ML19332E421

Rev 7 to Limerick Generating Station QA Program Description.

ML19332E421
Person / Time
Site:	Limerick
Issue date:	11/22/1989
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML19332E419	List: ML19332E418 ML19332E421
References
NUDOCS 8912070203
Download: ML19332E421 (115)

Text

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LIMERICK: GENERATING STATION QUALITY ASSURANCE PROGRAM .

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DESCRIPTION 1 Revision L7. <

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/ 17.l' QUALITY ASSURANCE DURING DESIGN AND=f0NSTRUCTION-  ;

Philadelphia' Electric Company (PECo) has 1 established and implemented a quality' assurance-program to ensure that Limerick Generating:

Station Units 1 and 2.are designed, fabricated, constructed, inspected, and tested in accordance

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with applicable codes, specifications, and i regulations. The. program begins with the design >

of the plant-and proceeds.through the phases of t component procurement, manufacture and >

construction to plant completion including the preoperational tests-and inspections.

The program is described-in " Limerick Generating Station Units 1 and 2; Summary Description of the Quality Assurance Program for Design and Construction,". dated June 10, 1983, which supersedes Appendix D of the '

Preliminary Safety Analysis Report, and was s transmitted by a letter from PECo, Eugene J. Bradley, to the NRC Regional Administrator Region I, June 10, 1983, and a letter from PECo, J. S. Kemper, to the NRC Regional Administrator Region I, September 15,  ;

1983. 4 t

The program described in the document

" Limerick Generating Station - Summary Description of the Quality Assurance Program -

for Design and Construction" dated June 22, '

1987 supercedes the program described above li for Limerick Unit 2 only. The' June 22, 1987 program description was transmitted by a letter from PECo, S. J. Kowalski to the NRC Regional Administrator, Region I July 9, 1987 and subsequently revised by a letter from PECo, J. S. Kemper to the NRC Regional Administrator, Region I, August 9, 1988.

A revised program description for " Limerick Generating Station - Summary Description of L the Quality Assurance Program for Design and l Construction," dated October 6, 1988, was transmitted by a letter from PECo, J. S. Kemper to the NRC Regional Administrator, Region I, October 24, 1988.

This document supersedes all prior revisions.

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E 17.2 QUALITY ASSURANCE DURING THE OPERATIONS PRASE t

E Philadelphia Electri.c Company is responsible  !

.for assuring:that-Limerick Generating Station-3 (LGS) is operated, maintained, and modified in accordance with applicable regulatory

' requirements.

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To ensure the quality ofLactivities affecting.

safety-related structures, systems, and components of LGS during.the operations phase,

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Philadelphia Electric Company has established a management control plan which complies with 10CFRSO, Appendix B. This plan consists of ,

(1) the Quality Assurance Program which-contains Philadelphia Electric Company's i

quality assurance commitments to the Nuclear s Regulatory Commission, (2)Lthe-Nuclear Quality Assurance Plan-(QA Plan) for the above. .

organization which contain a description of policies and program elements to implement the commitments to the NRC, and (3) organizational unit procedures necessary for the unit to comply with the requirements of the QA

<, programs and plans.

Appropriate portions of the program will als'o be applied to radioactive-meterial packages consistent with the activity and proposed use of the package.

The Quality Assurance Program elements described herein shall be implemented by written procedures, which shall be established prior to performing activities applicable to i those elements. .i Section 13.5 describes the station administrative,and implementing procedures which meet requirements of.the Quality Assurance Program and which will be implemented by the LGS plant staff.

b The responsibility for the QA Program

described herein is retained and exercised by L

PECo exclusively. When specific tasks are delegated to organizations outside of PECo, PECo shall maintain control over the functions through means such as-imposing QA Program requirements, reviewing documents, and performing audits. The vendor's QA Program 17.2-1 Rev. 7

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shall be reviewed and approved by PECo prior- '

to the vendor = performing work. The documents '

to obtain vendor services shall clearly define the scope of. work,-the-QA requirements and the c responsibilities being assigned to the vendor.

The Nuclear-Quality Assurance Progra.n is ,

described ~in Section 17.2. The program complies with the requirements of 10CFR50, ,

Appendix B and is based on the QA related NRC regulatory guides and associated industry standards. Compliance to these regulatory guides and associated standards is addressed in Appendix 17.2.II.

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17.2.1 Organization G

The Philadelphia Electric Company corporate structure is shown on the Executive Organization Chart, Figure 17.2-1. Fifteen organizations are directed by an Executive ,

Vice President, five Senior Vice Presidents, '

and thirteen Vice Presidents. The following PECo organizations are involved in quality ,

related activities for LGS: Nuclear Group, l Information Systems and General Services, Engineering and Production, Personnel.and

-Industrial Relations, and Legal.- -

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-17.2.1.1 Office of the Chief Executive The Chairman of the Board, President, and Chief Executive Officer, comprise the Office of the Chief Executive. The President of PECo has the ultimate responsibility for-the Quality Assurance Program for PECo nuclear facilities. The President delegates to the ,

t Executive Vice President, Nuclear, the

l. authority for instituting and maintaining the QA Program.

17.2.1.2 Nuclear Group The Nuclear Group is under the direction of l, - the Executive Vice President, Nuclear. The i

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- Executive Vice President, Nuclear is  !

responsible for.the operation,-maintenance, +

l. and modification of the PECo nuclear electric '

generation-facilities and.the establishment of.

the-Quality Assurance Program goals and objectives..

. . . .. The organization of the Nqclear Group is shown ,

in. Figure 17.2-2. The Nuclear Group is: J

. composed of six departments: Nuclear-Construction, Nuclear Services, Nuclear Engineering, Limerick Generating Station (LGS), Peach Bottom Atomic Power Station (PBAPS), and-Nuclear Quality Assurance (NQA). 'i The Nuclear' Group is supplied with procurement services, personnel,-maintenance, and other-support functions from other Philadelphia Electric Company organizations and contractors as1necessary. ,

17.2.1.2.1 Nuclear Construction Nuclear Construction is under the direction of a Senior Vice. President who reports to the ,.

Executive Vice President, Nuclear. The Senior Vice President is responsible for Limerick Generating Station Unit 2 construction.

17.2.1.2.2 Station Organization The LGS organization, duties, and responsibilities are described in Section l 13.1.2.

17.2.1.2.3 Nuclear Services Nuclear Services is under the direction of a Vice President who reports to the Executive Vice President, Nuclear. The Vice President is responsible for the activities that support PECo nuclear facilities. It is comprised of four divisions: Nuclear Maintenance, Nuclear Support, Nuclear Training, and Nuclear Administration. The organization of Nuclear Services is shown in Figure 17.2-3.

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-17.2;1.2.3.1 ' Nuclear Maintenance Division j v.

The Nuclear' Maintenance Division is under=the

direction of a Manager who reports to the Vice  ;

President, Nuclear. Services. The Manager is

, responsible'for maintenance support to the l maintenance organization at the nuclear' i

.. . facilities. The Division is composed of four sections: Mobile Maintenance,-Central Shop, Maintenance Services, and Planning and Coordination.

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l 17.2.1.2.3.1.1 Mobile Maintenance Section The Mobile Maintenance Section, under the J direction of a Superintendent, consists of ,

qualified craftsmen and supervision who support maintenance functions at PECo generating facilities.- The Mobile Maintenance Section is divided into four Branches:

Mechanical, Electrical, Turbine, and i Reactor / Pressure Vessel. Each branch consists of teams of qualified workers which accomplish assigned and planned work as designated by t,he nuclear-facility maintenance organization. [

l l 17.2.1.2.3.1.2 central Shop Section

The Central Shop Section, under the direction of a Superintendent, consists of qualified ~

craftsmen, supervision, and technical support personnel. The Maintenance Central Shop consists of: the Mechanical Shop Branch, Technical Support Branch, and the Electric  !

Shop Group. The section supplies various mechanical / electrical shop services to PECo generation facilities.

l 17.2.1.2.3.1.3 Maintenance Services Section -

Maintenance Services Section, under the supervision of a Superintendent, consists of i three branches: NDE Services, Division Administration, and Maintenance Program Analysis. The Maintenance Services Section is 17.2-4 Rev. 7

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l responsible for the performance of nondestructive examination, contracts / specifications, procedures, document control, commitment tracking, information systems, and maintenance program analysis-including prevent'.ve maintenance program-support, materials managemont program support, and general maintenance program support.

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l 17.2.1.2.3.1.4 Planning and Coordination Section The Planning and Coordination Section, under the direction of a Superintendent, consists of the Division Scheduling / Planning Branch, Technical Support Branch, and three site coordinators. The Planning and Coordination

! Section lo responsible for Nuclear Maintenance Division work force scheduling, coordination, electrical / mechanical work package planning, estimating and technical staff support of turbine, diesel, boiler, generator, motor, circuit breaker, welding, and metallurgical activities. A Nuclear Plant Coordinator is assigned to each nuclear site for '

Division / Plant coordination.

17.2.1.2.3.2 Nuclear Support Division The Nuclear Support Division is under the direction of a Manager who reports to the Vice President, Nuclear Services. The Division organization, duties, and responsibilities are described in Section 13.1.1.1.1.

17.2.1.2.3.3 Nuclear Training Division The Nuclear Training Division is under the direction of a Manager who reports to the Vice President, Nuclear Services. The Manager is responsible for obtaining and maintaining accreditation of nuclear training programs.

The Division is composed of two sections:

Nuclear Training and Barbadoes Training.

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c-17.2.1.2.3.3.1 Nuclear Training Section The Nuclear Training Section, under the direction of a Superintendent, provides regulatory-required training programs in support of PECo nuclear facilitiet.

17.2.1.2.3.*3.2 Barbadoes Training Section l The Barbadoes Training Section, under the  ;

supervision of a Director, provides for the i training of helpers and craftsmen and l qualification of craftsmen.

l 17.2.1.2.3.4 Nuclear Administration Division The Nuclear Administration Division is under the direction of a Manager who reports to the Vice President, Nuclear Services. The  ;

Division is composed.of Financial and L Administrative Services, Information Resourc'es '

Management, and Records Management and Office '

Services. The Division has the responsibility for administrative and technical engineering ,

support for the Nuclear Group.

l 17.2.1.2.3.4.1 Financial and Administrative Services Section The Financial and Administrative Services

! Section, under the supervision of a Director l who reports to the Manager, Nuclear Administration Division, is responsible for Nuclear Group budgeting, cost tracking, and j cost analysis.

l 17.2.1.2.3.4.2 Information Resources Management Section The Information Resources Management Section is under the supervision of a Director who reports to the Manager, Nuclear Administration Division. The Section is responsible for 17.2-6 Rev. 7 l

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... e managing all computer-based information, j acquisition, processing, and distribution in  !

the Nuclear Group. This includes creating, ,

obtaining, or enhancing computer hardware, I communication, and software systems to support j the tequirements of the Nuclear Group, while  !

maintaining and preserving information as a )

.. . corporate asset. This Section is also 1 responsible for the development of a software j quality assurance program. l I

l 17.2.1.2.3.4.3 Records Management and Office Services Section The Records Management and Office Services Section is under the supervision of a Director -

who reports to the Manager, Nuclear '

Administration Division. The Document Administration Center (DAC) in Philadelphia, is under the direction of a Supervisor who s reports to the Director, Records Management and Office Services Section.

The Supervisor-DAC is responsible for task delegation to ensure creation, preservation,,

and protection of PECo's record copy of ,

quality assurance documents that have been submitted to the DAC. In addition, the Supervisor-DAC is responsible for arranging transfer to the permanent offsite records

, center. ,

t DAC personnel are responsible for stamping sequence numbers on records, indexing records into the Nuclent Records Management System (NRMS) computerized data base, retrieving documents, microfilming records, verifying ,

legibility of microfilm, and disposition of records.

17.2.1.2.4 Nuclear Quality Assurance Nuclear Quality Assurance (NOA) is responsible for administering the overall Nuclear Quality ,

Assurance Program of the Nuclear Gruup. The organization of Nuclear Quality Assurance is l . shown in Figure 17.2-4.

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Nuclear Quality Assurance is headed by a ,

General Manager who reports directly to the Executive Vice President, Nuclear. NQA is composed of five divisions Quality [

Improvement, Peach Bottom Quality, Limerick Quality, Performance Assessment, and Corporate Nuclear Quality Division; and the Peach Bottom l

.. , and Limerick Independent Safety Engineering r Groups. j i

The General Manager, NOA, has the following l responsibilities and authorities: ,

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a. Formulate, develop, and establish Nuclear Quality Assurance policy in areas of <

Operations, Maintenance, Modifications, 3 l ISI/IST Inspection, Surveillance Testing, i Fuel Handling, Health Physics and Chemistry, Radiological and Environmental F Monitoring, Fire Protection, Physical Security, Emergency Preparedness, Radioactive Waste and Material, Training, Procurement, Audits, Records, Nonconformances, and Corrective Action.

b. Administer and coordinate the Nuclear Quality Assurance Program (NQA Program). j

, c. Furnish overall direction for i implementing the NQA Program,

d. Provide recommendations for correcting program deficiencies or improving the implementation of the NQA Program, as  ;

appropriate. l l e. Require tracking and verification of corrective action and problem resolution for all QA identified deficiencies and Corrective Action Requests (CARS).

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f. Direct cessation of work when such work l is to be a serious quality degradation. ,

This stop work authority shall be ,

delineated in applicable procedures. ,

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g. Determine the on going status and  !

adequacy of the NQA Program through I regular review of NQA Audits, Surveillances, Monitorings and

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! Inspections, identification and

%. investigation of problem areas, determination of timely and effective

.. ., steps taken to correct deficiencies, and ,

the evaluation of general plant QA/QC

_ performance through such other inputs as i are available or are deemed necessary to '

make a reasonably objective and confident judgement.

h. Apprise the Executive Vice President, Nuclear; the Vice President, Nuclear Services; the Vice President, Limerick

, Generating Station; the Vice President Nuclear Engineering; and the Nuclear Review Board periodically of the status of the Quality Assurance aspects of Limerick Generating Station's operations, and immediately of significant problems affecting quality.

1. Control contents and revisions of the QA Plan.

j. Ensure that personnel involved in implementing the NOA procedures are trained and/or qualified, as appropriate.

k. Contract for QA/QC consulting services as necessary.

1. Support QA/QC training and qualification programs, as required, for implementation-and execution of the QA Plan,

m. Establish and maintain the Evaluated Vendors List (EVL) of evaluated and i qualified vendors in accordance with administrative procedures.

n. Perform audit / surveillance of vendor activities as appropriate.

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o. Establish, administer, and coordinate the Nuclear Quality Assurance Program associated with modifications, and capital equipment installation or renewal.

. . . . p. Administration of internal audits and surveillances,

q. Require all deficiencies be verified and tracked by NQA.

17.2.1.2.4.1 Limerick Quality Division The Limerick Quality Division is under the supervision of a Manager who reports to the General Manager, Nuclear Quality Assurance.

The Division is composed of four sections:

Quality Assurance, Quality Control, Quality Support, and Technical Monitoring. The Manager is responsible for providing technical and administrative direction to the Division; providing single point accountability for al.1 site quality activities formulating the Audit Program; conducting audits, surveillances, inspections, and monitorings; reviewing and approving site-generated administrative procedures; identifying specific and

, programmatic deficiencies, tracking of these items until they are fully resolved; performing trend analysis, for providing periodic reports, to the General Manager, NQA, on the status and adequacy of the Nuclear Quality Assurance Program and advising of any prcblems requiring special attention; approving Stop Work requests; and for providing and maintaining a qualified and l suitably. trained quality assurance staff to carry out required project and staff j functions.

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l 17.2.1.2.4.1.1 Quality Assurance section The Quality Assurance Section is undar the supervision of a Superintendent who reports to I the Manager, Limerick Quality.

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The Superintendent has the following responsibilities  ;

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a. Provide administrative supervision and technical direction of the activities of the Quality Assurance Section.

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.. . b. Direct the performance of audits and.

. surveillances in accordance with written

. procedures to ensure compliance with the QA Plan.

c. Oversee the preparation of NQA audit i check-lists.

e d. Consult with the Quality Control ,

i l Superintendent, Technical Monitoring Superintendent, Quality Support ,

Superintendent, and the Manager, Limerick .

L Quality, on significant problems affecting quality,

e. Review and approve results of audits and '

surveillances.

f. Review with the Manager, Limerick Quali.ty

• those deficient areas, identified by audits or surveillances, which require corrective action and which may require subsequent follow-up action in future audits and surveillances.

g. Ensure that conditions adverse to quality ,

identified in audits, surveillances, technical monitorings or QC activities that require corrective action have scheduled completion dates.

h. Schedule and direct the planning of the audit program to ensure compliance with the QA Plan and Technical Specifications.

L 1. Issue CARS and verify corrective action l for conditions adverse to quality ,

L identified as a result of NQA activities

! which include audits, surveillances, I monitorings and Oc activities.

1 l j. Ensure that personnel involved in performing NQA audits and surveillances are trained and qualified.

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k. Assure timely follow-up of committed

[ corrective action.

1. Assure that corrective action performed in response to previously identified conditions adverse to quality, thru future audits and surveillances, that

. such corrective action is adequate and effective to preclude repetition.

