that the latest revised documents are in use.
Also, verification of compliance to this procedure by a physical check of document files, will be periodically performed by CECO Quality Assurance.
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7.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES 7.1 General The control of the quality of purchased material, equipment and services is achieved through the evaluation of vendors, surveil-lance of'their operations and required source inspection, documenta-tion, receiving inspection and retention of quality records.
Both Edison and the NSSS Supplier have direct procurement-functions for the Station.
The Architect Engineer offers recommendations to Edison on vendor selection and reviews vendor efforts as directed by Edison.
Edison will inspect and audit the NSSS Supplier's control of purchased material, equipment and services.
Edison has the responsibility for on-site control of Edison and the NSSS Supplier purchased material, equipment and services.
Contractors and suppliers furnishing material, equipment and services to CECO for items within the jurisdiction of this Quality Assurance Program will be selected on the basis of demonstrated capability to provide a product, process or service in accordance with the design specifications and contract provisions.
The purpose of this Section.is to define the quality system elements and related policies which assure the quality of purchased material, equipment and services through the evaluation of vendors, surveillance of their operations, required source inspection, documentation, receiving inspection and retention of quality records.
As applicable, the cognizant Projects Department Project
- 55 Manager or the Nuclear Engineering Department Design Superintendent / Supervisor in conjunction with Quality Assurance will require a Quality Assurance Program in accordance with ANSI /ASME NQA-1 and the daughter standards of ANSI N45.2 not included in ANSI /ASME NQA-1 or ASME Boller and Pressure Code Section III from vendors or contractors, consistent with the importance of the procurement to station safety and operation and the requirements of ASME Section III and 10CFRSO, Appendix B.
For ASME Code and safety-related procurement, the applicable vendor's Quality Assurance program shall be identified in the procurement documents and shall require certification to their QA Program accepted by CECO
- 55 and shall identify the QA Program revision and date to which the work was performed or item supplied.
In addition, Edison's procurement documents will provide notification to vendors and contractors that the provisions of 10CFR Part 21 apply.
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O Control and approval of subcontractors' quality assurance programs, procedures and personnel qualifications, are the responsibility of the specific contractor involved. Such contractor actions are to be documented and will be subject to audit by Commonwealth Edison Company.
An evaluation of vendor capability will be required for ASME Section III and safety-related items. Where valid records of vendor capability and' quality performance are not available to CECO, a survey of the supplier's facilities, capabilities and quality assurance system L
will be made by CECO or its designated representative.
For items requiring ASME Code conformance, vendors must be able to meet ASME Code-requirements.
Where material manufacturers or suppliers are qualified by CECO by. survey, as provided under ASME Section III, and materials or titems are procured directly from such qualified manufacturers or suppliers by another Certificate Holder on the basis of such survey, the qualification documentation shall be provided to,the other Certificate Holder prior to its use of the materials or items.
The Superintendent.of Off-Site Audits in the Quality
- S6 Assurance / Nuclear Safety Department will be responsible for assuring that vendor Quality Assurance Program evaluations are carried out.
The Quality Assurance / Nuclear Safety Department, for the Purchasing Department, prepares and maintains the computerized Quality Approved Bidders' List (QABL) for vendors of ASME, safety and regulatory related items.
The Purchasing Department maintains the commercial Approved Bidders List. Addition of vendors to the Quality Approved Bidders List shall only be made upon approval by.the Engineering and Construction
- s6 Manager and the Manager of Quality Assurance / Nuclear Safety, or their designees, as.to' meeting technical and quality assurance requirements.
For vendors to be placed on the Company Quality Approved Bidders List on
- s6 the basis of having an accepted Quality Assurance Program for ASME, safety or regulatory related items or work, a controlled copy of their accepted Quality Assurance Program shall be assigned to the Manager of
- s6 Quality Assurance / Nuclear Safety.
Section 9.0 of this report, " Control of Special Processes,"
establishes the evaluation and assessment of certain process and inspection capabilities of the vendor such as welding, heat treatment, and nondestructive examination.
7.2 Evaluation of Vendors Past performance of a contractor / vendor will be considered during procurement activities by CECO.
Prior to contract or purchase order award, the bidder's capability and quality performance will be reviewed relative to the product, process, or service being procured.
For suppliers of ASME services or items and for Material Suppliers or Manufacturers who do not have a Quality System Certificate (Materials) or an ASME Certificate of Authorization with an appropriate scope a survey of the bidder's facilities prior to award may be required.
