ML18106A931

Submits Request to Change QA Program for Hope Creek & Salem Generating Stations,Per Section 17.2 of Respective Ufsars. Changes to Section 17.2 of Hope Creek & Salem Ufsars, Respectively & Description of Proposed Changes Encl

ML18106A931
Person / Time
Site:	Salem, Hope Creek
Issue date:	10/19/1998
From:	Mcmahon J Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N980154, NUDOCS 9810270286
Download: ML18106A931 (75)

Text

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OPS~G Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit OCT 1 9 1998 LR-N980154 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REQUEST FOR CHANGES TO THE QUALITY ASSURANCE PROGRAM HOPE CREEK AND SALEM GENERATING STATIONS FACILITY OPERATING LICENSES DPR-70, DPR-75, AND NPF-57 DOCKET NOS. 50-272, 50-311, AND 50-354 In accordance with 10CFR50.54(a)(3), Public Service Electric & Gas Company (PSE&G) is submitting for your approval, a request to change the Quality Assurance (QA) Program for the Hope Creek and Salem Generating Stations, as documented in Section 17.2 of the respective Updated Final Safety Analysis Reports (UFSARs).

I The proposed changes include removing the QA Department from in-line review of certain programs and processes, clarifying various QA responsibilities and requirements, relocating the guidelines for independent inspections from the UFSAR, eliminating the requirement for Engineering involvement in the disposition of certain nonconformances, and making the description of the corrective action program more consistent with the description in 10CFR, Appendix B, Criterion XVI. Attachment 1 contains a description of the proposed changes, the reasons for the proposed changes, and the bases for concluding that the revised QA Program continues to satisfy the criteria of 10CFRSO Appendix B. Attachments 2 and 3 contain the changes to Section 17.2 of the Hope Creek and Salem UFSARs, respectively. Changes made since the last UFSAR update are showo with the changes proposed in this submittal highlighted in bold font. Only those pages that have changed since the last UFSAR update are provided.

If you have any questions regarding this submittal, please contact Mr. C. Manges at (609) 339-3234.

Sincerely, 1.fo/'1

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------------- ---*. -*~ :_'-f".:_I::. ..J:. ---- . --- - - - -

~hon Director - QA/Training/Emerg. Prep

~~ 9810270286 981019 PDR ADOCK 05000272 P PD~

The power is in your hands.

95*2168 REV, 6/94

• • "" ' ' ~~ Document Control D .

LR-N980154 C

Mr. H. Miller, Administrator - Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. R. Ennis, Licensing Project Manager - HC U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. P. Milano, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Pindale (X24)

USN RC Senior Resident Inspector - HC Mr. S. Morris (X24)

USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering P. 0. Box 415 Trenton, NJ 08625

Document Control Desk LR-N980154 Attachment 1 HOPE CREEK GENERATION STATION AND SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES NPF-57, DPR-70, AND DPR-75 DOCKET NOS. 50-354, 50-272, AND 50-311 REQUEST FOR CHANGES TO THE QUALITY ASSURANCE PROGRAM DESCRIPTION OF PROPOSED CHANGES A. Elimination of In-Line Reviews by QA/Clarification of QA Responsibilities The proposed changes would shift QA involvement and responsibilities with respect to procedures and manuals, design changes, documents affecting nuclear safety, deficiency reports, action requests, and cable system assessments (Salem only) from in-line reviews to evaluation through periodic assessment and selected inspection activities.

This is similar to the change submitted by Public Service Electric & Gas Company (PSE&G) in NLR-N94156, dated September 27, 1994. The subject change allowed performing assessments of QA Program administrative and implementing procedures in lieu of in-line reviews. Approval of this request was received in a letter from the NRG dated March 16, 1995.

The proposed changes would also clarify various QA responsibilities and requirements.

A detailed discussion of the proposed changes to Section 17 .2 of the Hope Creek and Salem UFSARs is as follows:

Sections 17.2.1, 17.2.1.1.1, and 17.2.7 on Pages 17.2-2, 4, and 27 (HC) & Pages 17.2-2, 4, and 26 (Salem)

The change proposes to replace references to Quality Assurance/Quality Verification with references to Quality Assurance because Quality Verification is considered to be a sub-part of the Quality Assurance program. This is considered to be an editorial change.