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17.2.1.2.4.1.2 Quality Control Section The Quality Control Section is under the direction of a Superintendent who reports to L

the Manager, Limerick Quality. The Site QC Staff is also under the direction of the Quality Control Section Superintendent. The Superintendent has the following responsibilities:

a. Provide administrative supervision and technical direction of the activities of l the NQA QC Inspection personnel.

l b. Oversee the inspection activities in th'e area of receipt inspection; radwaste/radmaterial packaging, handling, and shipment; maintenance and l modification activities performed on

, safety-related equipment; health physics; l plant operations etc., as appropriate.

c. Consult with the Quality Assurance Superintendent, Quality Support Superintendent, Technical Monitoring Superintendent, and the Manager, Limerick Quality when significant problems affecting quality are identified.

d. Overview of the QC Section inspection activities, schedules, and results.

e. Identify the need for the preparation of NQA supplements relating to QC l activities,

f. Ensure that the personnel involved in the l implementation of QC inspection

. activities are trained and qualified.

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g. Ensure that items requiring corrective action identified in inspection activities are rescheduled in-inspections, as appropriate.

t l h. Perform reviews of work requests for inclusion of QA Plan activities.

1. Document conditions adverse to quality ,

resulting from QC activities and verify corrective action.

17.2.1.2.4.1.3 Quality Support Section The Quality Support Section is under the supervision of a Superintendent who reports

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directly to the Manager, Limerick Quality.

1 The Superintendent, Quality Support has the following responsibilities:

a. Provide administrative supervision and technical direction of the activities of  !

the Quality Support Section,

b. Consult with the Quality Control Superintendent, Technical Monitoring Superintendent, Quality Assurance Superintendent and the Manager, Limerick Quality, on significant problems )

, affecting quality.

c. Ensure that personnel involved in performing NOA Quality Support activities are trained and qualified.

d. Perform Quality Exit Interviews and Quality Concern follow-up for NQA Limerick Quality Division Personnel,

e. Act as NRC interface and coordinate NRC open item activities for Limerick Quality Division.

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f. Review and coordinate revision of NQA Procedures.

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l. g. Review of selected Site Implementing Procedures.

l l h. Review and approval of purchase orders and approval of technical receipt

.. , inspection documents.

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i. Review NCR dispositions.

, l j. Review of corrective maintenance work requests.

, l k. Tracking and Trending Analysis of L Inspection and Monitoring Activity reports.

1. Document conditions adverse to quality identified during reviews of inspection and monitoring trends.

m. Design and generate reports for NQA Management on Quality Activities.

n. Provide secretarial and clerical setvic.es for the Limerick Quality Division.

o. Maintain Quality Assurance (QA), Quality Control (QC), Quality Support (OS), and Technical Monitoring (TM) correspondence

, control system and files.

p. Log status and follow-up of Corrective Action Requests and nonconformances.

.l q. Input data in computer for QATTS (Quality Assurance Tracking and Trending System).

l r. Input data in the computer for Inspection and Monitoring Reports.

s. Keep the appropriate NQA Superintendents l l current on the recertification l

l. requirements for their personnel.

1 l t. Resolve identified training deficiencies.

u. Maintain NQA personnel qualification L records.

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'l'17.2.1.2.4.1.4 Technical Monitoring Section F

The' Technical Monitoring Section is under the direction.of a Superintendent who reports to

the Manager, Limerick Quality. The L-Superintendent has the following responsibilities

a. Provide administrative supervision and technical direction of the activities of l the Technical Monitoring Section.

,- b. Oversee monitoring performance in such i areas as operations, health physics, radioactive waste, chemistry, security, p post maintenance / modification testing, surveillance testing, maintenance, fire protection, plant modifications, safety i and emergency planning.

c. Interface with station management to provide feedback and obtain corrective action to identified problems, f

d. Issue monthly monitoring schedules and reports. ,

e. Overall planning for the development of Monitoring Guidelines.

f. Ensure that monitoring personnel are properly qualified.

g. Ensure that items requiring corrective I action are properly identified in accordance with NQA procedures.

l 17.2.1.2.4.2 Limerick Independent Safety Engineering Group The Limerick Independent Safety Engineering Group (ISEG) composition and responsibilities are defined in Section 13.4.5. i i

l 17.2.1.2.4.3 Performance Assessment Division The Performance Assessment Division is under the supervision of a Manager who reports to 17.2-15 Rev. 7 i

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i the General Manager, Nuclear Quality. '

Assurance. The Manager is responsible for ,

cy l s assessing organizational performance and ,

.providing independent evaluations of the ,

effectiveness of PECo's nuclear program.  ;

These assessments will be based on sources of information such as monitoring of plant i

.. . performance trends, QA and Quality Control reports, reports from the-Independent Safety Engineering Groups, trend analysis, observation of plant condition and activities, the conduct of internal evaluations and special assessments and reviews. The Manager will report on these subjects to the Nuclear  ;

Review Board, the Executive Vice President, Nuclear, and the four Vice Presidents through the General Manager, Nuclear Quality ,

Assurance.

k l 17.2.1.2.4.4 Corporate Nuclear Quality Division ll The Corporate Nuclear Quality Division is under the supervision of a Manager who reports to the General Manager, Nuclear Quality ,

Assurance. The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality activities. This includes manuals and procedures, vendor audits and surveillances, training,. procurement controls,

, oversight of the quality activities of Nuclear Engineering and Nuclear Services, ,

identification of specific and programmatic deficiencies, tracking of these items until they are fully resolved, performing trend analysis, conducting internal audits at the '

corporate offices, and single point of accountability for all Corporate Nuclear Quality (CNQ). The Division consists of three sections: Quality Engineering, Audit, and Administration.

l l 17.2.1.2.4.4.1 Quality Engineering Section l.

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, l The Quality Engineering Section is under the i supervision of a Superintendent who reports to the Manager, Corporate Nuclear Quality

< Division. The Superintendent's responsibilities include the scheduling and performance of technical and/or performance based internal audits, the analysis of trend L

information, the generation of trend reports, the review and approval of procurement documents, specifications review / approval, modifications interface, verification of NRC correspondence, engineering programs overview expertise and technical direction for the Nuclear Fuel QA Program.

o l 17.2.1.2.4.4.2 Audit Section The Audit Section is under the supervision of a Superintendent who reports to the Manager, Corporate Nuclear Quality Division. The Superintendent is responsible for.providing administrative supervision selected services audits, security screening audits, vendor audits and surveillances, and maintaining the '

l Evaluated Vendors List. The Audit Program will involve compliance-based, performance-based and/or technical-based audits or a combination thereof, as appropriate. Where it is practical and appropriate (e.g.,

operational audits), the audits will be primarily performance-based and/or technical-l based audits, l

17.2.1.2.4.4.3 Administration Section The Administration Section is under the supervision of a Superintendent who reports to l the Manager, Corporate Nuclear Quality. The l Superintendent is responsible for the generation and distribution of.NQA reports; l the trending of quality deficiencies; the maintenance of the Quality Assurance Tracking l and Trending System (QATTS); administrative l supervision and technical direction to the QA Assistants and clerical staff; the preparation of the NQA budget, keeping the appropriate NQA

. Superintendents current on the recertification 17.2-17 Rev. 7

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requirements for their personnel; resolving identified training deficiencies; maintenance 3

of CNQ personnel qualification records; '

maintaining current codes, standards and regulations pertaining to the Quality  ;

Assurance Program; and advising the Corporate

, Nuclear Quality Manager on the status of ,

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.. regulations, codes and standards which may l affect the content of the.QA Plan, NQA l personnel training, entering NQA records into

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, the Nuclear Records Management System, the l review of-NQA administrative procedures, review of Nuclear Group administrative  :

procedures, review and revision of the  !

FSAR/UPSAM, review and revision of the NQA j Plan, and the standardization of office / site i procedures.

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1 l 17.2.1.2.4.5 Quality Improvement Division The Quality Improvement Division is under the supervision of a Manager who reports to the General Manager, Nuclear Quality Assurance. ,

The Manager is responsible for establishing, ,

developing, and assisting in the maintenance of Quality Improvement Processes in'all organizations in the Nuclear Group. The Division is not involved in Nuclear Plant ,

, Quality Assurance activities.

17.2.1.2.5 Nuclear Engineering Nuclear Engineering, under the direction of the Vice President, Nuclear Engineering, who ,

l reports to the Executive Vice President, ,

Nuclear, is comprised of four Divisions:

Engineering, Limerick Unit 2, Project Management, and Engineering Design. Nuclear Engineering organization, duties, and responsibilities are described in Section 13.1.1.2. The organization of Nuclear l Engineering a:? shown in Figure 17.2-5.

17.2.1.2.6 Plant Operation Review Committee (PORC) 17.2-18 Rev. 7

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, j The PORC composition and responsibilities are.

defined in Section 13.4.2 i

17.2.1.2.7 Nuclear Review Board (NRB) i

. The NRB composition and responsibilities are ,

, defined in Section 13.4.3.

t 17.2.1.3 Engineering and Production i

The Engineering and Production organization is-under the direction of the Vice President, Engineering and Production. The Vice President is responsible for providing support for. nuclear operation activities through the Production and the Engineering and Construction departments. The organization of Engineering and Production is shown in Figure -

17.2-6. l s

17.2.1.3.1 Production Department The Production Department is under the direction of a General Manager who reports to .

the Vice President, Engineering and

, Production. The General Manager is responsible for providing services to the -

nuclear production activities. The Production Department is comprised of: Services Division, System Operation Division, and ,

Maintenance.

l 17.2.1.3.1.1 Services Division  !

l The Services Division is under the direction of a Manager who reports to the General Manager, Production Department. The Services Division is comprised of Fuels Section, Methods Section, Performance and Cost Section, and Training Section. The Performance and Cost Section and Fuels Section are not l involved in nuclear plant Quality Assurance activities.

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L 17.2.1.3.1.1.1 Methods Section

The Methods Section, under the direction of a j

Superintendent whc reports to the Manager,

i Services' Division, is responsible for the  ;

L preparation and distribution of rules and procedures that are necessary to provide  ;

. . . . industrial safety protection to personnel and l

, equipment in generating facilities. This responsibility does not include safety  :

protection for personnel ot equipment in  ;

nuclear generating stations from exposure ta i the hazards of radioactivity. '

These rules and procedures are directed at protecting personnelc in, on, or around machines or equi.pment during repair, maintenance, operation, and associated activities from injury due to unexpected energiration or.startup of equipmente These r rules are implemented by affixing appropriate lock-out/ tag-out devices to the machines or equipment energy isolation devices. ,

The Methods Section is responsible for the preparation, control, and distribution of the l book entitled Rules for Permits and Blocking.

. The Methods Section is responsible for the investigation of on-the-job accidents as directed by the Manager, Services Division. ,

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17.2.1.3.1.1.2 Training Section The Training Section, under the direction of a L Superintendent who reports to the Manager,

! l Services Division, is responsible for l preparing and conducting various training programs for fossil / hydro operations and supports the Naclear Training Section, ao required. In addition, the Training Section ,

administers the PECo operating employee qualifying exam! nation program for the Fossil / Hydro Generation Stations, as

, appropriate.

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The Engineering and Construction Department is under the direction of a General Manager who reports to the Vice President, Engineering and l-Production. The General Manager is

< responsible for providing services as needed

to the Nuclear-Group. The department is comprised of the following divisions

,

~

.. . Research, System Planning, Construction, Engineering, Engineering Designe and Testing and Laboratories. The Research, System Planning, Construction, Engineering Design and-  ;

Engineering divisions are not involved in '

nuclear plant QA activities.

17.2.1.3.2.1 Testing and Laboratories Division The Testing and Laboratories Division is under l the direction of a Manager who reports to the i General Manager, Engineering and Construction Department. The ' c ivision is composed of: '

Laboratories Section, Communications and Control Section, and System Sorvices Section. -

The System Services Section and the Communications and Control Section are not ,

involved in nuclear plent GA activities at .

LGS.

I o

l 17.2.1.3.2.1.1 Laboratories Section The Laboratories Section is under the supervision of a Manager who reports to the .

Manager, Testing and Laboratories Division. '

The Section is responsible for the calibrating of measuring and test equipment; for '

conducting metallurgical tests; and for testing and evaluating mechanical components, electrical components, and materials; and for assisting the nuclear plant staff in the performance of routine and npecial tests end analysis of a chemical nature as requested, l

l 17.2.1.4 Personnel and Industrial Relations 1

17.2-21 Rev. 7

Personnel and Industrial Relations is under  !

the direction of a Vice President who reports to the President and Chief Executive Officer  !

of the company. Personnel and Industrial Relations is composed of three departments:

Industrial Relations, Medical, and Personnel. -

Medical and Personnel are not involved in i nuclear plant Quality Assurance activities.  !

The organization of Personne? and Industrial j l Relations is shown in Figura 17.2-8.  ;

l i

l 17.2.1.4.1 Industrial Relations Department The Industrial Relations Department is under the direction of a Manager who reports to the Vice President, Pert,onnel and Industrial Relations. The Department is compoced of four  ;

Divisions of which only the Safety Division is ,

involved in nuclear plant Quality Assurance activities.

l 17.2.1.4.1.1 Safety Division , ,

The Safety Division is under the direction of a Director who reports to the Manager, Industrial Relations. The Safety Division Fire Protection Section is under the l

supervision of the Company Fire Marshal who reports to the Director, Safety. The Fire Protection Section, in conjunction with Nuclear Group site personnel, performs ot arranges to perform certain fire equipment i tests and inspections, both routine and as

! required by Technical Specifications. In addition, the Safety Division Fire Protection Section is responsible for the procurement, -

testing, replacement, and record keeping of l

fire hoses, extinguishers, fire brigade self-contained breathing apparatus, and other fire fighting equipment as required. The Company Fire Marshal is responsible for the review of fire protection system designs, as requested.

The safety Division is responsible for at least a once per year review of housekeeping practices that affect safety. The Safety

. Division assigns a Safety Representative to l

17.2-22 Rev. 7

v s * ,

e3ch nuclear power plant so as to provide a constant review of all industrial safety practices that affect personnel safety.

l~17.2.1.4.2 Information Systems and General Services.

~

Information Systems and General Services is under the direction of.the Vice President, Information_ Systems and General Services, who reports to a Senior Vice President, Finance.

Information Systems and General Services is composed of four departments: Purchasing, i Information Systems, Service Operations and Real Estate. The Information. Systems, Service Operations and Real Estate Departments sre not involved in nuclear plant quality assurance ,

activities. The organization of Information ,

Systems and General Services is shown in ,

Figure 17.2-9.  ;

17.2.1.4.2.1 Purchasing Department I

The Purchasing Department, under the direction of a Manager who reports to the Vice +

President, Information Syctems and General '

Services is responsible for purchasing all l , equipment, material, spare parts, and services l as requisitioned by the LGS Staff, Stores

! Division or other requisitioning organizations.

l The Nuclear Fuel Section is responsible for l 1. The purchase of: *

. nuclear fuel assemblies and related services l . urani:am concentrates

! . uranium conversion and enrichment l services l

l l . radioactive waste disposal services L

l 17.2-23 Rev. 7

a <.

. control rod blades, local power -

E l range monitors and fuel chant.els;

2. Contracting for nuclear fuel cycle requirements to meet long term requirements as established by the Fuel '

Mcnagement Section of Nuclear Services.

1 17.2.1.5 Legal Department The Legal Department is directed by the Senior Vice President and General Counsel with the aid of the Vice President and Associate '

General Counsel. The Legal Department has the ';

responsibility for the activities of the Legal Division, Internal Auditing, and the Claims -

Security Division. The organization of the  ;

Legal Department is shown in Figure 17.2-10.

17.2.1.5.1 Claims - Security Division The Claims

• Security Division is under the direction of the Manager, Claims - Security '

} , Division who reports to the Vice President and Associate General Counsel, Legal Department.

The Director of Security, who reports to the -

Manager, Claims - Security Division, is responsible for advising and assisting all departments of the company in security related '

matters.

17.2.2 Quality Assurance Program 17.2.2.1 The operating philosophy of the Philadelphia Electric Company places emphasis and primary concern on the safety of its employees and the public. Other considerations such as continuity of service, equipment protection, 17.2-24 Rev. 7

~

cr o .

I economic operation, and environmental effects l are recognized as important but are secondary I to human safety.

The Quality Assurance Program described herein l applies to those structures, systems, and components of the Limerick Generating Station  ;

.. that prevent or mitigate the consequences of i postulated accidents that could cause undue  ;

risk.to the health and safety of the public. ,

The specific structures, systems, and components to which the QA Program applies are

• identified through the Project Q-List, Quality l Assurance Diagrams, and Table 3.2-1. ,

l The Quality Assurance Program elements described harein shall be implemented by '

written procedures which shall be established  !

at the earliest practical time consistent with the schedule for the activity and in all cases prior to performing activities applicable to those elements.

17.2.2.1.1 Philadelphia Electric Company's many years o,f experience operating generating stations has evolved a wide spectrum of management measures directed toward efficient and safe operations.