Such review will verify ASME Code compliance as applicable.
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! 7.3 Surveillance of Vendor =00erations
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j Source surveillance will be carried out through notification j.
points established as a condition of procurement of safety-related or ASME Section III items.
Special consideration will be given for 1
surveillance during manufacture when one.of.the following is involved:
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a.
Determination of conformance of.the item to purchase order requirements at any other point would require uneconomic disassembly or destructive testing.
b.
Special instruments, gauges, or facilities required for inspection or test are more readily available at source and would be uneconomic to reproduce at the job site.
c.
A receiving inspection would destroy or require replacement of special preservation and packing.
d.
Quality Controls and inspections are integrated into production methods, and inspection at the suppliers plant is necessary to economically verify test reports, inspection records, certifications or other evidence of quality.
Source surveillance by Commonwealth Edison Company or.its agents will not nullify the vendor's responsibilities for maintaining a quality control organization delivering items conforming to procurement requirements. Unless otherwise specified, acceptance by Commonwealth Edison Company will be at the nuclear generating station site in accordance with the terms of the contract.
The administration, surveillance and inspection of off-site equipment and material vendors will be the responsibility of the Engineering and Construction Department, as applicable with final approval of inspection acceptance reports being vested in the Nuclear Quality
- ss Programs Department.
7.4 Receivino Insoection Materials and articles received from vendors will be inspected upon receipt to assure physical integrity and identity plus documentation compliance with the procurement requirements.
For items not source inspected, specific receipt inspection measures such as material and dimensional checks against approved drawings and specifications and assurance that ASME Code Data Reports are received will be performed by qualified personnel in accordance with the applicable CECO or vendor QA program and to checklists approved by
' 95 appropriate Quality Assurance or Quality Control personnel to verify conformance to procurement requirements.
Where receiving inspection requires the use of calibrated instruments and tools, the identity of such equipment shall be recorded on the applicable receiving inspection documents.
CECO purchases Code items and turns them over to site Code vendors.
In the case where receipt inspection is
- S6 7-3 Rev.55 9/13/89 Commonwealth Edison
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assigned to a site contractor, CECO provides them with applicable o
procurement documents, such as the Purchase Order, Specification,
'etc., required.to assure that the CECO purchased items meet Code
' requirements and to perform receipt inspection. Also, for material.
I supplied by non-Certificate holders, the CECO survey data covering such firms is made available to site Code contractors. When CECO-performs receipt inspection of such purchases or when CECO upgrades stock material for ASME Code use, CECO provides these vendors with
- ss 3
k the applicable Certified Material Test Reports and/or Data Reports j
l, plus'the Material Receiving Report to provide verification that the purchased items supplied by CECO meet Code requirements. Documented-evidence that material or equipment conforms to procurement requirements including, for Code items, indication of their.
compliance to the specified quality program must be retained and available at the site prior to use or installation.
Part of this evidence shall be in the form'of acceptable documentation such as Certified Material Test Reports, Pressure Test Reports, Certificates of Conformance, etc.
Documentation requirements will be delineated in the individual equipment specifications.
The Construction Materials Receiving Coordinator or designee will be responsible for assuring that receiving inspection is completed where the Engineering and Construction Department is responsible ~for the work; receipt acceptance approval will be by Nuclear Quality Programs
- s6 Department or its designated agent.
Where ASME Section III components and safety-related materials and equipment are received by the station Stores Supervisor station Quality Control ~will be responsible for receiving inspection and the Quality Assurance Engineer or Inspector for Maintenance shall assure through audit and surveillance that the receiving inspection is complete and traceability is maintained.
ASME Code material transferred from
. Stores or another Commonwealth Edison Company station shall meet the requirements specified for the designated installation.
Nonconforming. equipment will be controlled.
7.5 Sucolier Audit Vendors of safety-related and/or ASME Section III items
.will be subjected to survey,- audit or surveillance of their quality assurance system by CECO, or its agents, at intervals consistent with the importance to safety, complexity, and the quantity of the product or services being furnished in accordance with approved agenda and checklists to assure that the necessary manufacturing processes are being utilized and that quality controls are being maintained.
7.6 Soare Parts and Renacements Spare parts and replacement items, equipment and components will be purchased to original or better design requirements in accordance with the controls herein.
The applicable quality assurance requirements will be included in the procurement documents.