Section 17.2.1.1.1 on Page 17.2-5 (HC) & Page 17.2-4a (Salem)

The change proposes to clarify Responsibility 2 under the Manager - Corrective Action, Emergency Preparedness, and Instructional Technology. The responsibility is rephrased to require overall management of the trending of corrective action reports related to human, organizational, and programmatic performance. Department managers are responsible for trending their individual departments and Engineering is responsible for equipment failure trending. This is considered to be an editorial change that more clearly states the intended requirement. The level of detail in Responsibility 3 is more than required and is considered to be part of the overall management responsibility covered by Responsibility 2. Responsibility 3 is therefore deleted. This change is also considered to be an editorial change.

Page 1of9

Document Control Desk LR-N980154 Section 17.2.1.1.1 on Page 17.2-6 (HC) & Page 17.2-5 and 17.2-6 (Salem)

Responsibility 6: The change proposes to clarify that surveillances are synonymous with functional area assessments by changing "surveillances" to "functional area surveillances/

assessments." The responsibilities of the Manager - Quality Assessment are clarified to include performing functional area surveillances/assessments. The surveillences/

assessments performed by the functional area engineers verify and ensure that the operational QA program requirements are covered. These are considered to be editorial changes.

Responsibilities 7 and 9: The change proposes to delete Responsibility 7 under the Manager - Quality Assessment and -to consolidate QA responsibilities with respect to procedure assessments for procedures other than Nuclear Administrative Procedures (NAPs) under Responsibility 9. The change proposes to modify Responsibility 9 to require review of selected procedures by periodic assessment and inspection thereby eliminating the requirement for in-line reviews of non-NAP procedures by QA. In-line review of NAPs would continue to be required as specified in Responsibility 8. The phrase in Responsibility 9 regarding station procedures is eliminated since station procedures are a subset of NBU procedures. Further details regarding procedure assessment requirements are contained in Sections 17.2.1.1.2.1, 17.2.2, 17.2.5 and 17.2.6.

Responsibility 12: The change proposes to clarify QA's responsibilities with respect to commitments. The responsibility is revised to specify verification of compliance with the procedures that implement the commitment management program by review of selected commitments rather than coordination of the commitment verification program. This is considered to be an editorial change that more clearly states the intended requirement.

Responsibility 13: The change proposes to clarify QA involvement and responsibilities with respect to Code-related inspections, tests, and reviews. The proposed change specifies inspection of selected Code related activities, observation/performance of selected testing, and review of selected weld procedures. This is considered to be an editorial change that more clearly states the intended requirement.

Responsibility 14: The change proposes shift QA involvement and responsibilities with respect to review of DCPs. The proposed change eliminates in-line QA reviews by requiring review of selected DCPs by periodic assessment and inspection.

Salem Responsibilities 17 and 19: The change proposes to delete Responsibility 19 under the Manager - Quality Assessment and to consolidate QA responsibilities with respect to cable system assessments under Responsibility 17. The proposed change eliminates in-line reviews by QA by requiring verification that selected cables have been installed, identified, and routed as specified per procedure through periodic assessment or inspection of selected cable systems.

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Document Control Desk LR-N980154 Attachment 1

• Section 17.2.2 on Page 17.2-12 and 17.2-13 (HC) & Page 17.2-11 and 17.2-12 (Salem)

The change proposes to add a sentence to state that the NRC shall be notified of changes made to the QA Program description as required by 10CFR50.54(a). The change also proposes to clarify that the discussion with respect to substantive and non-substantive changes refers to organizational changes. These changes make the UFSAR more consistent with the requirements of 10CFR50.54(a) and the descriptions in the standard review plan (NUREG-0800). Although Salem is not committed to NUREG-0800, the changes are considered appropriate for Salem. A change is also made to indicate that the UFSAR is updated periodically in accordance with 10CFR50.71 (e) rather than on an annual basis.

The change proposes to modify the procedural review requirements of this section to be consistent with the changes in Section 17.2.1.1.1 by eliminating in-line QA reviews of procedures other than NAPs.