The Quality Assurance (QA) Program for LGS

, recognizes quality assurance as an L interdisciplinary function involving many organizational components (i.e., departments, divisions, sections, groups, and individuals) and is not regarded as the sole domain of the Nuclear Quality Assurance (NQA) Department.

l Quality Assurance encompasses many functions and activities end extends to various levels

! in all participating organizations. First-L line supervision is responsible for the

quality of the work performed under their supervision. Second-line supervision and qualified craftsmen / technicians may verify work functions associated with normal operation of the plant, routine maintenance, L and certain technical services routinely l

assigned to the onsite operating organization where necessary to assure quality.

Independent inspection of non-routine maintenance and plant modifications shall be 17.2-25 Rev. 7 l

i. l

.c0 :C l

1 l

performed, as required, by qualified individuals who are organizationally independent of the individual or group l performing the work. The Station Vice .

President has overall responsibility for the  !

execution of the administrative controls at l the plant and implementation of I

.. , responsibilities assigned to plant personnel j by the QA Program. An overview of the-QA j Program is provided by personnel from Nuclear .

l Quality Assurance who are organizationally  !

independent of other nuclear organizations.

NOA shall ensure, through the auditing, I l technical monitoring and quality control 1 programs, that activities affecting quality are accomplished in accordance with the requirements of the QA Program. ,

b 17.2.2.2 Management recognizes the need to maintain a i competent plant staff and to provide this staff with the support necessary to maintain ,

operational safety. To meet this goal, certain activities conducted in the plant have been recognized as important to operational -  :

safety, and specific management control measures have been set up to assure quality in these activities.

Personnel shall be trained and indoctrinated

, in these activities which are pertinent to their job description and responsibilities, with due regard to the effective implementation of the QA Program. Management requires that operations be conducted in accordance with approved procedures and has established review and reporting mechanisms which provide prompt and effective action when exceptions occur.

The staffing of the station is such that certain disciplines (e.g., Chemistry, Stores and Purchasing, Maintenance) share high level L

supervision and management with other plants and facilities of the Philadelphia Electric l Company. This is an important aspect of the staffing which provides a great wealth of experience and knowledge in assuring proper operation of the plant.

l l

l 17.2-26 Rev. 7 i

1

c t-The station technical group is composed i primarily of graduate engineers _who acsist l plant supervision in areas of operational surveillance, maintenance, plant monitoring, and testing. Additionally. Philadelphia  !

Electric Company's own highly qualified l l Nuclear Engineering Departmont, nhich is responsible for the design and construction of the plant, is'readily available for engineering consultation during operation.

First- and second-line supervisory positions  !

are normally filled by promotion of qualified i l personnel. This procedure assures knowledgeable and experienced checking and inspection of in-progress work activities and is considered a noteworthy aspect of ,

operational safety.

l Shift operation at a power plant is an important activity that greatly impacts safety. This activity is concerned with the '

proper performance of the plant processes both during the shutdown and power phases. It >

involves surveillance of plant variables and manipulation of controls to maintain variables at desired levels. Prompt and effective l action during off-normal plant operations ir

• required. Management has taken measures in

l. the area of training and staffing which enhance safety of operation and require mechanisms to be established which provide objective evidence that important operations are being performed in accordance with established procedures. Appropriate objective evidence, in the form of check-off lists, log records, and data sheets, is reviewed by appropriate supervision as specified in Administrative Procedures.

Another important aspect of shift operations is communications. Communications between shift personnel and plant supervision, between one shift and succeeding shifts, and between "

staff group leaders and shift supervisors must be effective to assure safe operation. Viable mechanisms are established, where appropriate, to enhance inter-plant group communications to assure timely and effective communications.

1 1

, 17.2-27 l

Rev. 7

We .

> 17.2.2.3 Training and qualification of plant operators )

is an on-going activity required to ensure  ;

safety in operation. Training and retraining ,

efforts are formalized and objective evidence is available for auditing purposes. On-the-  ;

job " hands on" experience is designed into the program to a maximum practical degree.  ;

.. . Records of each operator's important  !

operations are maintained, e.g.,' reactor startup and shutdown. Qualified instructors l and training material are utilized. .

Evaluations of students' training progression  ;

and requalification status are maintained.

l The training program assures competent material selection and instruction. The i requalification program is designed to maintain current operator competence and uses current NRC requirements. Training aids and individual study periods shall be utilized, as appropriate. Formal classroom instruction e shall be scheduled. Evaluation of trainees' progress shall be documented.

The training program also includes provisions ,

for nonlicensed personnel and general employee indoctrination. As appropriate to the duties and responsibilities of an individual, general employee training includes: general description of plant and facilities, job related procedures, radiological health,

, emergency plan and procedures, industrial safety, fire protection program, quality assurance program, and security plan and procedures. Personnel performing quality-

• l related activities shall be trained and *

( qualified in the principles and techniques of L the activities being performed. Training l shall be in accordance with written procedures l' to ensure that suitable proficiency is l achieved and maintained. Areas of training i include technical training, on-shift training, qualification or certification requirements, and qualifying tests, as appropriate for the job position. Administrative procedures shall delineate the scope, objective and methods associated with the training program, along with requirements for requalification and l documentation of the training accomplished.

The qualification requirements for plant i personnel are described in Section 13.1.3.

L 17.2-28 Rev. 7

C H n .*

C Philadelphia Electric Company has taken  ;

predetermined and systematic action to assure I

that LGS operations are conducted in a safe )

h efficient manner. High employee loyalty ,

evidenced by many years of continuous service i and low employee turnover, combined with .

)

specialized training programs and other i employee benefits are recognized as l

, significant contributors to quality, l

l l

l 17.2.2.4 Surveillance testing of safety systems and instruments as required by the Technical Specifications is an activity which is an )

important contribution to the operational i safety of LGS. Administrative Procedures i require that these tests be conducted in a '

l. high-quality manner by knowledgeable personnel familiar with test procedures. Surveillance .

Test procedures are reviewed by PORC and  !

approved by the Plant Manager or designee.

Surveillance tests associated with process  ;

operation are conducted by the shift ,

operations group with review by shift supervision. Approved procedures and l documented reports are utilized to assure hrgh quality in this activity.

17.2.2.5 Work associated with radiation protection, radioactive waste and chemistry is conducted l

under supervision of the Senior Health 5 l

Physicist, Senior Engineer Radwaste, and the Senior Chemist, respectively, who report through Services Superintendent to the Plant Manager. The activities are divided into two types: first, those of a routine and uncomplicated nature and second, those of a -

non-routine or complex nature. Activities of l the first type are generally performed by members of the shift operations group. In s this way, this group maintains competence in -

the area of radiation control and chemistry and provides the capability for 24-hour-per-day radiation and chemistry monitoring.

The more complex studies and tests are performed by members assigned to the technical group. The importance of radiation control

, (ALARA) and chemistry on nuclear plant 17.2-29 Rev. 7

operation warrants every effort to establish high quality in this activity. Mechanisms such as shift and daily written reports, plots, and log books will be reviewed by appropriate supervision as specified in Administrative Procedures. Inspections.and reviews will also be conducted by senior plant

.. .. supervision as defined in Administrative Procedures.

17.2.2.6 Mechanical, electrical, and instrument and controls maintenance at LGS will be performed by the Maintenance / Instrument & Control group.

l- The Maintenance /I&C group reports through its Superintendent-to the Plant Manager. . Nuclear Quality Assurance, which is organizationally independent of the plant-operations staff, shall assign personnel to the station to provide quality control checking and inspsetion.

l Only qualified craftsmen are utilized to perform maintenance work. First and second level supervision and qualified craftsmen / technicians have had specific -

quality training and are recognized as an important means of contro' ling quality. These personnel may verify thos activities that are evaluated as not requiring organizational independence.

Installation of new components or the physical change in systems of a major nature is considered a modification activity which will normally be implemented by the Nuclear Engineering Department. Quality assurance.

measures and organization for modifications shall be implemented in a fashion similar to that used during plant design and construction with the additional assurance of review and approval by the Plant Operations Review Committee and, as appropriate, the Nuclear Review Board, i 17.2.2.7 The procurement of spare parts, materials, and services for LGS is initiated by cognizant personnel in accordance with approved policies l and procedures. Materials Management is an 17.2-30 Rev. 7

. .  ;

• i indepenoent organization functioning as a '

service group to the station. The ordering, j receipt, storage and issuance of materials and  :

services are accomplished in accordance with i Materials Management, Corporate, NQA, and plant procedures which incorporate measures to ,

assure quality. Requisitions for materials or ,

.. , services are transmitted from Materials

• Management or other authorized PECo entities to the Purchasing Department where buyers l execute the order in accordance with Company ,

purchasing procedures and policies. Spare  !

parts, materials, and services may also be obtained via a contractor who has been evaluated and is on the Evaluated Vendors i List.

9 17.2.2.8 The QA Program for Limerick Generating Station l will be defined in the Nuclear Quality Assurance Plan (QA Plan). The QA Plan ,

implements the policies and objectives of the >

Nuclear organization, and applicable codes, standards, and regulations by addressing the managerial and administrative controls in -

various operational activities such as:

Startup, Training, Health Physics, Chemistry, Fuel and Invessel Material, Shift Operations, Surveillance Testing, Maintenance of Instruments, Maintenance-Electrical and l , Mechanical, ISI/IST Inspection, Stores and Purchasing, Modifications, Radioactive.

Waste / Material, Nuclear Engineering and Plans.

For each of these activities, the QA Plan shall address-the eighteen criteria of 10CFR50, Appendix B, and describe how each

• activity is in compliance with tne applicable criteria in Appendix B. In addition, the radioactive waste / material activity shall also -

address the requirements of 10CFR71, Subpart H, Packaging and Transportation of Radioactive Material, Quality Assurance. Procedures are written to implement all aspects of the QA Plan. A matrix of these procedures or documents is presented in Appendix 17.2.I to demonstrate that 10CFR50, Appendix B criteria are fully implemented by documented procedures.

17.2-31 Rev. 7

e e  ;

Also, the QA Plan shall require written procedures to implemenc the requirements of the Regulatory Guides listed in FSAR Section 1.8, the General Design Criterion I of .

Appendix A to 10CFR50, and 10CFR50.55a.

l NQA, in the review of Administrative  !

. .. , Procedures, shall ensure that regulatory guide {

commitments are included in the appropriate l procedures.  !

t l All quality assurance program activities performed within Philadelphia Electric Company  ;

are subject to formal periodic audits by NQA.  :

These audits verify that organizations performing these activities are complying with  ;

and properly implementing their procedures, j i

f Administrative procedures for the preparation of documents, such as drawings, ,

specifications, and procedures assure that the t use of appropriate equipment, suitable  ;

environmental conditions, and compliance with necessary prerequisites are considered, as necessary, to perform activities affecting quality under controlled conditions. _

The development, control, and use of computer code programs, commensurate with its ,

~

importance, shall be conducted in accordance '

with the appropriate provisions of this QA

, Program. Software, commensurate with its l importance, used in the operational phase of r

l Limerick Generating Station, shall be subject to verification by Philadelphia Electric  :

Company or other qualified personnel.

Measures shall be established to ensure the computer codes are appropriate for their specific applications.  :

The QA Program shall be reviewed periodically l by NQA to determine status and effectiveness.

The Nuclear organization management is informed on a continuing basis of the status and effectiveness of the quality assurance l program through reports at Executive Vice l President - Nuclear staff meetings, and l through distribution of audit reports '

l (including NQA audits, Joint Utility Management Audits, INPO Audits, and NRC Inspections and Audits).

17.2-32 Rev. 7 l

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m e n,h a.. - '

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e 746  ;

l E17. 2. 2. 9: 'The-QA Plan' applies;to activities affecting ~

, .the' quality-of' systems,. components, and structures installed--.to prevent.or mitigate

',l* the consequences of an accident.which could be harmfulEto the public. These structures,.

systems, and components are-identified through the' LGS Project Q-List and the Quality

-l. .. .

Assurance Diagrams and Table 3.2-3.- Although the measures discussed apply'primarily'to-Q-listed _ equipment, they.may also be applied in varying degrees to non-Q-listed equipment- .

s (e.g., Seismic IIA). The selected application 't of these quality, measures to non-Q-listed D= systems is. intended to enhance operational

.,. safety and reliability.-

l-,rp .

-The QA Plan, including revisions thereto, shall'be approved by,the Manager, Corporate Nuclear Quality; General Manager NQA; Station l Vice President; and the Executive Vice President, Nuclear. prior'to issue. ,

l:

17.2.2.10 Nuclear Quality Assurance is staffed with-

l. trained, qualified, and experienced persennel

! -who.are organizationally independent of other.  ;

E> Nuclear organizations. NQA has the primary-

, responsibility to verify through the review of

! objective evidence and the performance of observations that the quality assurance l

activities are being accomplished in accordance with the QA Plan. This l verification is accomplished by means of the NQA Audit, Quality' Control, and Technical L Monitoring programs.

The Superintendent, Administration Section, Corporate Nuclear Quality Division, in ,

conjunction with the site NQA training coordinators, is responsible for developing

~< and maintaining a quality assurance indoctrination and training program for NQA personnel to establish proficiency in quality assurance / quality control and to qualify personnel in accordance with NQA requirements m and procedures.

NQA may involve itself in the planning of quality related activities as it deems 17.2-33

Rev. 7

_ , _ - ~ _. ,_ _ , _ . . . _ . .-

p-  !

. , co ' .c 1 J

4.

'l

' ~

necessary'to assure that quality _ assurance l' ye requirements are provided.

Resolutions of differences of opinion between  :

audited and auditing personnel, regarding deficiencies or.noncompliances identified by NQA-shall be made:by management. NQA l- .. .. management is authorized to stop work when ,

' such work is considered to be a serious quality degradation. '

17.2.2.11 The quality-assurance program for LGS'is documented by written' policies and procedures-and shall be carried outEthroughout the life e of'the plant. Administrative procedures shall

-control the preparation, review, approval, and-distribution of these documents.

NQA shall review and approve all .

Administrative Procedures that implement the l QA Plan.

The administrative and implementing procedures ,

and instructions pertainino to quality-relat_ed activities are~ written to accomplish those activities with appropriate equipment under suitable environmental conditions and in compliance with necessary prerequisites.

o 17.2.2.12 Information concerning plant conditions and status will be made available to NOA personnel to enable responsible NQA supervision to determine when audits, surveillances, monitoring, or inspections should be performed. This information may be in the form of communications with plant management or staff personnel through periodic meetings.

In addition, NQA personnel shall periodically review operating logs, maintenance work schedules, fuel handling operations schedule, l ISI/IST inspection program, and modification proposals, to ensure that NQA personnel are involved in day-to-day activities that are important to the safe operation of LGS.

17.2.2.13 Personnel performing or verifying quality-

- related activities shall be:

17.2-34 Rev. 7

L ,

Wa . -

la . Trained in the-pu.rpose, scope, and

~

j implementation of quality-related-manuals, instructions ~, and procedures. ,

b. Trained and certified in the principles, >

techniques, and requirements of the

. performed activity and such certification

.. .. shall delineate the specific area of-expertise and criteria used.

17.2.2.14 The training / certification. program shall include documentation of'the objective, h content,. enrolled attendees, date'of attendance, and examinations given.

17.2.2.15 The training / certification program shall provide for retraining, reexamination, and/or-recertification as appropriate.

17.2.2.16 The Manager, Performance Assessment Division (PAD), is responsible for assuring-that .

appropriate performance measurement programe  !

are in place to monitor organizational performance, inputting and closure-of PAD recommendations in QATTS database, and L providing independent assessment of the E effectiveness of' nuclear organizations. The' Manager will report on these assessments to the Nuclear Review Board, the Executive Vice President, Nuclear, and the four Vice Presidents through the General Manager, NQA.

p 17.2.'2.17 The Superintendent, Independent Safety Engineering Group (ISEG), is responsible for reviewing plant operating characteristics, NRC L issuances,-inputting and' closure of ISEG l recommendations in QATTS database and other l appropriate resources of plant design and y operating experience information that may i

indicate areas for improving plant safety.

17.2.3 Design Control 17.2.3.1 Measures shall be established and documented to provide for the control of design functions. The provisions shall identify responsibilities and activities to ensure that the following are accomplished, as applicable, for the particular design:

17.2-35 Rev. 7

$EE

• 1 .;

{',y "

+,

a.- Design bases are translated into design-documents such as drawings,-

specifications, instructions, and 3, procedures.

b.- Appropriate quality standards are specified and deviations from-these standards are identified,. controlled, and documented.

c. Design adequacy is checked by means such as design reviews, alternate calculational methods,-or testing.

programs.

1

d. Design reviews include appropriate attributes such as accessibility for l ISI/IST inspection, maintenance, and repair; suitability of application of materials, parts, equipment, and

, processes; reactor physics, stress, thermal, hydraulic, and accident analysis;. delineation of acceptance criteria for inspections and tests; and other design work on 0-listed items or systems.

e. Records of implementation of these-design control measures, as defined in the applicable design control procedures, shall be available.for review.

f. The responsible engineering organizations  !

ensure that design drawings and  :

specifications are prepared, reviewed,  !

and approved in accordance with 4 procedures and that these documents i contain the necessary quality assurance requirements, such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

l 17.2.3.2 The design procedures include provision to control design interfaces and to allow coordination among participating design

organizations. These measures shall include procedures for the review, approval, release, t-i i

1:

17.2-36 Rev. 7

(bb e c (E

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" distribution, and. revision ~of documents involving design interfaces as appropriate.