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- 8. IDENTIFICATION AND CONTROL OF MATERIALS, PARTS AND COMPONENTS A~ system of controls will be' utilized to prevent the use
=of nonconforming items or. items which have not received the required inspections and tests. Materials (including consumables),
parts, and components including partially fabricated subassemblies will have their identity marked on the item or on tags-and records traceable to the item. Identification assigned to materials, parts and: components,. including partially fabricated subassemblies, will be documented and maintained by the respective vendors, contractors or organizations having responsibility for the_ items involved throughout fabrication, installation or. erection and use of the item and be verified as to being correct prior to release for fabrication,' assembling, shipping or' installation.' The identification system for the station will be established by the Nuclear Engineering Department with assistance from the Architect Engineer and Nuclear Steam Supply System vendor'as needed, and consists of unique numbers assigned to pipes, instruments, valves and equipment. Also, stored spare parts..and equipment'will be assigned established Stores Items Numbers by.the Support Services
' *ss.
staff of.the Stores and Materials Management Department. Quality Assurance will assure such identification and traceability is provided.
Assigned identification of mat'erials, parts and components will be unique to the item. Identification will be on the item.where practicable, and/or on records traceable to the Litem. Prior to dividing material or cutting the markings, the marks or coded marking shall be transferred to the parts to be cut and such identification shall be independently verified.
During fabrication, installation, erection and use of items, identification will be maintained traceable to the-i documentation of sub-components and/or materials when specified.
Engineering review will establish that stamps, tags, or labels affixing identification to an item will not affect the properties or otherwise cause deterioration of the item and that stamps, tags and labels shall be made of material that will assure identification is not lost. The identification systems used by Commonwealth Edison Company, its contractors and major vendors for a nuclear generating station will be integrated to the extent necessary for uniformity.
The identity of items, components, equipment and systems generally will be applied during the design phase.
The procurement of items and components w111 use this identity and it will be maintained during fabrication 8-1 Rev. 56 9/13/89 Commonwealth Edison
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performed by. vendors. The' receiving-inspection, erection, repair and~.
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> maintenance records'of' engineered items and components which are filed at
..the construction site or station will be traceable.to the engineering
. identity. ' Items and components which have not been subjected to required inspection and_ tests prior to receipt will be tagged or marked and
. controlled to preclude-usage-. Also, nonconforming. items will be identified:and controlled to preclude' usage.
Stored replacement spare parts and equipment will be similarly.
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identified by, Stores. Item Numbers during purchase,' storage, and-installation to assure required traceability to records and documents and to' prevent their incorrect use. Part numbers are assigned by'the Support
- 55 Services staff.
The station Stores Supervisor maintains' parts, material,-
.and equipment.in" storage traceable to quality. assurance ~ documents.
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- 9. CONTROL OF SPECIAL PROCESSES For some processes, the required level of quality defined' in ASME Code ~and other applicable codes, standards and specifications cannot be assured by inspection of the item alone.
.For these processes,-quality assurance is obtained through reliance on personnel qualification and procedural control in force as appropriate for the processes being employed for a specific task in connection with plant contract work, maintenance, repairs and modifications. The application of these controls is assured through audit / surveillance activities by CECO or its agent at vendor plants and/or at the site and by Quality
- S6 Assurance at the operating stations. The Site Quality Assurance Superintendent or designee and the Station Quality Assurance
' Superintendent at the operating station is responsible for assuring that records.of qualified personnel are maintained by the contractor for work performed for Edison. These special and construction processes include welding, heat treating, concrete placement, coating, plating, material cleaning and bonding, chemical processes, certain nondestructive testing processes and such additional processes that may be identified in the contract, purchase order or maintenance or modification procedure, as the result of ASME Section III, Division 1 and Division 2 for concrete containment requirements and/or design review.
Procedures for the control of special processes will be maintained for components within the primary system pressure boundary and other safety-related items and ASME Section III designated components. These procedures will be in accordance with ASME and other applicable codes and specifications. When there is a specific reason to question whether the special process procedure or qualifications of personnel requirements are being met, the Authorized Nuclear Inspector may require requalification.
Process control procedures will be used as required by specifications, Code or standards, as applicable. Supplemental procedures will be prepared as necessary to provide detailed performance and metheds for control of special processes and concrete placements for concrete containments.
Process control procedures will specify the preparatory steps, processing details, 9-1 Rev. 56 9/13/89 Commonwealth Edison L
N conditions to be maintairied during the steps of process, inspection-
-and test requirements and records requirements. Process control procedures of contractors and vendors will be submitted to Commonwealth Edison Company for review and evaluation in accordance with documented: Commonwealth Edison Company procedures.