The change proposes to clarify the requirements to indicate that QA assesses rather than analyzes problems affecting quality. This is considered to be an editorial change.

Section 17.2.3 on Page 17.2-21 (HC) & Page 17.2-20 (Salem)

The change proposes to shift QA involvement and responsibilities with respect to design changes from in-line involvement and review to verification of inclusion of QA requirements in selected design changes through periodic assessment and inspection.

Section 17.2.4 on Page 17.2-21 (HC) & Page 17.2-20 (Salem)

The change proposes to identify that review of procurement documents assures that services are procured using controls that are commensurate with QA program requirements. This is considered to be an editorial change.

Section 17.2.5 on Page 17.2-23 (HC) & Page 17.2-22 (Salem)

The change proposes to shift QA involvement and responsibilities with respect to documents affecting nuclear safety from in-line reviews for QA requirements to assessment of selected documents to ensure incorporation of quality requirements through periodic assessment and inspection.

The change also proposes to allow personnel matrixed to QA to perform assessments of documents affecting nuclear safety. Matrixed personnel are personnel who are qualified in accordance with the QA training program or other equivalent department training.

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Document Control Desk LR-N980154 Attachment 1

• Section 17.2.6 on Pages 17.2-24 and 25 (HC) & Pages 17.2-23 and 24 (Salem).

The change proposes to modify the responsibility of QA with-respect to review and approval of NBU second tier manuals, including station administrative procedures from an in-line review to assessment of selected manuals and procedures. In addition, the change proposes to modify the responsibility of QA for review of design change requests (DCRs) from an in-line review to assessment of selected DCR/DCPs.

The change proposes to shift QA involvement and responsibilities with respect to work activities from in-line review of work procedures for designation of inspection hold points prior to approval to review of selected work procedures to assess the designation of inspection hold points through periodic assessment and inspection activities. In addition, the change proposes to explicitly identify observation of selected work activities as an area of QA involvement. . . . ..

Section 17.2.7 on Page 17.2-26 (HC) & Page 17.2-25 (Salem).

The change proposes to limit evaluation of changes to supplier and contractor procedures to changes that are significant. Significant changes are defined as any change that is not editorial in nature.

Section 17.2.10 on Pages 17.2-31 and 32 (HC) & Pages 17.2-32 and 33 (Salem).

The change proposes to clarify QA responsibilities regarding independent inspection by replacing the phrase "QA monitoring program" with the phrase "QA performance-based inspection" and by specifying that the program is conducted for selected activities.

Section 17.2.10 currently allows independent inspections to be performed by non-QA personnel. These changes are therefore considered to be editorial changes that clarify QA responsibilities.

The change also proposes to specify that a representative from QA, rather than the Manager - Quality Assessment, or his designee routinely attends and participates in schedule and status meetings. This is an editorial clarification since the Manager is not currently required to attend.

Other changes to Section 17 .2.10 are described in Section B below.

Section 17.2.15 on Pages 17.2-39 and 40 (HC) & Page 17.2-37 (Salem).

The change proposes to require in-line QA review of nonconformances and QA verification of resolution only if the nonconformance is dispositioned as "repair to other than current design" or "use-as-is." This activity will be covered under a NBU procedure.

QA would verify satisfactory resolution of other selected nonconformances through periodic assessment and inspection.

Other changes to Section 17.2.15 are described in Section C below.

Page 4of9

Document Control Desk LR-N980154 Attachment 1 Section 17.2.16 on Pages 17.2-40 and 41 (HC) & Page 17.2-38 (Salem).

The change proposes to clarify the requirements associated with QA department review of corrective action program (CAP) action requests to specify review of selected action requests for adequacy. A statement is added that indicates that the QA Department provides oversight of significant conditions adverse to quality through assessment and inspection activities.

Additional details are also added with respect to the periodic status reports that are used to monitor the CAP. This is considered to be an editorial change .

. Other changes to Section 17.2.16 are described in Section D below.