~

17.2.3.3 ' Changes to the design, including field-initiated changes, are controlled-and=

.. .. subjected to design measures commensurate with those applied to'the origi pl design. Where-

-necessary to ensure proper application of design information or' changes, a-." place-in-

, effect" statement shall'be. included:in the appropriate procurement or design document.

L

-17.2.3.3.1 Instructions for the design of modificationa shall be written to require compliance t'o regulatory requirements as defined in 10CFR, ,

Part 50.59, and as defined in the license l L application in accordance with the design j basis of the. structures, systems, or  !

components.  !

-17.2.3.'3.2 Administrative procedures shall be written which require that modifications be reviewed- .

af ter completion of the work to deterr.:ine if' i the "as-built" installation differs from the q original design, and that drawings and documents'are revised, .if required, to reflect .

the actual installation in a timely manner ,

., according to' procedures, t 17.2.3.4 Approval of modifications shall be delineated in the Administrative Procedures. Design ,

L documents for modification shall be L administered, maintained, and controlled in I accordance with Administrative Procedures.

17.2.3.4.1 As-built documents are controlled in accordance with established procedures which describe a definite method to be followed upon completion of any plant modification. This procedure includes notification of completion by field personnel, mark-up on drawings of any changes from the original design, and l

17.2-37 Rev. 7

~ .. . - . - _

pt.4 i- e approvals of certain as-built. drawings m equivalent-to the original design.

l 17.2.3.'S Measures shall be established to assure that-the modifications meet-design, installation, inspection,' testing, and quality assurance standards. Testing ~of modifications assures-system integrity and provides for evaluation of performance prior to operation.

17.2.3.6 Written procedures shall provide design  !

reviews which shall be performed by individuals or' groups other than-the original-designer. The design and design review l processes shall provide for preparation of  !

documentation to establish that the design process was used to describe the scope, depth,.

and results of design reviews. I i

17.2.3.6.1 Design adequacy of modifications shall be ,

determined by an independent design review ih l accordance with Administrative Procedures.

These reviews shall be performed by vendors, cognizant engineers on the plant staff or in the appropriate PECo organization. The

-reviews.shall. consist of reviewing the design, 1 spot checking 1the calculations or analysis,  ;

and assessing the results against the original' .l design basis and functional requirements. l l

17.2.3.6.2 When the adequacy of design is to be verified by test only, procedures and instructions will  ;

be written which include measures to ensure i that: 1

a. Criteria are provided to specify when  !

verification should be by test.

b. Where applicable, prototype, component, or feature testing will be performed prior to installation of plant equipment.

In those cases where this cannot be met, the testing will be deferred but not i 17.2-38 Rev. 7

y '

s? . 'e :

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b'eyond the point when the installation would become irrevarsible,

c. Tests will be performed under conditions

-that simulate the most adverse design

. conditions, as determined by analysis. -

17.2.3.7 The requirements for materials, parts, and equipment, including standard, commercial (off-the-shelf) items are defined for procurement by means of a. specification-type document which is subjected to-design review prior to use.

17.2.3.8 The following is~a~ general description of the

- process used to, control modifications.

1 Because modifications differ in scope and complexity, the activities do not'necessarily

- occur in the sequence listed below'and certain activities may not apply to all Modifications, i

a. Modification is requested and evaluated '

and, if.the concept is accepted, the i following steps are taken:

b. Engineering Work Letter is' issued to define the modification and

, responsibilities for its accomplishment.

I

c. A Safety EvaluationLis performed.to determine if an unreviewed safety question or change to the Technical Specifications is involved,

d. A design criteria document is developed to establish the design basis for the modification.

e. Modification drawings are prepared and approved to define the design and the  ;

work to be accomplished.

f. Calculations and design analyses are prepared to substantiate the design.

g. Specifications and procurement documents

. are prepared and issued.

17.2-39 Rev. 7 d- , , _, U

h. Vendor document submittals, as defined in the procurement-documents, are reviewed andiapproved'.

go i. Receipt inspection requirements-for ,

procured-items are issued by the appropriate PECo organizations for use in. !

.. . performing receipt inspection.

j. Installation inspection and testing requirements are developed in cases.where procedures do not exist or where special' instructions are needed.

17.2.4 Procurement Document Control

'17.2.4.1 Measures shall be established and documented to assure that applicable regulatory l- requirements, design bases, and other requirements which are necessary.to assure adequate quality are included.or referenced Jn the documents for procurement of items and services. Changes in procurement documents shall be subject to the same degree of control l.. as was utilized in the preparation of the original document, as. described herein.

The documents used for procurement shall ,

specify appropriate requirements for: ,

a. . Submittal of drawings, specifications, procedures, and plans to PECo. The time of submittal (e.g., prior to use) and the purpose of submittal (e.g., review, approval, or.information) shall-be specified.

b. Submittal of record's to PECo. The time of submittal (e.g., prior to shipment) and the purpose of submittal (e.g.,

review, approval, or information) shall be specified.

c. Retention of records by supplier.

17.2-40 Rev. 7

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to. .-

d. PECo's right of' access to supplier

-facilities.anderecords for inspection and audit and source inspection as determined by the responsible engineer.

e.

Reporting and disposition of-nonconformances"from procurement

, requirements when the vendor's~ proposed

. disposition is "use-as-is" or " repair".

f. Submittal of documentation-that identifies the purchased items and,the

-specific procurement requirements (e.g.,-

codes, standards, and, specifications) met' by the' item,

g. . Submittal of documentation identifying any procurement requirements that have not been met,

h. Design basis technical requirements, including applicable regulatory requirements.

i. Appropriate material and component identification requirements. ,

j. Appropriate test, audit, and inspection-requirements.

k. Appropriate requirements for fabrication ,

such as special process procedures.

1. Appropriate requirements for handling,-

storage, packaging,~and shipping.

m.- Lower tier procurements.

n. Any additional documentation requirements.

17.2.4.2 To the extent necessary, procurement documents shall require vendors to provide a QA program consistent with the pertinent requirements of 10CFR50, Appendix B, or equivalent alternative

-l measures shall be specified to assure the quality of the product. The program implemented by the supplier shall be approved by the Nuclear Quality Assurance Department 17.2-41 Rev. 7

as , !? 1

.  :<: c prioritosinitiationfof the affected I activities.

Suppliers shall be required to either.(a)  ;

impose appropriate QA-program requirements on .

their subtier' suppliers, or (b) implement

, equivalent alternative measures to assure

.. product quality.

17.2.4.3 Requisitions for nuclear safety-related items shall clearly. indicate that the request is for

" nuclear safety-related" items.

t 17.2.4.4 Documents, and revisions thereto, used for

,. c procurement, including the procurement of spare or replacement parts as a part of a -

modification, are subject to the review.and a approval process described herein.

17.2.4.5 Administrat'ive Procedures shall require that" a I

cognizant member-of the requisitioning '

organization determine the technical and m quality assurance requirements for a nuclear

,. safety-related item or service. The member L' shall determine the' applicable specifications, l , drawings, details, and' code. requirements'to be applied to the procurement document. 'The member shall also determine any special controls to be applied such as vendor i controls, hold points, and tests to be performed, along with acceptance or rejection criteria, subvendor controls, vendor check

l. points, test data, test results, special l labeling, storage. instructions, requirements I

for reporting nonconformances, shipping instructions, and documentation requirements.

4 17.2.4.6 Administrative Procedures shall clearly delineate the responsibilities and sequence for the preparation, review, approval, and control of the documents used in procurement.

Technical and quality assurance requirements are defined in-procurement documents. These 17.2-42 Rev. 7

requirements are subjected to the design review process and are referenced in i a ,

procurement-documents.  !

I l

17.2.4.7 Nuclear Quality Assurance personnel-shall I review ~and approve the documents which define i the QALprogram and quality requirements to 1

-assure that such requirements are correctly stated, controllable, and.inspectable and that adequate acceptance / rejection criteria are defined. This permits verification that the documents to be used for procurement have been-prepared, reviewed, and approved-in'accordance l with the QA program.

17.2.4.8 The' review and approval of the documents discussed above are performed prior to release as a part of solicitation for bids, prior to purchase order award, and prior to the issuance of changes, a

17.2.4.9 Purchase. orders shall be issued to suppliers whose quality assurance programs have been evaluated for adequacy, or other appropriate l

.- measures shall be defined to assure quality.

I 1

l. 17.2.4.9.1 The Materials Management Section'and '

Purchasing Department shall process only approved-requisitions in accordance with PECo Procurement procedures and policies.

17.2.4.9.2 The Purchasing Department shall not alter'the requisition of any nuclear safety-related item or service without prior approval of the requisitioning source, except for commercial l items such as price, quantities, schedule, L F.O.B. terms, etc. Prior approval is required

, from the responsible organization for cases where the requisitioning source is not the L PECo organization responsible for the 17.2-43 Rev. 7

' ..  ;.

technical and quality aspects of the item or service. .

--17.2.4.10. Nuclear Engineering procurement documents for

., modifications shall be controlled in accordance with administrative procedures ~.. ,

17.2.4.11.. .. Procurement documents shall be maintained in accordance with Section 17.2.17.

17.2.5 Instructions, Procedures, and Drawings t

i 17.2.5.1 Activities affecting quality shall be prescribed and accomplished in accordance with

_ documented instructions, procedures, specifications, and drawings which are i prepared, reviewed, approved, and controlled in accordance with the PECo QA Program.

1:

_4

[ 17.2.5.2 The procedures for preparing the documents

, discussed above shall include consideration of l appropriate quantitative and. qualitative L acceptance criteria to verify that important L: , activities have been satisfactorily

! accomplished.

l L The activity may'be prescribed in job specifications, work instructions, shop drawings, job tickets, planning-sheets, operating or procedure manuals, test procedures, or any other type of written form, provided that the activity is adequately described. Quantitative criteria, such as dimensions, tolerances, and operating limits, and qualitative criteria, such as comparative workmanship samples, shall be specified, as appropriate, for determining satisfactory work performance and quality compliances.

The review and approval of station procedures is described in Section 13.5. In addition, PORC, whose members are knowledgeable in

. quality requirements and administrative 17.2-44 Rev. 7

~ w.

, f, T controls,' reviews test-and maintenance

procedures that are developed in the modification process.

i 17.2.5'.3 The Nuclear Quality Assurance Department shall

- ' review and approve the following and the

. revisions thereto:

l1 a. The Nuclear Quality Assurance Plan 1 i b. Nuclear Quality Assurance Procedures.

l

, , i 17.2.5'4 . . Limerick Generating _ Station Administrative

. l- Procedures shall be reviewed by PORC and j approved by the Plant Manager-or'his i designated alternates and the Manager, j Limerick Quality, NQA Department, and shall- be distributed to predetermined personnel. These ,

administrative procedures shall contain H provisions which clearly delineate the _, ,

l' sequence of actions for the_ preparation,  !

1 review, approval, and control of activity implementing procedures, instructions, and drawings. j l i l b l 17.2.,5.5 Implementing procedures, instructions, and i drawings shall include, as appropriate, quantitative, and qualitative acceptance criteria, signoffs, and inspection points to assure that important activities are ';

satisfactorily accomplished.

Appropriate recording documents, such as log  ;

l books, Maintenance Request Forms,. checkoff lists, or data sheets, shall be used, when appropriate, to assure compliance with the ,

instructions, procedures, and drawings.

17.2.5.6 Engineering notification to field forces and other engineering groups for implementation of a modification are given in one or more 7 17.2-45 Rev. 7 J

r >

. 1

[lk , .:  :

H

, Engineering' Work, Letters. The Engineering Work Letter (s) include the following:  ;

a.- Scope-of work

b. Engineering, design, and procurement responsibilities

c. Special testing requirements ,

117 . 2. 5.7- Modification Installation and Testing Memoranda are issued by the Installation Section to define to Installation personnel the work operations necessary to perform a modification. The Modification Installation l and Testing Memoranda include or reference the following:

P

a. Modification drawings

b. Purchase orders for components

c. Major equipment list

d. Special receipt-inspection instructions" for each component, when applicable

e. Listing of work operations, including instructions for performing the-operations, showing, when necessary, which operations are to be performed in-sequence or concurrently

f. Inspection instructions for activities affecting quality

g. Testing instructions for performing tests e

17.2.5.8 Procedures may also include applicable reference to vendor equipment manuals, design drawings and specifications, prerequisites, special precautions and the delineating of the work to be accomplished.

17.2-46 Rev. 7 f_

p

,. .e EquipmentLmanuals and manufacturers'-

instructions shall-be readily available for use.

.j 17.2.5.9' Nuclear Quality Assurance Department personnel

. . . .. shall, in.the course of.the auditing, quality

'll ,

control,'and technical monitoring program,

-selectively review the adequacy, completeness, and effectiveness of implementing procedures, instructions, andJdrawings associated with l activities performed under the.QA Plan.

Administrative type; procedures shall be written by other organizations participating in quality-related activities supporting-operation of-LGS.under the QA Program. These procedures shall contain provisions which-clearly delineate the sequence of actions for the conduct of safety-related activities. The-

l. Manager, Limerick Quality Division, shall-review;and approve these administrative l procedures to assure compliance with the QA L Plan, j

_4 l i

17.2.6 Document Control 17.2'.6.1 Measures shall be. established and documented to control the issuance of documents, such as  !

j instructions, procedures, specifications and

! drawings, including changes thereto, which  !

L prescribe activities affecting quality. These measures shall assure that documents, l- including changes,lare reviewed for adequscy i and approved for release by authorized personnel and are distributed to and used at the location where the prescribed' activity is i

performed prior to commencing the work. These  ;

documents shall be submitted to the LGS Document Administration Center for inclusion in the Nuclear Records Management System.

17.2.6.1.1 Changes to documents shall be reviewed and approved by the same organizations that 17.2-47 Rev. 7

. ~

,7s- /  ;..

cL unless otherforganizations are specificaliy designated. . The. reviewing organizations shall have access to pertinent' background information upon which to base its approval.

and shall havc: adequate understanding-of the requirements and-intent of the original-

-document.

~

17.2'.6.2 -Those participating in'an activity shall be made aware of.and shall use: proper and current instructions, procedures, drawings, and-

.l. specifications for performing the activity. ,

Participating ~ organizations shall have procedures for control of the documents and changes thereto to avoid the misuse of outdated or inappropriate documents.

Procedures will also prescribe the methods (such as training reading lists) by which-those personnel participating in an activity  ;

are made aware ofEmodifications and document changes.

17.2.6.3 Document control measures shall provide fori"

a. Identification of individuals or organizations responsible for preparing, reviewing, approving, and issuing documents and revisions thereto.

b. Identifying the proper documents to be used in performing the activity.

c. Coordination and control of interface documents,

d. Ascertaining that proper documents are being used.

e. Establishing current and updated distribution-lists.

f. A mechanism for temporary and emergency procedural changes.

g. Submittal of approved, issued, controlled document to the Nuclear Records 17.2-48 Rev. 7

$ N. . .s :

Management System for indexing and j a retention, u

" l'17.2.6.~4- The QA Plan and Nuclear Quality Assurance , s Procedures

and. revisions-thereto shall be j controlled per NQA Procedures under the

,- authority of the General. Manager, NQA. e

'17.2.6.5 LGS activity instructions, procedures, and drawings, delineated-in the document control requirements of the QA Plan,'shall be procedurally controlled and approved in ,

accordance with the Administrative Procedures '

r under the authority of designated, responsible management'. These controls establish ,

individual responsibilities for the preparation, re@iew, approval, and distribution that apply to the.various quality related activities.

,, 17.2.6.6 The-control of documents shalls apply to those records delineated in Section 17.2.17.

17.2.,7 Control of Purchased Material, Equipment and Services 17.2.7.1- Procedures for the control of purchased material, equipment, and services shall-j provide.for-the following activities to be L

performed prior to the award of a purchase L order or contract:

f a. A line organization (such as the station

' or a division in the Nuclear Engineering Department) shall have proposed or concurred in the selection of prospective l vendors for material, equipment, or services.

b. The veiidor shall have been evaluated and approved by the Nuclear Quality Assurance L

17.2-49 Rev. 7

'r j c -

i O'

Department using'one or-more of'the )

following methodst. i

~ gl

, 1. Evaluation of the vendor's capabilityLto comply with the r elements of-10CFR, Part 50, Appendix i B, that are: applicable to the type l of' material, equipment, or service

~

being procured or-to co.nply with equivalent' alternatives.. ,

2. A review of previous records and

. performance of vendors who have provided similar articles of the type being procured.

3. A survey of the-vendor's facilities and QA program to determine his -

capability to supply a product which ,

meets.the design, manufacturing,-and quality requirements.

17.2.7.2 The results of vendor evaluations and audits are documented and maintained on file. s 17.2.7.3 Measures shall be established and documented l~ to assure that purchased items and services conform to the~ procurement documente. These-measures shall include provisions for one or

, more of the following techniques depending upon the quantity, complexity,-and importance to safety of-the item being supplied:

a. Quality assurance audits'of the vendor.

b. Witnessing of selected operations, inspections, or tests which are designated with hold points in the fabrication process.

c. Periodic or continuous shop surveillance.

d. Receipt inspection which, depending upon the item supplied, may include appropriate testing of the finished product.

p e. Evaluation of objective evidence of

quality furnished by the vendor.