Process control procedures will specify the methods of verifying the L
adequacy of processing materials, solutions, and' equipment, l
including definitions of their associated control parameters.
When the process is conducted in special environments, such as in vacuum or inert gases, the process control procedures will specify the requirements and methods for maintaining such environments.
The control and approval of sub-vendor Quality Assurance and Quality Control procedures are the responsibility of the specific vendor involved (included NSSS vendor).
Control procedures for nondestructive examination processes such as radiography, ultrasonic testing, liquid penetrant inspection, and magnetic particle inspection, will be used by Commonwealth Edison Company and their contractors and vendors to assure that the results provide accurate, uniform and reproducible indications of actual quality.
Commonwealth Edison. Company and contractor and vendor personnel responsible for the' performance and verification of special processes and-the inspection of concrete placement involving concrete containments and other inspection and test activities will be certified as required by specifications, ASME Code or other applicable codes and standards. Certification of personnel for such processes and concrete inspection and other inspection and test activities will include necessary training followed by an examination of each individual.
The period of validity for certifications shall be specified, and each individual shall be decertified at the end of such a period by retesting or by demonstration of satisfactory performance.
Personnel failing retest shall be_ removed from operations pending requalification.
Personnel who have not performed inspection, examination and test activities in the qualified area for a period of one year shall be re-evaluated to re-establish required capability.
Training, testing, and:
qualification of personnel.shall be in accordance with criteria described in ASME Code, standards and specifications.
Process control records will provide objective evidence that special processes were performed in compliance with approved process control procedures by qualified personnel.
Process records will specify the inspection and test data to be verified.
Results of nondestructive examinations will be recorded in accordance with applicable specifications, codes and standards.
These records will be retained by Commonwealth Edison Company or when the work is contracted, they will be retained by the vendor and then supplied to Commonwealth Edison Company as required by procurement documents.
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- ss 3/27/89 Commonwealth Edison
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- 18. AUDITS Audits will be performed by Commonwealth Edison Company and/or its vendors and sub-vendors to verify the implementation
- 56 and effectiveness _of quality programs under their cognizance. -The number and experience of persons participating in audits will vary according to the nature:and significance of the audit.
A'udits under the responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits will cover quality systems for engineering, construction, operations.
- 56 modifications, maintenance, in-service inspection and Stores activities. ' Audits will be performed to evaluate-the implementation of the quality assurance programs, the adherence to procedures and controls and the fulfillment of requirements.
Certifications and records will also be evaluated.
Product audits assess the effectiveness of in-progress work, inspections and tests that-are specific'to the fabrication,' installation, construction, testing and operation of an item.
The performance and compliance of each operating station to the Quality Assurance Program is assured through review surveillance _and audit of_ operations by the Quality ~ Assurance-Engineers or Inspectors under the direction of the Station Quality Assurance Superintendent, who-is responsible through review, surveillance and audit of operating, maintenance, modifications, Stores and in-service inspection activities by Quality Assurance Engineers or Inspectors to the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits. Audits are performed to audit schedules which are approved by the Manager of Quality Assurance / Nuclear Safety.
These schedules include the minimum audits required. Other audits will be performed as directed by Quality' Assurance supervision.
The Audit Team Leader's auditing organization shall
- ss develop and document an audit plan for each audit.
This plan shall identify the audit scope, requirements, audit personnel, activities to be audited, organizations to be notified, applicable documents, schedule, and written procedures or checklists.
Audits will be conducted using checklists or an agenda approved by trained, qualified and responsible Quality Assurance supervisory personnel and will be conducted with sufficient authority and organizational freedom to evaluate compliance with all applicable aspects of the Quality Assurance Program and specified requirements.
Audits will be initiated early to assure effective quality assurance during design, procurement, manufacturing, 18-1 Rev. 56 9/13/89 Commonwealth Edison
. construction and installation, inspection and test and be performed efficiently in order to achieve a minimum of ir.terference with work-in progress and minimum disruption of organizations being audited.
- 4a '
- An. audit plan will be maintained in. order to schedule audits of site
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vendors. Audits of off-site vendors generally will be conducted in
- ss
. conjunction with plant visits for witnessing inspection points by a
. qualified Audit Team Leader. Also, periodically Quality Assurance
- 56 will participate in such audits or perform independent audits to assure effectiveness of the program, compliance to the program and fulfillment of procurement requirements.