B. Independent inspections Section 17.2.10 on Pages 17.2-30a, 30b, and 31 (HC) & Pages 17.2-30-17.2-32 (Salem).

The change proposes to relocate the guidelines for establishing independent inspections to the Quality Assurance Inspection Program.

The change also proposes to relocate the list of typical periodic insp~ctions to Quality Assurance procedures.

The word "qualified" is added to clarify that independent inspections are performed by qualified individuals. This is considered to be an editorial change.

The activity associated with independent inspection of nondestructive examination is clarified as being a visual inspection. This is considered to be an editorial change.

C. Nonconformances Section 17.2.15 on Pages 17.2-39 and 40 (HC) & Pages 17.2-37 (Salem).

The proposed change clarifies and provides additional details regarding the disposition of nonconformances. Specifically, the proposed change identifies the Action Request Process, Corrective Action Program, and/or Maintenance Program as the mechanisms to be used to identify and disposition nonconformances. Clarification is provided to describe the circumstances under which each process should be used and the requirements that apply. The proposed change would allow certain nonconformances to be dispositioned without Engineering involvement.

The title of Operations Superintendent/Control Room Supervisor is revised to Licensed Senior Reactor Operator (SRO) .

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Document Control Desk LR-N980154 Attachment 1

-The change also proposes to clarify that reports identifying significant quality problems be initiated to "appropriate levels of management" rather than to "higher management."

This is considered to be an editorial change that is consistent with the language used in 10CFRSO, Appendix 8, Criterion XVI.

D. Corrective Action Program Section 17.2.16 on Pages 17.2-40 and 41 (HC) & Page 17.2-38 (Salem).

The change proposes to modify the requirements for significant conditions adverse to quality and conditions adverse to quality to be consistent with the requirements of 10CFRSO, Appendix 8, Criterion XVI.

REASON FOR PROPOSED CHANGES A. Elimination of In-Line Reviews by QA/Clarification of QA Responsibilities Removal of the QA Department from in-line reviews will improve independence in the quality oversight functions and allow for more efficient use of resources. The changes to the requirements to Section 17 .2.10 support transfer of inspection hold point activities to the line organization and establishment of a performance-based inspection program.

Allowing QA personnel and or personnel matrixed to QA to assess documents affecting nuclear safety would allow more flexibility in supplementing the QA staff on an as needed basis. The changes to the description of QA organization changes and changes to the QA Program description make the UFSAR discussion more consistent with the applicable regulations and guidance. The change to eliminate PA review of editorial changes to supplier or contractor procedures or manuals eliminates reviews that are not necessary in evaluating supplier/contractor QA capability. The remaining changes provide editorial clarification of QA responsibilities and requirements.

8. Independent inspections Relocation of the guidelines for establishing independent inspections and the list of typical periodic inspections from the UFSAR to the Quality Assurance Inspection Program removes unnecessary detail from the QA Program. The remaining changes provide clarification.

C. Nonconformances Some nonconformances can be appropriately dispositioned without Engineering involvement. Other dispositions and approvals are identified within the N8U procedures.

The proposed change clarifies that engineering personnel do not have to be involved in the disposition of every nonconformance.

Page 6of9

Document Control Desk LR-N980154 Attachment 1 Revising the title of Operations Superintendent/Control Room Supervisor to licensed

• SRO allows any licensed SRO to perform reviews of nonconformances for Limiting Condition for Operation applicability.

D. Corrective Action Program The change to the CAP description is intended to clarify the requirements and to make the description more consistent with the requirements of 10CFRSO, Appendix B, Criterion XVI.

BASIS FOR PROPOSED CHANGES A. Elimination of In-Line Reviews by QA/Clarification of QA Responsibilities Periodic assessment and inspection will allow for more effective evaluation of the processes involved by focusing on the process requirements. Removal of the QA organization from in-line review of these activities will shift the responsibility of quality onto the organizations performing the work. This will allow the QA organization to place more emphasis on independent oversight of station activities through periodic assessment and selected inspection of on-going work. The changes continue to satisfy the requirements of 10CFRSO Appendix B since QA personnel will continue to perform the quality assurance functions required by Criterion I.