L 17.2-50 Rev. 7

{!

, . . . h  :.. _._.._. - _. ,,.,. . . _ . . . . . . . , _ . - ,

v. ... ,

of .

l 17.2.7.3.1- Where required by codes, regulations or 1 specifications, documentary evidence that

~, items conform to procurement requirements shall: be a"allable at the plant site prior: to installat on or use of such items.-.This documen try: evidence shall be retained at the plant site and shall be sufficient to identify .

.. , the specific requirements such as' codes,-

standards, and specifications met by the purchesed item. The documentary evidence

. shall be indicated on records traceable to the item or on the item prior to release from receiving. Where not precluded by other requirements, such documentary-evidence may ,

-take the. form of written certifications of conformance which identify the requiremants met by the items, providing means are available to verify the validity of such certificates.

l 17.2.7.4 Receipt inspections shall be performed to verify that material components or parts received conform to the purchase order requirements. ,

e 17.2.7.4.1 Receipt inspection shall be performed by

. personnel who have access to the pertinent L ,

procurement documents and who have an o understanding of-the technical and quality requirements of the procurement document.

Responsibility for receipt inspection shall be delineated in Administrative Procedures.

17.2.7.4.2- Receipt inspection shall include, as appropriate, visual examination of physical L properties, determination, and identification

[ of marking or labeling, and review-and l

inspection of quality assurance documentation to verify conformance with the purchase order specifications and requirements.

L J

L 17.2.7.4.3 Nonconforming items shall be identified, segregated (physically separated and/or conspicuously tagged) and controlled until dispositioned. Control and identification 17.2-51 Rev. 7

. 1 p4.'

s status of-recei'ved material,_ parts, or components shall be accomplished in &ccordance  ;

with Administrative Procedures. l l'7.2.7.5 .The procurement documents shall define or

. . . , provide for defining the records to be-supplied. ,

w 17.'2.7'.6 Deviations from procurement-document requirements, including those requirements in.

vendor drawings and procedures which are approved by PECo, shall be submitted to'PECo for review and approval when the proposed

.l disposition of such deviations is either "use-as-is" or " repair". PECo approval shall be required prior to the vendor proceeding.. The final records for the procured item shall contain documentation of such deviations and of PECo's approval.

17.2.7.6.1 The processing of vendor document submittals7 including final records, shall be controlled in accordance with written procedures which

_l will assure that the documents are reviewed and, when required by the procurement documents, approved by appropriate personnel.

17.2.7.7 Procurement of items or services from other than " Evaluated Vendors" shall be controlled and shall have the concurrence of the General Manager, NQA Department, or his alternate,for establishment of procurement requirements to assure the quality of the product.

17.2.7.8 Vendors that are on the " Evaluated Vendors List" are audited triennially by NQA commensurate with the importance, complexity, and quantity of the product or service being purchased.

17.2-52 Rev. 7

C;:

s=v-F; -

(17.2.8 Identification and Control of Materials,

' Parts, and Components E

17.2;8.1 - Measures shall be established and documented for the identification and control.of 4- .. materials, parts, and components including

. partially fabricated subassemblies.- These l

^

measures shall provide for assuring that only correct and accepted items are used and installed, and relating an. item of production (batch, lot, component,.part) at any stage, from initial receipt through fabrication, installation, repair or modification, to an- ,

applicable drawing, specification, Engineering o '

Work Letter, installation procedure, inspection and testing instruction, purchase order, or other pertinent technical-documents.-

- Physical identification shall be used to the

! - maximum extent practicable. Where physical i identification is-either impractical-or i

insufficient, physical separation, procedural control, or other appropriate means shall be-employed. Identification may.be either on the item or on records traceable to the item, as ' i appropriate.

p I 17.2.8.2 Where identification marking is employed, the-

, marking shall be-clear, unambiguous and d indelible, and shall-be applied in such a manner as not-to affect'the fit function, or quality of the' item. Markings shall be f

transferred to each part of an item when-subdivided and shall not be obliterated or hidden by surface treatment or coatings unless other means of identification are substituted.

When codes, standards, or specifications require traceability of materials, parts or  ;

components to specific inspection or test l records, the procedures shall be designed to provide such traceability. ,

17.2.8.3 Measures shall be established to identify and control materials (including consumables),

parts, or components in accordance with 17.2-53 Rev. 7

~

L

, Ec1 l -1 written procedures and instructions and:shall .

apply to-the fabrication, storage (including.

shelf-life), and installation or use of the ,

materials (including consumables), parts, or -

components.

.. ~ ,

17.2.8.3;1',

Consumables, as addressed above, include, but are not limited to, weld filler material,.

lubricants, chemicals, reagents, and fuels-that impact on safety-related equipment.

'17.2.8.3.2 Procedures for installation and inspection ,

shall require that the correct identification of materials, parts, and components is verified and documented prior to release'for fabrication, assembling, or installation.

-17.2.8.4 The identification and control of materials, parts or components associated with design change activities shall be delineated in Administrative Procedures and shall cover sddh items as traceability to specifications, purchase orders, quality assurance documentation, fabrication and installation inspection and. functional verification-tests

, prior to use or placement in operation.

17.2.9 Control of Special Processes 17.2.9.1 Measures shall be established and documented to assure that special processes, such as welding, heat treating, coatings, chemical.

cleaning, and nondestructive examination, are accomplished under controlled conditions in accordance with applicable codes, standards, specifications, criteria and other special requirements, using qualified personnel, equipment, and procedures. Qualification of personnel, procedures, and equipment shall comply with the requirements of applicable

- codes and standards. Documentation shall be 17.2-54 Rev. 7

.+ ,

,s yf!

, tL

j .

lQ f ~ '

't maintained'for currently qualified personnel,

-processes,-or equipment in accordance with the requirements of pertinent codes and standards.

For special processes not covered by existing codes or standards, or where item quality '

requirements exceed-the requirements-of-established codes or standards, the necessary qualifications ~of personnel, procedures, or equipment shall be defined, '

17 . 2 . 9 .1. l~ 'Special processes are those that require interim inprocess control in addition to final, inspection to assure quality.

- 17.2.9.2 Procurement documents shall specify the requirements imposed on the vendor and subcontracted services for the control of special processes. Included shall be requirements for qualification of procedures, equipment, and personnel. Such special

. processes shall be performed oy qualified personnel in accordance with approved procedures. -Records of qualification of procedures, equipment, and personnel shall be established and filed by the vendor and, as required by the procurement documents, shall be submitted to PECo.

17.2.9.3 The Nuclear Group and Engineering and Production are responsible for development of special processes performed under the QA Plan.

These processes and the personnel implementing them shall be qualified.

17.2.9.4 Drawings, specifications, or installation procedures (as appropriate for the activity) shall define the specific requirements for special processes performed by PEco during installation.

L 17.2-55 Rev. 7 k

~~

C s in ,

r,c . . l 17.2.9.4.1- The-qualification of-PECo welding procedures and personnel.is the responsibility of the ,

l_ Nuclear Training Division in conjunction with' Nuclear Maintenance Division. Such '

qualification shall be in accordance with the codes,. standards,'or special provisions.

applicable to-the work being performed. ,

Certification of welders performing. activities

' under, the QA Plan shall be kept: current through records of qualifying tests, recording of welds on current. work, retraining and qualifying for specialty work in accordance ,

with Administrative Procedures and Section XI '

g' e of the ASME B&PV Code.

17.2.9.5- Review and approvalaof special process procedures shall be accomplished in accordance with Administrative Procedures.

1 mt\4 17.2.9.6 . The nondestructive examination procedures for j the ISI/IST Inspection Program shall be written in accordance with applicable codes,"

standards, and specifications, h .17 . 2 .,9 . 6 .1 NDE procedures shall require that personnel b performing these examinations be qualified in I accordance with the recommendations of the American. Society for Nondestructive Testing Practice No. ASNT-TC-1A, " Recommended Practice for Nondestructive Testing Personnel Qualification and Certification." ,

.17.2.9.7 The qualification and certification of PECo

] nondestructive testing (NDT) personnel and procedures are the' responsibility of' Nuclear

, Maintenance Division. Qualification and certification of NDT personnel shall be accomplished in accordance with established l

Nuclear Maintenance Procedures which follow the guidance of ASNT-TC-1A. The qualification of procedures shall be in accordance with the ASME Code,Section V.

17.2-56 Rev. 7

.. .a  ?

A; -

l

~F l'.2.9.8 7 Records of qualification of' procedures, equipment,-and~ personnel associated with

'special processes shall be established, filed, ,

and kept current. Results of special  !

processes performed shall be documented, in-  ;

accordance with approved instructions and L procedures.

17.2.9.9 The NQA auditing, quality control, and l technical monitoring. programs provide assurance that the qualification of special processes, the equipment used, and the qualifications of personnel are satisfactorily performed.

17.2.10 Inspection 17.2.10.1 A program for inspection of activities affecting quality shall be-established-and executed by the organization performing the activity to verify conformance to the documented instructions, procedures,.and drawings'for accomplishing the activity.

Inspection activities to verify the quality of work shall be performed by. persons other than  :

those who performed the activity being inspected. Such persons shall-not report directly to the immediate supervisors who are responsible for the work being inspected.

17.2.10.2 Inspection requirements for purchased materials, parts, and components and.for installation activities shall be established to verify conformance of quality affecting activities with established requirements. The inspection requirements and inspection results shall.be documented.

t 17.2.10.3 The inspections to be performed shall be defined in drawings, specifications, Engineering Work Letters, or 17.2-57 Rev. 7

W . .

e. ; . . ..

inspection / installation procedures, as

. appropriate for the activity, The inspections shall be performed in accordance with written

~

l~ procedures or instructions. -The results shall

,.. be documented, evaluated, and their P acceptability determined by qualified t

individuals. Evaluation ~beyond that given-in

.. inspection-level personnel shall not norma 11y'  :

be required for go/no-go and pass / fail type inspections.

17.2.10.3.1- The inspection procedures _or instruction shall

a. Identify the characteristics and 1 activities to be inspected, including-  !

establishment of inspection hold points I where appropriate.

b. Identify the individuals or groups responsible for performing the inspection operation.

l

c. Define the acceptance / rejection criteria.

d.- Provide instructions for performing the inspection, including the inspection j

j. methods, a description of the necessary .!

j measuring and test equipment and the ,

, appropriate accuracy requirements.

e. Require recording evidence of l completing / verifying the activity and the l results. l 4

f. Require identification of the 1

' inspector / data recorder and recording the l' results of the inspection.

Ii I ci g. Be reviewed by qualified personnel l knowledgeable in NQA disciplines to ensure inclusion of items listed above.

l 17.2.10.4 The inspection program for modifications and nonroutine maintenance work shall be l accomplished by qualified NQA personnel who l 17.2-58 Rev. 7

.e are independent of the group.or individual performing the work.~

, -l.17.2.10'.'4.1 ' Examinations, measurements, or tests;of items ,

shall be performed for each work operation l s.. ,

where.necessary'to assure. quality..

17.2.10.4.2 Modifications for which. Nuclear Engineering is

'l responsible shall be inspected in accordance with Nuclear Engineering Department approved requirements.

17.2.10.5 Inspection personnel are responsible.for assuring that the necessary instructions, drawings, or other documents related to the inspection are current and used.  ;

l

17. 2.10.6 'Where direct inspection can not be used to-

.i L

verify satisfactory completion of quality i affecting activities, indirect methods (such ,

o as monitoring process methods, equipment, and -j personnel) may be used.- When necessary, both.  !

direct and indirect inspection will be '

l

, specified.

p l

f 17.2.10.7 If mandatory inspection hold points,.which require witnessing or inspecting and beyond '

which work shall not proceed are required, the specific hold points shall be indicated in-appropriate procedures. Such inspections L shall be documented prior to the continuation of work beyond the designated hold point. i The procedures shall include the characteristics to be inspected, a description of the method of inspection, acceptance / rejection criteria, a description L of necessary measuring and test equipment (including appropriate accuracy requirements) and the identification of the individual or

- group responsible for inspection.

17.2-59 Rev. 7

n. v - -

s p 4' i  : E

~ Satisfactory completion of inspection points 0

shall'be~ documented and chall be included in

-the documentation associated with the -

performance of the work.

Verification of equipment operability following maintenance and modification work

. . . .. shall.be accomplished, along~with inspection '

of the work area for safety, housekeeping, cleanliness, and health physics practices.

17.2.10.8 Appropriate NOA Department management have ,

sufficient authority to stop wcrk. Such authority is defined in administrative ,

procedures.

17.2.'10.9 Personnel performing quality control inspections shall be qualified in'accordance with applicable industry-standards and company a training programs. Certification of: inspector qualifications shall be maintained in accordance with procedures. ,

17.2.10.9.1 The code authorized inspector shall assure i

'that'the ASME B&PV Code-inspections are

, performed in accordance-with written-approved j procedures and accomplished by qualified personnel in accordance with ASME Code requirements.

l 17.2.10.10 A program for the required ISI/IST inspection of completed systems, structures and compcnents shall be planned and executed by or for the organization responsible for operation

[

of the plant.

l u

I-17.2.10.11 Job performance of each inspector is l periodically evaluated to assure that the l inspector is performing in accordance with the L qualification specified for the job.

Qualification requirements for nondestructive l

17.2-60 i Rev. 7 l

i,

y a: '

G 2 el testing personnel are described in Section 17.2.9.

'l 17.2.10.12 NQA shall perform surveillance of selected quality related " work-in-progress" activities

. commensurate with the importance of such

, activities to verify that certain aspects of the Quality Assurance Program are performed adequately and in compliance with program and procedural requirements.

Procedures shall be selectively reviewed, as appropriate, in the course of activities performed during NQA audits, technical monitorings, and inspections to assure that necessary inspection points are included and that a mechanism is provided for the documentation of inspection results.

1 17.2.10.12.1 If individuals performing inspections are not I part of the NQA organization, the NQA Department will assure through the audit, quality controle and nionitoring programs tha1 the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are acceptable.

o 17.2.11 Test Control, 1

17.2.11.1 A test program shall be established to ensure that all testing required to demonstrate that an item will perform satisfactorily in service ,

is identified and documented. This testing shall be performed in accordance with written ,

test procedures, drawings, specifications, or installation procedures which incorporate or l

reference the requirements and acceptance limits contained in applicable Technical Specifications and design documents.

l j

17.2-61 Rev. 7

(

l '

l

1 The program for the control of testing shall i be established in accordance with  !

Administrative Procedures. I i

17.2.11.2 The test program shall cover all required i' tests, including, as appropriate, qualifications tests, post-maintenance or  ;

modification tests, and operational  :

l surveillance tests to verify continued l satisfactory performance during operation. )

Where appropriate, vendor documents and instructions shall be used as input for determining required tests.

I 17.2.11.3 When such testing is required, approved test procedures shall incorporate or reference

a. The requirements and acceptance limits contained in applicable design and procurement documents.

b. Instruction steps for performing the -*

l test.

c. Applicable test prerequisites such as:

1. Use of calibrated instrumentation.

t

2. Adequate and appropriate equipment.

3. Identification of responsibilities to perform the test, including any special personnel qualification .

requirements.

4. Completeness and preparation of the item to be tested.

l S. Sultable and controlled l environmental conditions.

6. Provisions for data collection, review, and disposition. -

d. Necessary monitoring including mandatory I

inspection hold points.

l l 17.2-62 Rev. 7 i

o .

e. Acceptance / rejection criteria. l

f. Methods of documenting or recording test data and results, t

g. Requirements related to evaluation and l acceptance of test data.

.. ~

,. Evaluation beyond.that given by testing ,

personnel is not normally required for go/no- '

go and pass / fail type tests.

17.2.11.4 Measures shall be established such that when ,

an activity involves breaching a pressure-  !

retaining item, the quality of the work can be  ;

demonstrated through a functional test. The ,

functional test shall be performed by-individuals other than those who petformed or directly supervised the work, but can be from '

within the same group.

17.2.11.5 Test results shall be documented and their -

evaluation and acceptability determined as i defined in the test procedure or in the procurement documents. ,

Unsatisfactorily test results shall be

( , documented as required by procedures and j corrective action shall be taken in accordance with Administrative Procedures.

17.2.11.6 Modifications, repairs, and replacements shall be tested in accordance with the original design and testing requirements or to approved alternatives.

17.2.11.7 The Technical Specifications establish the requirements for the safe operation of the plant, including provisions for periodic and nonperiodic tests and inspections of various l structures, systems, and components. Periodic L tests are those tests delineated in the surveillance testing activity and nonperiodic 17.2-63 Rev. 7

1 tests are those proof tests performed following modifications or major maintenance.

17.2.11.8 Overall control of tests affecting plant -

operations shall be accomplished by Shift  ;

l .. .. Operations personnel to assure that testing of *

. components, systems, and instruments does not adversely affect the safe operation of the  !

plant.

17.2.31.9 In addition to the above testing-program, an ,

ISI/IST Inspection Program has been developed l

and shall be implemented to assure that plant  !

components perform satisfactorily in service.