-The elements in the quality program, in procurement docu-ments and in related codes and standards, are subject to systems audits.
Also, items received, fabricated and constructed or installed for use by Commonwealth Edison Company in its nuclear power plants are subject to audits.
Audits will be performed selectively at various stages of contracts on a varying frequency, based on the nature and safety significance of the work being done to verify compliar.ce and determine the effectiveness of procedures, inspections, tests, process controls and documentation.
For Code materials, when a Material Manufacturer or Material Supplier, as applicable, does not hold a Qual.ity System Certificate (Materials), the CECO audit frequency shall be at'least once annually during the interval in which CECO purchased material is being controlled by the Material Manufacturer or Material Supplier.
In addition to these audits, Quality Assurance will conduct approximately annually, overall system audits of the NSSS vendor, the Architect Engineer, site contractors, vendors of services, and involved Edison Departments.
Audits of CECO are also performed by the Authorized Inspection Agency as required by the ANSI N-626 series of Standards.
Commonwealth Edison Company's active participation in joint utility audit programs provides an alternative means to fulfilling CECO's responsibility of auditing active vendors.
To accomplish this task, the completed joint utility audit report will be reviewed
- S6 by the QA/NS Off-Site Audit staff for adequacy and compliance to CECO and regulatory requirements and for applicability and adherence to CECO specifications.
Results of the QA/NS review and a copy of said audit report will be distributed internally to designated personnel.
For operating stations, periodic Quality Assurance audits will be performed to verify compliance with, and the effectiveness of, the program. Audits cm.ering operating will be performed in accordance with the Technical Specifications under the direction and responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits, as applicable, independent of the Production Department.
Surveillance, review and audits covering maintenance, modifications, in-service inspection and Stores activities performed by the station organizations will be performed under the direction and responsibility of the Nuclear Quality Programs Manager and the Superintendent of Off-Site Audits, as applicable, where maintenance and modifications are performed by
- S6 vendors or other organizations under the direction of the Engineering and Construction Department for the stations.
Audit results and recommendations of corrective action will be documented and reviewed with the management of the Station.
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requiring prompt corrective action are reported immediately to 4-management of the audited organization. Verification of the completion of corrective action recommended in audit reports will be performed by the Technical. Staff-Supervisor or Quality Control Supervisor.
Follow-up of open station items is tracked by the
~ Action Item Records (AIR)-System.
Where an audit item is placed under the AIR system for tracking completion, approval as to satisfactory completion of corrective action shall be obtained from the responsible station Quality Assurante Engineer or Inspector.
Audits will be established and conducted by qualified personnel who are familiar with written procedures, standards and processes-applicable to the area being audited, but who do not have direct responsibilities in the areas'being audited.
An audit report shall be written for each audit. An audit report package consisting of Summary Sheet, Attachment Sheet, Checklists or Agenda and any additional pertinent details recorded on additional-sheets necessary to support h finding (s) will be on file. The audit report will be reviewed, signed, and dated by the Audit Team Leader.
The audit shall be reviewed for acceptability by
- E6 a supervisor. The audit report shall be sent, as applicable, to-the President, Senior Vice President (Nuclear Operations), Manager of Engineering and Construction, the Nuclear Engineering Manager, Manager of Quality Assurance / Nuclear Safety and Superintendent of Off-Site Audits,. Assistant Vice President (Quality Programs-and Assessment) and the Nuclear Quality Programs Manager, and the Vice Presidents '(BWR and PWR Operations) for management review and action.
The.above stated system audits are also sent to the Chairman and CEO and the President and Chief Operating Officer for review and evaluation and action as deemed necessary by the Manager of Quality Assurance / Nuclear Safety. Also, monthly to bi-monthly-i periodic reports on. quality assurance activities are submitted to top management.
Such reports, in part, provide bases for periodic top management reviews and discussions of quality assurance activities, implementation status and effectiveness.
Such reviews and discussions are held by tre Chairman and President'with the Manager of Quality Assurance / Nuclear Safety and with other executives.
Audits shall be scheduled and follow-up review of deficient areas or adverse conditions and follow-up on corrective action commitments shall be performed by Quality Assurance to assure effective corrective action and implementation have been carried out.
Deficiencies in the execution or implementation of corrective action will be brought to the attention of the person who is responsible in the area involved. Continued deficiencies, or failure to implement corrective action will be reported in writing by Quality Assurance to appropriate executives within Commonwealth Edison Company.
18-3 l
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