The proposed changes to Section 17.2.2 with regard to changes to the QA Program make the UFSARs more consistent with the standard review plan. Although Salem is not committed to NUREG-0800, the changes are considered appropriate for Salem. The changes continue to satisfy the requirements of 10CFRSO Appendix B The proposed changes to Section 17.2.5 with regard to matrixed personnel ensures that QA functions continue to be performed by personnel with qualifications equivalent to those required by the QA training program. The changes continue to satisfy the requirements of 10CFRSO Appendix B The change made to Section 17.2.7 with regard to eliminating PA review of editorial changes to supplier or contractor procedures or manuals does not affect the ability of PA to evaluate the supplier's/contractor's QA capability. Editorial procedure changes would not impact the ability of the supplier/contractor to comply with quality requirements. The change continues to satisfy the requirements of 10CFRSO Appendix B Other changes are editorial clarifications .

• Page 7of9

Document Control Desk LR-N980154 Attachment 1 B. Independent Inspections With respect to relocation of the guidelines-for-establishing independent inspections from the UFSAR to the Quality Assurance Inspection Program, NUREG 0800 states that program procedures provide criteria for determining when inspections are required or define how and when inspections are performed. PSE&G has established procedures to provide these criteria. There is no requirement to include the subject criteria in the QA Program description. This change continues to satisfy the requirements of 10CFRSO Appendix B.

With respect to relocation of the list of typical periodic inspections, there is no requirement to provide a list as part of the inspection program in Section 17.2.10 of the UFSAR. This change continues to satisfy the requirements of 10CFRSO, Appendix B.

C. Nonconformances 10CFRSO, Appe.ndix B, Criterion XV, requires procedures to identify, document, segregate, disposition, and notify appropriate organizations about nonconformances, but does not require engineering involvement in all nonconformances.

Maintenance and planning personnel have the capability, responsibility, and authority to scrap a nonconforming item, or to use normal maintenance practices and procedures to restore nonconforming materials, parts and components to design conditions. Therefore, those organizations, and personnel, are the appropriate ones to disposition nonconformances of this nature. Since normal maintenance practices will be used, normal testing and QA practices provide adequate checks and balances.

Only engineering personnel, using approved design change and modification processes, have the capability, authority, and responsibility to alter the design of systems, structures, components, or parts. Therefore, engineers must be involved in the disposition of nonconforming materials, parts and components, if those items are to be repaired to other than design conditions, or to be used-as-is. Such nonconformances will continue to be reviewed and approved as stated in the NBU procedures. Repairs of these nonconforming material, parts, or components are inspected or retested, or both, in accordance with specified test and inspection requirements established by the responsible engineering representative, based on applicable requirements. QA currently does, and vvill continue to verify the satisfactory completion of the disposition of these nonconformances as selected per NBU procedures.

Any licensed SRO, which includes the Operations SuperintendenUControl Room Supervisor are qualified to determine if a LCO is applicable for nonconformances.

These changes continue to satisfy the requirements of 10CFRSO, Appendix B .

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Document Control Desk LR-N980154 Attachment 1

• D. Corrective Action Program The changes to the CAP description are consistent with the requirements of 10CFR50, Appendix B, Criterion XVI, and therefore, compliance with Appendix Bis maintained.

CONCLUSION:

PSE&G has determined that the proposed changes will not reduce the effectiveness of the QA Program and that the Program continues to satisfy the requirements of 10CFR50 Appendix B.

• Page 9of9

PROPOSED HOPE CREEK UFSAR CHANGES

Quality Assurance (QA) policy statements are issued by key management representatives, including the Chairman and Chief Executive Officer and the Chief Nuclear Officer and President - Nuclear Business Unit (CNO/PNBU). These policy statements are mandatory throughout the Company for nuclear facilities.

Key policy elements, as they apply to nuclear safety, include the following:

1. Nuclear safety is of the highest priority and shall take precedence over matters concerning power production.

2. The public's heal th and safety is the prime consideration in the conduct and support of Public Service Electric and Gas Company's nuclear* operations and shall not be compromised.* All decisions which could affect the health and safety of the public shall be made conservatively.

3. The Operational Quality Assurance Program is an essential part of the PSE&G commitment to safe and reliable nuclear power operation.