The program shall include baseline examinations and periodic examinations in accordance with Technical Specifications.

i 17.2.12 Control of Measurj,,nq and Test Equipment [

17.2.12.1 Measures shall be established and documented l l to assure that tools, gages, instruments, and other inspection, measuring, and testing

, equipment and devices used in activities l affecting quality are of the proper range, type, and accuracy to verify conformance to l established requirements. To assure accuracy, inspection, measuring, and test equipment shall be controlled, calibrated, adjusted, and .

maintained at prescribed intervals or prior to l l use against certified equipment having known l valid relationships to nationally recognized standards. If no national standards exist, the basis for calibration shall be documented.

This requirement is not intended to imply a ,

l need for special calibration and control measures on rulars, tape measures, levels, and such other devices, if normal commercial

, practices provide adequate accuracy.

1 Q

17.2-64 Rev. 7

I I e .

5 17.2.12.2' .The method and interval of calibration for ,

each item shall be defined and shall be based  !

on the type of equipment, stability  !

characteristics, required accuracy, and other conditions affecting measurement control. .

Special calibration shall be performed when accuracy of the equipment is suspect. When ,

. inspection, measuring, and test equipment are found to be out of calibration, a documented evaluation shall be made of the validity of r previous tnspection or test results and of the acceptability of items previously inspected or r tested. If any inspection, measuring, or test i equipment is consistently found to be out of calibration, it shall be repaired or replaced.

17.2.12.3 Reference standards used for calibrating L measuring and test equipment should have an accuracy level, acceptable calibration rangea, .

and precision that are better than those' required of the measuring and test equipment.

i When this is not possible, reference standards with the same accuracy may be used if they can be shown to be adequato fet the requirements i and if the basis of acceptance is documented ~  !

and authorized by responsible management.

The accuracies of measuring and test equipment and the reference standards shall be chosen ,

t , such that the equipment being calibrated can be calibrated and maintained within the'  ;

required tolerances.

I Records shall be maintained and equipment l suitably marked, or otherwise controlled, to l indicate calibration status. Such records shall be traceable and retrievable.

Calibration of measuring and test equipment should be against reference standards that L have an accuracy of at least four times the required accuracy of the equipment or, when this is not possible, has an accuracy that l assures the equipment being calibrated will be within required tolerance and that the basis of acceptance is documented and authorized by responsible management.

17.2-65 Rev. 7

h ,o i-17.2.12.4 The Testing and Laboratories Division is

, responsible for the calibration program _and performs a calibration service to the Operations, Maintenance, Construction, and Engineering organizations at LGS.

17.2.13 .

Handling,-Storage and Shipping 17.2.13.1 Measures shall be established, documented, and implemented to control handling, storage, and shipping, including cleaning, packaging, and preservation of material and equipment in accordance with established instructions, procedures, or drawings to prevent damage, deterioration, and loss before and aftet receipt. When necessary-for particular items, any special coverings, special equipment, or special protective er.vironments, such as inert gas atmosphere, specific moisture content levels, and temperature levels, shall be specified and provided, and their existence shall be verified. _

17.2.13.2 As required by the procurement documents, vendor procedures shall provide control over

, cleaning, preservation, packaging, and l shipping to assure that items are delivered in acceptable condition.

17.2.13.2.1 Storage requirements shall be defined by cognizant personnel unless special instructions are provided by the vendor and approved by appropriate cognizant personnel.

17.2.13.2.2 Special handling tools important to nuclear safety shall be inspected and tested in accordance with written procedures and at specified times, to verify that the tools and equipment are adequately maintained.

17.2-66 Rev. 7

I

.; .-

17.2.13.2.3 Packaging requirements shall Le delineated, as j necessary, to avoid deleterious effect of  ;

shock, vibration, physical damage and j protection against environments. i

)

17.2.13.2.4 '

.. Shipping requirements shall be delineated, as

. necessary, to provide adequate protection ]

during loading and transit.. Labeling requirements are to be applied in a manner l 1

that is clearly visible and remain legible to specify special controls or handling i instructions.  :

17.2.14 Inspectio h _Te_s_t uand_ Operating Status 17.7.14.1 Measures shall be established and documented to identify inspection, test, and operation status. Such measures shall provide means for l assuring that r2 quired inspections and tests i- ere performed and that the acceptability of ~'

items with regard to inspections and tests performed is known throughout procurement, installation, and operation to preclude inadvertent bypassing or altering the sequence of such inspections and tests.

17.2.14.2- Bypassing of, or deviation from, required inspections, tests, or operations defined in drawings and installation or testing L procedures shall be controlled by procedures.

I '

l In general, such actions shall be subject to l the same controls as the original review and approval unless other provisions are specified.

17.2.14.3 Nonconforming items shall be clearly >

identified to prevent inadvertent use.

17.2-67 Rev. 7

l 17.2.14.4 A receipt inspection program shall be ,

p documented and the physical segregation of

• F items which have not satisfactorily completed i receipt inspection shall be employed to assure j that the status of items can be determined. '

Items which are found deficient during receipt inspection shall be " hold tagged" until the i

- . deficiency is resolved, t 17.2.14.5 During installation and testing, status shall  ;

be determinable through use of the  ;

instructions for installation, installation inspection records, and test procedures / records, i 17.2.14.6 The inspection and test status of items shall be maintained through the use of status indicators such as physical location, tags, markings, shop travelers, stamps, or inspection records. The measures shall l provide for assuring that only items that have passed the required inspections and tests are-used, installed, or operated.

17.2.14.7 Measures shall also provide for indicating the

, operating status of systems and components of the nuclear power plant, such as by tagging valvec and switches, to prevent inadvertent operation.

L 17.2.14.8 The operating status of components under test or inspection shall be indicated and controlled through the use of the handbook for permits and blocking, procedure checklists, or logs to prevent inadvertent use.

I i

(-

l 17.2.14.9 The application and removal of inspection and l

status indicators, such as tags, markings,

! labels, and stamps, shall be controlled by procedures for these activities.

l l

17.2-68 Rev. 7 l

, t 17.2.14.10- Defective material, parts or. components shall Ebe promptly identified, tagged and recorded or ^

otherwise controlled to indicate operating status of such equipment and to prevent its ,

inadvertent use.

l t

-- ..  ;

17.2.14.11 Implementation of these measures shall be verified through the NQA auditing, quality control, and technical monitoring Programs conducted in accordance with the QA Plan.

l These activities shall assure that the +

required inspections and tests are procedurally controlled as required by the QA ,

Plan.

17.2.15 Nonconforming Materials, Parts, or Components 17.2.15.1 Measures shall be established and implemented to control materials, parts, or components ,

which do not conform to requirements to prevent their inadvertent use or installatidh.

The measures established shall include, as appropriate, administrative and/or implementing procedures for the following functions for nonconforming materials, parts, '

, or components.

a. Identification. As a guideline, control of nonconforming items by tagging, marking, or other means of identification is acceptable where physical segregation is not practical, although physical segregation and marking are preferred.

Segregation where necessary and possible; b.

otherwise, identification will serve this p function.

c. Describe the nonconforming condition (s).

1

d. Disposition covering:

1. A description of the disposition L .

17.2-69 l

Rev. 7

m-e v

2. Restoration to conforming status.

Repaired and reworked items shall be reinspected in accordance with applicable procedures, or L '-

.l 3. Define the repair method and associated _ inspection and test

.. . requirements for " repair" dispositions.

4. Replacement with conforming material, or p~ 5. Acceptance for interim use.until replaced. Such measures shall l- provide assurance that the item is identified as nonconforming and controlled. The measures shall L require documentation verifying the acceptability of nonconforming items which have the disposition of

" repair" or "use-as-is." A description of the change, waiver, or deviation that has been accepted shall be documented to record the change and denote the as-built --

i condition.

6. Provide the engineering rationale / justification and independent review for "use-as-is"

, or " repair" dispositions.

7. Signature approvals and dates.

e. Notification to station management and other responsible organizations of equipment malfunctions or deviations.

The notification system shall include provisions for initial and follow-up information until the item is finally dispositioned.

f. The responsibility and the authority for the disposition of nonconforming items shall be defined for each responsible organization.

g. Documentation of each item from first identification to final disposition.

l l

17.2-70 Rev. 7 L

i l

9

n. .

e

h. Be included or referenced in the records package for the affected item. )

17.2.15.2 Nonconforming items identified by PECo during source surveillances/ audits shall be reported

. as described in Section 17.2.18.

17.2.15.2.1 Nonconforming materials, parte, or components  :

l shall be reported to station management in accordance with applicable procedures.

17.2.15.2.2 Nonconforming items identified during receipt l inspection shall be " hold tagged" and reported in accordance with written ptocedures.

Nuclear Engineering or the Procurement Engineering Group, which is part of the .

Materials Management Section, is responsible ,

for providing/ approving the disposition.

17.2.15.2.3 NOA approval is required on all proposed dispositions.

f 17.2.15.3 Procurement documents shall require that

, vendors report nonconformances with proposed dispositions of "use-as-is" or '" repair" to PECo for approval. The nonconformance report, e showing Nuclear Engineering or Procurement ,

Engineering Group and NQA approval shall be

included in the records package for the item.

l This shall apply to deviations from I

procurement document requirements and from ,

l vendor drawings and procedures which have been l approved by PECo.

l 17.2.15.3.1 Vendor corrective action shall be evaluated and approved by Nuclear Engineering (for "use-as-is" and " repair" dispositions involving l technical requirements) and by NOA. For "use-as-is" and " repair" dispositions which affect particular hardware, a copy of the 17.2-71 Rev. 7

.o .

dispositioned report shall be included in the record package for the affected item.

17.2.15.4 Nonconforming items identified during installation activities and post-installation

~

. testing activities shall be identified and

. reported in accordance with administrative procedures. A copy of the dispositioned report shall be included in the records package for the affected item.

17.2.15.5 Procedures shall provide for analyzing nonconformances for trends, for performing a periodic review and assessment of the trending data, and for reporting the results of such reviews to the appropriate level of management.

17.2.15.6 It is PECo's pollry and intent that nonconforming mater 131s, parts, or components' not be installed in LG3. Where technical adequacy is demonstrated to PECo's satisfaction, use of some nonconforming materials, parts, or components may be permitted. When this is done, a complete

. record shall be available throughout the life of the material, part, or component. In no case will use of nonconforming materials, parts, or components be permitted if a hazard to the health and safety of the public could result from their use. Administrative Procedures shall delineate acceptance and approval mechanisms for permitting use of nonconforming materials, parts, or components.

17.2.15.7 Where rework of a nonconforming item invalidates a previously completed test or inspection, the test or inspection shall be reperformed unless the approved disposition specifies otherwise. The testing and inspection of a repair shall be as given in the approved disposition of the nonconforming item.

17.2-72 Rev. 7

1 17.2.15.8 PECo shall report abnormal occurrences and

- unusual events to the USNRC as required by NRC Regulations and LGS Technical Specifications.  ;

j 17.2.16 Corrective Action  !

, i 1

l 17.2.16.1 Measures shall be established to assure that conditions adverse to quality are promptly  !

identified and corrected. Conditions adverse i to quality are failures, malfuncticns, deficiencies, deviations, defective material and equipment, and nonconformance to specified ,

requiremente. The measures established shall include the foll9 wing:

a, In cases of significant conditions adverse to quality, the cause of the condition shall be determined and documented, and corrective action taken and documtnted to preclude recurrence. ,

] b. Reports to PORC, NRD, and appropriate ,

levels of management of the significant condition adverse to quality and documentation of such reports.

17.2.16.2 Administrative Procedures shall require that  :

modification and repair procedures include the reworking of components, systems or structures in accordance with original specificationo,- -

instruction manuals, instructions, prints, i codes and standards. Appropriate testing and  ;

inspection requirements shall be included to verify acceptability of the repairs or I modifications.

17,2.16.2.1 The above responsibilities are assigned to the LGS staff members responsible for the various activities.

17.2-73 Rev. 7

6 o

• I 17.2.16.3 Procedures shall be established to assure that  :

conditions adverse to quality are controlled. j These procedures shall include the following ,

a. Identify thoce individuals or groups who-I shall authorize the corrective action.

l .. _. b. Assure that the NQA organization that has  :

responsibility for:the job performs a l review of the planned corrective action.

l c. Document the cause, if it can be identified.

d. Identify and. document, if possible, the I l,-

root cause. ,

e. The appropriate staff engineer shall -

review the corrective action and equipment history to determine equipment performance trends, to identify '

repetitive failures and to adjust, if applicable, the preventive maintenance program.

i l 17.2.16.4 NQA may identify conditions which require corrective action. Such conditions shall be reported to responsible management for ,

corrective action in accordance with

, applicable procedures. -

17.2.16.4.1 Dependent upon factors, such as the nature of the deficiency, the cause, and the corrective action taken, NQA shall follow-up corrective action of deficiencies identified by NQA to determine the adequacy and effectiveness of such action. The follow-up reviews to verify proper implementation of reported corrective actions shall be documented.

17.2.16.4.2 Written procedures shall establish methods for

[ monitoring the prompt resolution and close-out for each of the mechanisms used to report l

l conditions adverse to quality.

l l

17.2-74 Rev. 7

w- V i

. i I

17.2.16.4.3 The status of conditions adverse to quality  !

identified by technical monitoring,  !

inspections, audits, or surveillances shall be. l reported to the Executive Vice President, j Nuclear; the responsible Vice-President; and  !

the appropriate supervision.  ;

. i 17.2.16'.5 ' Corrective action performed in response to an l item identified by NQA shall have the i documented concurrence of NQA for the adequacy I of the corrective action. l l

.l 17.2.16.6 Procedures shall require NQA review and concurrence with the adequacy of prescribed

]

l corrective action for nonconformance reporto.

NQA periodic audits of the NCR procedure i include verification of proper implementation l of corrective action. l l

17.2.17 Quality Assurance Records . . ,

17.2.17.1 Sufficient records shall be maintained in +

accordance with Administrative and

. Implementing Procedures to provide documentary ,

evidence that activities affecting quality are performed adequately and in compliance with the Quality Assurance Program. The requirements shall include required records, collection, filing, storing, and disposition including transmittal responsibilities and processing requirements. These requirements shall comply with the QA Plan and applicable codes, standards, specifications, or regulatory requirements and shall be specified in procurement documents, drawings, and procedures. The procedures to be employed to perform the required activities shall be planned and documented.

17.2.17.2 OA Records shall include results of reviews, inspections, tests, and material analysis; 17.2-75 Rev. 7

o

a. ..

operating logs; QA surveillances or audits; .

qualification of personnel, procedures, and i equipment; and other documentation such as r drawings, specifications, procurement .

documents, calibration procedures and reports, reportable occurrences, maintenance and ,

modification procedures, nonconformance and i corrective action reports, and other records required by technical specifications.

17.2.17.3 The significance of the event covered by a- -

record type and the contribution of the record ,

to the ability to reconstruct significant events shall be considered in establishing  :

retention periods.

Retention periods shall satisfy applicable statutory requirements. Some types of quality  ;

records with minimum retention periods are listed in LGS Technical Specifications. For records not listed in the Technical Specifications, the type most nearly '

describing the record in question should be followed with respect to its retention period. ,

17.2.17.4 Records retained by PECo shall ba' identifiable i and retrievable and storage requirements  !

shall be established for the maintenance, preservation, and protection of records from their completion through submittal into the Nuclear Records Management System. The records shall be stored in predetermined locations to prevent destruction of the records by fire, flooding, theft, and deterioration by environmental conditions as required by applicable standards, codes, and regulatory agencies.

17.2.17.5 Applicable design specifications, procurement documents, test procedures, operational precedures and other documents shall specify the quality records to be generated. The l procurement documents shall specify the

records to be provided to PECo, the time of L

submittal, and whether or not PECo approval is l-l l 17.2-76 Rev. 7 l

l

v

.e . .

I required. All of thir above records shall be l legible,-filled out to the extent required, and adequately identifiable to the item or activity involved. ,

17.2.17.6 - . When records are retained by vendors, the  !

storage, maintenance, preservation, and

~

l protection requirements shall be.specified in

> the procurement documents and the vendor shall

• be required to provide PECo~with an index of the records not provided with the item.

17.2.17.7 The applicable quality records shall be  ;

considered valid only if stamped, initialed, signed, or otherwise authenticated and dated- .

by authorized personnel. These records may be I,

either the original or a reproduced copy and nhall be submitted to tne LGS Document '

^. Administration Center for inclusion in the Nuclear Records Management System. ,

1~/.2.17.0 Inspection and test records shall contain the  ;

following where applicables

a. A description of the type of observation, .

. . including procedure used and revision level. ,

b. Evidence of completing the operation.

c. Date and results.

1

d. Information related to conditions adverse ,

to quality,

e. Inspector or data recorder identification,

f. Evidence as to the acceptability of the results.

1 17.2-77 Rev. 7 i

%J  !

p l 17.2.17.9 NOA and other organizations responsible for

record control are defined in the Administrative and Implementing Procedures.

i i' 17.2.18 Audits I

.- t 17.2.18.1 Compliance with the requirements and guidance >

x for estsblishing and implementing the Quality Assurance Program.is assured through the NQA

auditing program for PECo nuclear organizations and vendors. j i

l'17.2.18.2 ~The NQA auditing program shall consist oft l

a. Audits - Documented-activities performed  ;

in accordance with ANSI N45.2.12 as described in Appendix 17.2.II.

b. Surveillances - Documented activities ' '

identical to Audits except that no formal audit plan and audit checklist are generated and no exit interview is >

conducted if no noncompliances are ,

identified. Surveillances are normally ,

initiated on short notice based on plant

, conditions and may include observation of work in process.

L ,

l 17.2.18.'3 .The aspects covered by the auditing program L include designing, purchasing, fabricating, .

I handling, shipping, storing, cleaning, erecting,-installing, inspecting, testing, I

modifying, and maintaining LGS Q-Listed structures, systems, and components. In addition, Audits may be performed on non-Q activities that will enhance operational safety as determined by appropriate management.

l Any procedures, instructions, drawings, '

procurement documents (for vendors),

activities, work-in-progresa, processes, hardware documents or records that are related 17.2-78 Rev. 7 P

e -- ---

c s- .

b to the items above are subject to objective audit evaluation for compliance with the PECo L QA Program.

l'17.2.18.4 NQA is responsible for the planning,

.. . performance, reporting, and follow-up of the

, auditing program for the various aspects of

! the QA Plan to determine compliance with the elements and effectiveness of the QA Plan.

17.2.18.5 Audits and Surveillances shall be performed in l accordance with written procedures by NQA personnel, who are independent of any direct responsibilities for the performance of j activities which they will audit. NQA may request the assistance of personnel from other disciplines or technical specialist who are independent of areas being audited.

l The General Managet, NOA, shall establish the auditing program personnel qualifications and the reauirements for the use of technical

?~ specialists to accomplish the auditir.g of tnh Quality Assurance Program. Personnel shall be selected for quality assurance auditing assignments based on experience or training which establish that their qualifications are

, commensurate with tne complexity or special nature of the activities to be audited. In selecting personnel for auditing assignments, consideration shall be given to special abilities, specialized technical training, prior pertinent experience, personal characteristics, and education.

17.2.18.6 Audits shall be regularly scheduled on the basis of the status and safety importance of L the activities. The following activities of the Quality Assurance Program are described in the QA Plan and shall be audited at least every two years:

a. Training

- b. Health Physics l

+ 17.2-79 L Rev. 7 l

l 1

O c c I

c. Chemistry

d. Fuel /Invessel Material

e. Shift Operations

f. Surveillance Testing

.- g. Maintenance of Instruments

-l h. ISI/IST l i

l

1. Maintenance - Electrical and Mechanical  ;

j. Stores and Purchasing

k. Modifications 1 Radioactive Waste Material .

m. Plans - Includes Emergency Plan, Physical Security Plan, Fire Protection Plan, and Radiological Environmental Monitoring ,

• Program. The Emergency Plan and Physical Security Plan are audited annually.

n. Nuclear Enginecting Other areas that shall be subject to scheduled audits include preparation, review, approva), r and control of specifications, procurement documents, instructions, procedures, and drawings; receiving and installation inspections; and vendor activities.

Regularly scheduled audits may be supplemented by unannounced or unscheduled audits or surveillances as determined by NQA.

17.3.18.7 Audit and Surveillance procedures shall require that nonconformances which are identified be documented in sufficient detail to assure that required corrective action can be effectively carried out by the audited organization. Corrective action may be l recommended, as appropriate, by NOA. ,

l' l

17.2-80

Rev. 7

r+

17.2.18.8 Responsible management shall take the

necessary action to correct any identified deficiencies and to report the cause of the l deficiency and the corrective action to NQA.

Unless justified in writing as not appropriate, corrective action intended to prevent recurrence shall also be taken and reported.

i 17.2.18.9 When corrective action measures are indicated, follow-ups or re-audits of applicable areas l shall be conducted, to assure implementation and effectiveness of corrective actions.

L 17.2.18.10 The results of the auditing program shall be l documented by NQA and distributed to the appropriate levels of management including the management of the audited area.

Audit results shall be analyzed and a statement regarding the effectiveness of the QA Program in the areas audited shall be

--- included in the Audit Report. -

i

)

17.2.18.11 Audits performed under the cognizance of.the Nuclear Review Board are discussed in Section 13.4.

17.2.18.12 The auditing program shall be periodically l reviewed and revised as necessary to assure that coverage and schedule reflect current activities.

t The General Manager, NQA, is responsible to 17.2.18.13 identify overdue corrective action to the l appropriate responsible management.

l l

17.2-81 ,

Rev. 7 i

l

. o 1 QUALITY ASSURANCE FIGURES

~

Figure No. Jitle l

i 17.2.1 Executive Organization Chart, 1 Philadelphia Electric Company

'17.2 2 Organization Chart Nuclear Group, Philadelphia Electric Company 17.2-3 Organization Chart, Nuclear Services Philadelphia Electric Company 17.2-4 Organization Chart, Nuclear Quality Assurance, )

Philadelphia Electric Company

^

17.2-5 Organization Chart Nuclear Engineering Philadelphia Electric Company 17.2-6 Organizatior. Chart, Engineering ano Production l Philadelphia Electric Company 17.2-7 Organization Chart Finance Group,  !

(Delete,d) Philadelphia Electric Company 17.2-8 Organization Chart, Personnel and Industrial Relations, Philadelphia Electric Company 17.2-9 Organization Chart, Information Systems and General Services, Philadelphia Electric Company 17.2-10 Organization Chart, legal Philadelphia Electric Company

+

L 17.2-82 Rev. 7

/

4

• ..--. 4 - - - , - - .._.,e

INCLUDES ORGANIZATIONAL CHANGES COVERED BY BULLETINS NO. 2065. 2066. 2067 NO. 202 E. 47 CHAIRMAN OF THE BOARD eResiDenT AND CHIEF EXECUTIVE OFFICER

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. Appendix 17.2.II i

i PECo's Application of Industry Standards and USNRC  !

Regulatory Guides

~

Philadelph.ia Electric Company follows the ANSI Standards and USNRC Regulatory Guides as described below. Documents referenced in ANSI Standards are excluded unless they-are addressed separately.

Unless stated otherwise, PECo shall comply with the documents listed below during the operational phases of LGS. PECo shall comply with these documents for operational activities that are

. comparable in nature and extent to related design or constrpction activities as determined by the following as appropriate, LGS-Vice President, General Manager, NQA and Executive Vice President, Nuclear.

a. Regulatory Guide 1.28, March 1978, Quality Assurance Program Requirements (Design and Construction).

Endorses ANSI N45.2-1977.

PECo shall comply with Regulatory. Guide 1.28, March .

1978, and ANSI N45.2-1977 during the design and construction phases.

b. Regulatory Guide 1.30, August 1972, " Quality Assurance Requirements for the Installation, Inspection, and e Testing of Instrumentation and Electrical Equipment."

Endorses ANSI N45.2.4 - 1972.

PEco shall comply with Regulatory Guide 1.30, August 1972, and ANSI N45.2.4 - 1972, except for the following alternatives.

l 1. ANSI N45.2.4, Section 1.1, Scope - PECo's alternate f to classification of Class I and IE electric power, instrumentation, and control equipment is to apply the requirements of this standard to PECo "Q-

! listed" items. (Those instruments, equipment and systems that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.)

i

2. ANSI N45.2.4, Section 3, Preconstruction Verification - Subsection (3), requires the checking of records of protective measures maintained during storage for conformance to 17.2.II-l Rev. 7

en s 1

storage 4 requirements. ' ANSI N45.2.2 --1978, Section-6.4, Control of Items in-Storage,. requires inspections and examination during the storage period. The' responsibility within PECo for,these j l_ -inspections rests with Materials Management.

-Compliance with these requirements for checking of records is assured through the auditing.and quality- 1

.. control programs conducted by NQA Department personnel along with the monitoring of Materials Management activities by Materials Management

-Supervision.

3. ANSI N45.2.4, Section 7, Data Analysis and

, Evaluation - A program for. processing, reviewing, and analyzing electrical equipment and-instrumentation inspection and test data for acceptability is provided in the administrative procedures which govern the repair, maintenance, and testing of electrical equipment and instrumentation. Maintenance is controlled through l the use of a work request form that has provisions for cognizant personnel sign-off after completion. l of the work. Functional testing and calibration  ;

procedures include provisions for review, analysis j of data, and approval by signature of cognizant personnel. ,

c. Regulatory Guide 1.33, Revision 2, February 1978,

" Quality Assurance Program Requirements (Operations)."

Endorses ANSI N18.7 -~1976/ANS 3.2.

, PECo shall comply with Regulatory Guide 1.33, Revision 2, February 1978 and ANSI N18.7 - 1976/ANS 3.2 during 1 the operational phase except for the following  !

clarifications or alternates:

1. Regulatory Guide 1.33, Section C.4 and ANSI N18.7 -

.1976/ANS 3.2, Section 4.5, Audit Program - The  ;

audit program carried out by the Nuclear Quality Assurance Department shall be performed in such a manner that individual activities of the QA Plan are investigated within a period of two (2) years.

This investigation shall consist of either audits l

or surveillances. See Section 17.2.18.

1

. ", 2. Regulatory Guide 1.33, Section C.4.c and ANSI N18.7

- 1976/ANS 3.2, Section 4.5, Audit Program (second paragraph) - The word " performance" means the implementation of the training program, participation in the training program by l individuals, and the comparison of documented L

17.2.II-2 Rev. 7 l:

(

6 .,.- 1 individuals, and the comparison of documented' qualifications with established raquirements.

Activities and records associated with confidential employee performance reviews and subjective evaluation of personnel capabilities are  ;

specifically excluded from the audit program. 1 l

. 3. Regulatory Guide 1.33, Section C.5.c and ANSI N18.7

, - 1976/ANS 3.2, Section 5.2.4, Special Orders and.

'Section 5.2.4, Temporary' Procedures - The types of procedures described in these sections-are not expected to be used at LGS. Administrative j Procedures will specify mechanisms for temporary  ?

changes-to existing procedures.

4. ANSI N18.7 - 1976/ANS 3.2, Section 4.3, Independent Review Program - the description and activities of l the Nuclear Review Board will be as specified in the LGS Technical Specifications.

5. ANSI N18.7 - 1976/ANS 3.2, Section 4.3.2.2, Meeting Frequency - The " period'of initial operation" means "one year after fuel loading of Unit 1."

6. ANSI N18.7 - 1976/ANS 3.2, Section 4.4,. Review Activities of the Onsite Operating Organization ,

The word " verify" does not imply review or certification by supervisory personnel of every day-to-day operating activity; rather, the performance of reviews of documents and logs and monitoring activities by supervisory personnel in accordance with station procedures and practices is considered to meet this requirement.

7. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.1, Responsibilities and Authorities of Operating Personnel - Item (4) is changed to-read: "The responsibility to respond conservatively to instrument indications including the case in which the credibility of the indication is in doubt."

This statement permits the operator to compare Control Room instruments and infer instrument error without proving it such as by calibration checks.

8. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.2, Procedure Adherence - The term " supervisor in charge of the shift" means either the Shift Superintendent or Shift Supervisor.

9. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.6, Equipment Control (6th paragraph, last sentence) and Section 17.2.II-3 Rev. 7

.a .

~ . - - ... ,

. x 5.2.13.2~(4th~ paragraph) - In order to allow:for-

. action-other-than-obtaining-the original specified-  ;

' documentation. " disposition by proper authority" is-the criteria for use of' items which have=been-identified as nonconforming. .

10. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.6, Equipment Control- ,

'(a) ' Temporary modification (5th paragraph) - The need for independent verification of Temporary Modifications will be determined on an individual basis:considering the complexity and impact of the modification.

^

(b) (7th paragraph) requires " operating personnel" to place equipment in operation. Equipment-may be placed into operational status by personnel.not on the operating staff, such as instrument technicians.

11. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.7, Maintenance and Modifications - The. requirement concerning original design bases and requirements, material specifications, and inspection requirements is modified to permit approved .

alternate requirements which are subject to the '

design review process.

12. ANSI N18.7.- 1976/ANS 3.2, Section 5.2.7.1, Maintenance-Programs a

(a) Emergency maintenance to Q-listed equipment-(work which must proceed immediately to correct a degraded condition) may.be performed concurrent with procedure preparation and documentation of steps actually taken. Such maintenance may be performed with the authorization of designated personnel and subsequent procedure review by the PORC.

(b) The cause of repetitive malfunctions should be determined, it is not practical, and may not be possible, to determine the cause of every malfunction.

13. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.10, Housekeeping and Cleanliness Control (a) Control measures to prevent contamination with foreign materials will be specified in 17.2.II-4 Rev. 7

% c.; l Administrative' Procedures'and'will include, as appropriate, access control. ,

(b) Second Paragraph, first and second sentences are taken to meant "Where needed to prevent contamination . . . . "

14. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.11,

.. Corrective Action, AdministrativeJand implementing i

' procedures will delineate the responsibility.for the determination of which conditions adverse to quality are significant. Significant conditions-adverse to quality shall be reported to the-Plant Operations Review Committee and the Nuclear Review-

• Board."

15. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.12, Plants Records Management - Retention periods will satisfy' '

statutory requirements for the record. .The ,

significance of the event covered by the record and the contribution of the record to the ability to reconstruct significant events will be considered in establishing retention periods.

16. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13, Procurement and Material Contr.ol - Item (1) -

Administrative Procedures shall specify the means for' control of procurement of commercially."off the shelf" items. The Administrative Procedures.shall describe the receipt inspection, storage, and o handling prior to installation and operation. Off-l e -the-shelf (catalog) items are evaluated by qualified personnel for their intended use. The Administrative Procedure restricts the use of catalog items for only these evaluated applications. The purchase order shall require the

vendor to notify the requisitioning organization of a change in an item described in the catalog.

17. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13.1, Procurement and Document Control, (second sentence) l - QA Program requirements or alternate approved l- methods will be used to assure quality. Examples i of alternates for suppliers without GA Programs L include: material analysis, sample testing, in-L process inspection and monitoring, and design J review by PECo.

1

18. ANSI N18.7 - 1976/ANS 3.2, Section 5.2.15, Review, Approval and Control of Procedures - The frequency 17.2.II-5 Rev. 7

r; .

3 m . . .

- s a .

of review'of plant-procedures'is discussed in PSAR Section 13.5.

19. ANSILN18.7 - 1976/ANS 3.2, Section 5.2.17, Inspections The results of inspection are not always subject to a further evaluation. For example,Levaluation beyond that given by inspection

- level personnel is not normally required for

. g'o/no-go and pass / fail type inspections.

12 0 . ANSI N18.7 - 1976/ANS 3.2', Section 5.3, Preparation.

of Instructions and Procedures, (last sentence) -

-The clarification regarding emergency _ maintenance in-Item 12, above, applies.

s

21. -ANSI N18.7 - 1976/ANS 3.2, Section'5.3.10, Test and

. Inspection Procedures, (first paragraph) - The.

clarification regarding test result evaluations in Item 19, above applies.

22. ANSI N18.7 - 1976/ANS 3.2, Section 5.3.10,. Test and Inspection Procedure, (second paragraph, last i sentence) - These procedural aspects will be-l included when appropriate. For example, "as-found '

g condition" is not applicable to all test and L inspection procedures.- ,

d. Regulatory Guide 1.37, March 1973, " Quality Assurance Requirements for' Cleaning of Fluid Systems and L Associated Components of Water-Cooled Nuclear Power ~

Plants." ' Endorses ANSI N45.2.1 - 1973.

n Decontamination and cleanup of radioactively l contaminated systems and components are not included in.

y the scope of this response.

PECo shall comply with Regulatory Guide 1.37 - March 1973 and ANSI N45.2.1 - 1973 except for the following alternates:

1. ANSI'N45.2.1, Section 3.2, Water Quality Requirements - pH measurements are not required for conductivity values of less than or equal'to 1 michromho/cm. PECo utilized PH limits of 5.2 to 8.6 at 25 degrees centigrade, uncorrected for CO2 and may apply conductivity measurements in place of total dissolved solids.

2. ANSI N45.2.1, Section 3.1.2, Class B - The flushing velocity may be as specified in other approved 17.2.II-6 Rev. 7

m t.

1 documen'ts associated with'the maintenance or modification, as well as procurement documents.

e. Regulatory-Guide 1.38, Rev. 2, May 1977, " Quality-Assurance Requirements for Packaging, Shipping,. l Receiving, Storage, and Handling of Items for Water-  !

Cooled Nuclear Power Plants." Endorses > ANSI /ASME N45.2.2..- 1978.- 1 PSCo'shall comply with Regulatory Guide 1.38, Rev. 2, ,

May 1977, and ANSI /ASME N45.2.2 - 1978, except for the

• following clarifications or alternatives:

1. ANSI /ASME N45.2.2, Section'2.7, Classification of Items - Philadelphia Electric Company does not classify items into the four (4) levels' described '

in this standard., However, the specific guidance and recommendations which are appropriate to each

class are applied to those items packaged, shipped, received, stored, and handled through the use of

, procedures, original specifications, instructions, l

and drawings, as applicable.

2. ANSI /ASME N45.2.2, Section 3, Packaging and Section 4, Shipping - Philadelphia Electric Company utilizes the packaging and shipping requirements delineated in the original equipment specifications as part of our procurement requirements to suppliers or manufactures. Those requirements and recommendations of Sections 3 and 4 are included in the original specifications as appropriate for the

, item being procured. Receipt inspection activities are in'accordance with Section 5 of this standard and are sufficient to identify packaging and shipping nonconformities.

3. ANSI /ASME N45.2.2, Section 6, Storage -

Philadelphia Electric-Company does not classify items into four (4) levels for storage purposes, as delineated in Section 6.1.2. Stored items are placed in limited access controlled areas, and are segregated with respect to the Q-list classifica: ion-of the1 item (s). The specific guidance and recommendations which are appropriate to each class are applied to those items stored through the use of procedures, specifications and manufacturers recommendations and instructions.

4. ANSI /ASME N45.2.2, Section 6.4.2. (7), Care of Items - The rotating of certain electrical motors in storage, which must be energized to release an 17.2.II-7 Rev. 7

.V 'i ,

p , .-

+

electrical brake, will be stored and maintained'in I n

-accordance-with' manufacturers recommendations, i Other motors, which can be rotated without energizing, will be maintained in accordance with J

.the requirements of Section 6.4.2 (7) of the standard. ]

f. ~ Regulatory Guide 1.39, Revision 2, September 1977,

" Housekeeping Requirements for Water-Cooled Nuclear Power Plants." Endorses ANSI N45.2.3 - 1973.

PECo shall comply with Regulatory Guide 1.39, September 1977 and_ ANSI N45.2.3 - 1972 except for the following alternates:- r

1. ANSI N45.2.3, Section 2.1, Planning - Zone II requirements for clean gloves, shoe covers, and head coverings will be determined by health physics personnel under the radiation protection program and specific requirements listed on the Radiation Work Permit for entry in Zone II' areas.

2. ANSI N45.2.3, Section 2.1, Planning - Material accountability for Zones II and III shall be controlled by procedural requirements, periodic inspections and surveillance of areas for w ..

acceptable housekeeping practices. Implementing' procedures for activities such as maintenance and modifications require housekeeping and cleanliness inspections of areas and equipment to eliminate foreign materials that may have a' detrimental

, effect. Post Maintenance or modification inspections for housekeeping and cleanliness shall be conducted and documented in accordance with administrative controls.

3. ANSI N45.2.3, Section 2.1, Planning - Personnel L accountability for Zone III will be controlled as determined by the administrative controls for L

locked doors and radiation work permit requirements in lieu of specific access registers.

g. Regulatory Guide l.54, June 1973, Quality Assurance Requirements for Protection Coatings applied to Water-Cooled Nuclear Power Plants." Endorses ANSI N101.4 -

L 1972.

PECo shall comply with Regulatory Guide 1.54, June 1973, and ANSI N101.4 - 1972, for major modifications except for the following alternative.

=.

17.2.II-8 1

Rev. 7 L

1 l

l

t

v *  ;

1.- ANSI.N101'.4 1972,, Paragraphs-(5)'and (6) - a procedure (s) will be implemented prior to coating '

that will. ensure satisfactory application and inspection of coatings applied to Nuclear Facilities.

a h.. Regulatory Guide 1.58, Revision 1, "Gualifications of

-Nuclear Power Plant Inspection, Examination. and Testing

~

~P,ersonnel." Endorses ANSI /ASME N45.2.6 - 1978.

PECo shall comply with Regulatory Guide 1.58, Revision 1, and ANSI /ASME N45.2.6 - 1978, except for the '

following clarification and alternates.

1. Regulatory Guide 1.58, Revision 1, Section C.1, and-ANSI /ASME N45.2.6 - 1978, Subsection 1.2, states that the standard applies to " personnel who perform inspections, examinations, and tests."

Philadelphia Electric Company personne1'who inspect equipment as part of plant maintenance, in other than a quality control function; and plant staff personnel (as defined in the LGS Technical Specifications), who approve test procedures and test results and direct or supervise'the conduct of individual' tests, will be qualified in accordance with' ANSI /ANS 3.1 - 1978 in lieu of ANSI /ASME ,

N45.2.6. - 1978.

2. ANSI /ASME N45.2.6. - 1978, Subsection 3.5, presents experience recommendations'for candidates.

-Experience in maintenance, modification, and E , operating activities is considered related experience since such experience provides training in the safety aspects of the facility.

1. Regulatory Guide 1.64, Revision 2, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants." Endorses ANSI N45.2.ll - 1974.

j. PECo shall comply with Regulatory Guide 1.64, June 1976, L and ANSI N45.2.ll - 1974 except.for the following L

clarification and alternate: i Alternate -

1. Regulatory Guide 1.64, Section C.2, design verification can be performed by the designer's ,

immediate Supervisor under the following circumstances:

17.2.II-9 Rev. 7

%: L4

. e

a. -When the supervisor is the only technically

. qualified individual.

, b. -Theineed'is individually documented and approved in advance by.the supervisor's management.

c. . . . QA Audits cover' frequency and effectiveness of

,. use of supervisors as design verifiers to guard against abuse.

Clarification -

1 _

l.- Modifications are defined in appropriate  ;

administrative procedures.

o j. Regulatory Guide 1.74, Revision 0, February 1974, ,

" Quality Assurance Terms and Definitions." Endorses ANSI N45.2.10 - 1973.

PECo: shall comply with Regulatory ' Guide 1.74, Revision 0,-February.1974 and ANSI N45.2.10 - 1973, except for the following alternate:

The word " examination" also means an exercise to examine progress or: status of knowledge or qualification. .

-k. -Regulatory Guide 1.88, Rev. 2, October 1976,

" Collection, Storage, and Maintenance of Nuclear Power PlantiQuality Assurance Records." PECo shall comply-with ANSI /ASME N45.2.9 - 1979, except for the following

' alternatives:

1. ANSI /ASME N45.2.9, Section 3.2.6, Supplemental Information to Records - Supplements and corrections to records will be in accordance with 4 procedures, but will not necessarily require review or approval by the organization which originated the record.

2. ANSI /ASME N45.2.9, Section 5.3, Storage, Item 3. 7 This items implies the use of a transmittal document. Philadelphia Electric Company will '

utilize such documents as determined by the type of record being stored.

1. Regulatory Guide 1.94, Revision 1, April 1976, " Quality 7 Assurance Requirements for Installation, .Tnspection and Testing of Structural Concrete and Structure Steel During the Construction Phase of Nuclear Power Plants."

Endorses ANSI N45.2.5 - 1974.

17.2.II-10 Rev. 7 e

p n.

am 3;

P .: -

Nik >

["'

PECo: shall comply- to Regulatory ' Guide 1.94,. Revision.1, Aprilc1976,-and ANSI.N45.2.5 - 1974, except for the b -

following clarification::

p s i c l'. . ANSI N45.2.5 - 1974 will be implemented by PECo by initiating ~a procedure, prior to any work, that

-l will assure satisfactory installation, inspection, "2 '

a,nd-testing of structural concrete or structural.

,  ;. . steel.

E ,

m. fRegulatory Guide 1.ll6,JRev. 0-R, May 1977, " Quality Assurance Requirements for Installation, Inspection, and Testing'of Mechanical Equipment and Systems." Endorses ANSI?N45.2.8 - 1975, except for the following .

alternates:

l.- ANSI N45.2.8, Section 2.2, Procedures and Instructions - FSAR Section 13.5 addresses compliance with ANSI N18.7 - 1976/ANS 3.2 and Regulatory Guide 1.33. These requirements provide L adequate controls for the-Procedures and  ;

Instructions addressed in this Section.

2. ANSI N45.2.8, Section 2.3, Results - PECo's

! commitment to ANSI 18.7 - 1976/ANS 3.2:provides L adequate guidance for the documentation and revigy.

l of the results of inspections and tests, t

3. . ANSI N45.2.8, Section 3.4, Physical Condition -

l PECo's response to ANSI N45.2.1, N45.2.2, and L N45.2.13 provide adequate guidance and control for e the requirement that mechanical items are in L accordance.with specified requirements.and that the quality has been maintained, n.- Regulatory Guide 1.123, Revision 1,' July 1977, " Quality Assurance Requirements for Control of Procurement of Items'and Services for Nuclear Power Plants." Endorses

. ANSI N45.2.13 -'1976.

o. Regulatory Guide 1.143, Revision 1, October - 1979, j

Design Guidance for Radioactive Waste Management

! Systems, Structures, and Components installed in Light-Water-Cooled Nuclear Power Plants."

PECo shall comply with Regulatory Guide 1.143, Revision i

1, October 1979, for major modifications, subject to the exceptions and clarifications listed in Table 3.2-1, Note 18.

l 17.2.II-11 l

Rev. 7 t.

, , . ~ -

~

j 1

< E ja ,

.; .

l fp .y Regul'a tory Guide.l.144',fSeptember 1980, " Auditing of _ I Quality Assurance Programs-for Nuclear Power Plants."

Endorses ANSI /ASME N45.2.12 - 1977. ')

I PECo shall' comply-with Regulatory Guide 1.~144, September i

• 1980, and ANSI /ASME N45.2.12 - 1977, with the i cla'rification discussed in' Item-1, under Regulatory i Guide 1.33Eand with the following alternate:

l' ,' ANSI /ASME.N45.2.12, Section 4.2.4, Audit Notification, and Section 4.3.1, Pre-Audit Conference - Pre-audit notification is given to ,

, _ plant management in an informal manner due to daily-contact and communications between Nuclear Quality-Assurance Department personnel ~and plant personnel.-

- 2 .- Section 4.3.3, Post-Audit Conference - A post-audit conference will be held if unsatisfactory findings are identified during the audit.

3. ANSI /ASME N45.2.12, Section 4.4.6, Reporting - The auditireport shall-be issued within 30 working days after:the post-audit. conference.

q. Regulatory Guide 1.146, August 1980, " Qualification of

-Quality Assurance Program Audit Personnel for Nuclear , '

Power Plants." Endorses ANSI /ASME N45.2.23 - 1978, ,

, PECo shall comply with Regulatory Guide 1.146, August

? 1980, and ANSI /ASME N45.2.23 - 1978, except for

- following alternatives:

a-

1. . ANSI /ASME N45.2 1978, Subsection 2.3, states requirements for qualification of auditors, In lieu of the-stated requirements, PECo will qualify personnel in accordance with the requirements presented below. These alternate requirements will provide PECo with sufficient flexibility to qualify competent personnel with-initial technical experience in a more effective manner. The proration of credits between initial experience requirements and additional experience gained as an

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assistant to a Lead Auditor assures that highly qualified personnel will be available as audit L personnel in a more timely manner.

2. Substitute the following for Paragraph 2.3.1 of L ANSI /ASME N45.2.23 - 1978:

b L 2.3.1 Education and Experience - The prospective Lead Auditor shall have verifiable evidence that a minimum of u

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ten (10) credits under the following scoring system'have been accumulated.

2.3.1.1 Education'(four (4) credits maximum) - Associate degrees from an accredited institution score one (1) ,

creditLor-if the degree is an engineering, physical -

sciences, mathematics, or quality assurance, score two

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a' bachelor degree from an accredited institution score two (2)~ credits or if the degree is in engineering, ,

-physical sciences, mathematics, or quality assurance, ,

score three (3) credits; in addition, score one (1)-

credit-for a master degree in-engineering, physical sciences, business management, or quality assurance.from an accredited institution.

2.3.1.2 a) Initial Experience Prior to Assignment (six (6) credits-maximum) - Technical experience in

-engineering, manufacturing, construction, operation, maintenance, or-quality assurance related to the aforementioned activities, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience.

If two (2) or more years of this experience have been ,in the nuclear: field, score one (1) additional credit.

2.3.1.2 b) Additional' Experience (after assignment)

(four~(4) credits maximum) - Experience in quality assurance, score one-(1) credit for each full year (2

-, credits maximum) or, Experience in auditing, score two (2) credits for each full year -(3 credits maximum) or, Experience in nuclear quality assurance, score one (1) credit for each full year (three (3) credits maximum) or, Experience in nuclear quality assurance auditing, score one (1) credit per every six months (four (4) credits maximum).

2.3.1.3 Other Credentials of Professional Competence L (two (2) credits maximum) - Certification of competency in engineering, science or quality assurance specialties L issued and approved by a State Agency, or National L Professional or Technical Society, score two (2) credits.

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yh(i .., s L2.3.2.4 Rights of-Management-(two_(2) credits maximum)T-The' Lead Auditor's employer may. grant up to one (1)'

credit ~for other performance factors applicable to

' auditing which may not: be explicitly called out -in. this-standard,-such as leadership,' sound-judgement, maturity,

analytical'_ ability,ctenacity, and past performance, plus one:(1) credit'for satisfactory completion of Lead Auditor.. training program.

l- r. Branch Technical Position (BTP) CMEB 9.5-1 For modification work performed ~by the Nuclear.

Engineering Department during the operations phase,Lthe

. Nuclear Engineering Department'will maintain compliance with the requirements of CMEB 9.5-1 in accordance with-Section:9.5.1.

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l Ouestion 260,13-

- I Describe those' provisions which assure that the QA organization and the necessary technical organizations participate early in the QA Program definition stage to determine and identify the extent QA controls are to be applied to specific structures, systems.-and components. (SRP17.1,283)

Response

, Limerick is currently staffed with Nuclear Quality Assurance Personnel, including Lead Auditors, Quality Engineers and Inspectors. Corporate QA and technical personnel are available for support when needed by the QA and i technical site personnel.

The Quality Assurance Plan for the operations phase of Limerick Generating Station will describe how the QA and the necessary technical organizations are- '

involved and to-the extent the QA controls are to be applied to specific structures,. systems, and components.

h l Sections 17.2.2.8 and 17.2.2.9 provide additional information. .

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. Question 260.21

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. In addition to the' design controls specified in Section 17.2A and 17.28, l describe _those provisions which assure procedures are established requiring that j design drawings and specifications be reviewed by the QA organization to assure i that the documents are~ prepared, reviewed, and approved in accordance with '

company procedures and that the documents contain the necessary quality assurance requirements such as inspection and test requirements, acceptance ,

requirements, and the extent of documenting inspection and test results. (SRP 17.1,3E2)

Response

Sections 17.2.3.2, 17.2.3.3..and 17.2.'3.1 (f) provide the requested information.

The independency of the design review is defined in Section 17.2.3.6.1.

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i Question 260.26 t

p' Describe those provisions which assure that responsible plant personnel are made.

- aware of' design changes / modifications which may affect the performance of their

-duties.- (SRP 17.2.3. item 2)

Response-U . Procedures shall ensure that responsible plant personnel are made aware of design changes / modification which may affect the performance of their duties.

H l Sections 17.2.3.2, 17.2.3.3 and 13.2.2.1.3 provide additional information.

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, ,l v. 'h p -Question 260.30 y ,- ..

Describe those provisions which assure that procedures are established to

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l provide for the preparation of as-built drawings and related documentation in a

-timely manner to accurately reflect the actual plant design. (SRP 17.1, 6Cl)

Response

Administrative procedures have been written which require modifications be reviewed after completion of the work to determine if the "as-built" installation differs from the original design, and that drawings and documents are revised; if required, to reflect the actual installation in a timely manner according to procedures.

Sections 17.2.3.1, 17.2.3.2, 17.2.3.3.2, and 17.2.3.8(j)-provide additional l

information.

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= Question 260.31 Describe.in more detail the responsibilities of the QA organization for the

, control-of purchased material, equipment, and services, including interfaces between design, procurement, and QA organizations. (SRP 17.1, 7A1) j'

Response

NQA personnel shall review procurement documentation for modifications and operations procurement. The responsible Engineer shall determine source inspection. requirements.

Sections 17.2.1.2.4.1.3(1),17.2.1.2.4.4.2,17.2.'4.1,17.2.4.5,17.2.4.6, 17.2.4.7, 17.2.4.9.1, and 17.2.4.9.2 provide additional information.

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Question 260.39 Describe those provisions which assure that an effective inspection program has been established which provides criteria for determining the accuracy requirements of inspection equipment and criteria for determining when inspections are required. Describe the responsibilities of the QA/QC-

' organizations in the above functions. (SRP17.1,10A)

Response

Sections'17.2.1.2.4, 17.2.12.1, 17.2.12.2, 17.2.12.3 and 17.2.1.3.2.3.1.1 provide the requested information.

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-Question 260.40 '

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Identify >the o'rganization responsible for inspection and provide assurance that individuals performing inspections are other than those who performed or directly supervised the activity being inspected and do not report directly to the immediate supervisors who are responsible for the activity being inspected.

If the individuals performing inspections are not part of the QA/QC organization the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, should be reviewed and found acceptable by the QA organization prior to the initiation of the activity. (SRP 17.1, 1081)

Response

Sections 17.2.1.2.3.1.3, 17.2.1.2.4.1.2, 17.2.1.2.4.1.1, 17.2.10.1, 17.2.10.12.1, 17.2.10.3.1 and 17.2.10.4 provide additional information.

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1 Question 260.49 Describe those' provisions which assure that procedures are established to F control altering the sequence of required tests. Inspections, and other operations important to safety. Such actions-should be' subject to the same controls as.the original review and approval. (SRP 17.1. 14.3)

Response

Sections 17.2.14.2 provides the requested information. ,

" Deviation from" used in Section 17.2.14.2 means the same as " altering the sequence of ..."

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