Applicable program requirements shall be strictly adhered to in the performance of activities covered by the Operational Quality Assurance Program.

PSE&G requires its suppliers and contractors to assume responsibility for establishing and implementing Quality Assurance/Q11a:lity Vex:ification (QA-/W) programs, as applicable, to meet 10 CFR 50, Appendix B. However, responsibility for the overall QA program is retained and exercised by PSE&G. EZA Procu:tement.

Assessment (PA) reviews those programs and conducts appropriate monitoring and auditing as required to assure that the suppliers are properly implementing their QA-/W programs. The Operational QA Program verifies that requirements necessary to assure quality are properly included or referenced in procurement documents.

In addition, these suppliers' procurement documents include applicable PSE&G quality assurance requirements for items and services provided by their suppliers .

• HCGS-UFSAR 17.2-2 Revision 8 September 25, 1996

17.2.1.1.1 Quality Assurance

• The Director -

implementing, Quality, and NT, coordinating and EP is the QA responsible program.

authority and has the independence to interpret quality requirements, for defining, He has quality problems and trends, and provide recommendations or solutions to quality been formulating, delegated identify the problems for all areas except those non-QA areas under his control. He is responsible for approval of the QA/NSR Department Manual used during the operations phase of the nuclear stations. He also is responsible for verifying compliance with established requirements for the QA program through document review, inspection, assessment, monitoring, and audits for all areas except those non-QA areas under his control. QA provides a centralized coordinating function for QA-fff.f activities applied to the operation phase.

The Director - Quality, NT, and EP has the authority and responsibility to stop work through the issuance of a stop work order, when significant conditions adverse to quality require such action.

The PSE&G policies and organization structure assure that the Director - Quality, NT, and EP has sufficient organizational freedom and independence to carry out his responsibilities.

The full attention of the Director will be in support of QA activities and will take precedence over his non-QA activities. In the event of a conflict, he will delegate all QA authority to the Manager - Quality Assessment if necessary. The Manager Quality Assessment has the authority to report directory to the CNO/PNBU for these matters.

The Director Qtrn:lity, N'.E', and EP Procu.rement A§seps,ment * (PA.r *Manage:r:-, who r.eports to the Manager - Nuclear Procur.ement anci Material: Management (NP&MM), ,is

~ responsible for the Quality Services activities provided by the Material &

Stipplier Plant Stipport PA group'. I t>Qhich incltide3. The' PA activities of the Manager ~:::** MP&MM will ta,.ke precedE)nce* over ){is. non-PA activities. In the even.t of a confliCt, he will delegate a.g authority i.n the area of PA to the PA Manager if nElcessary .

• Responsibilities and authorities of the PA Manager include the following:

1. The authority and, responsibility to stop work, Stop Work Order~

throµgh the i.ssuance. o:f a when sfgrificant coriditfons ad.verse to quality reqµirei3

such action.

2' The freedom and authority to directly access the MaJ:lager Quality Assurance if the need for such* access *exists* f~J: any.* i.'ssue under his responsibpi ty. In t.he event of a conflict concer::ni.ng' the impl_em:ent.ation of foe QA program. between NP&_MM i:!nd PA,_ the r::eporting line will be dirE)s:;t from PA t9 tl1,e Manager - _Quality A,ssessment.

1- 3. Review of engineering documents such as equipment specifications for inclusion of QA requirements.

2 4. Review and approve specifications for Q-listed materials 1 equipment, and services.

~ 5. Review of procurement documents for insertion of QA requirements.

~ ~. Conduct of supplier surveys, audits and surveillances .

• 5 7.. Evaluation of prospective and existing Supplier QA Programs.

17.2-4 HCGS-UFSAR Revision 9 June 13, 1998

8. Monitoring/auditing of nuclear fuel fabrication and in:5tallation.

T 9. Review of NBU fuel specifications for inclusion of QA requirements.

~ 10. Perform material evaluation activities on items subject to the QA Program.

Responsibilities of the Manager - Corrective Action, Emergency Preparedness, and Instructional Technology (Manager - CA, EP & IT) include the following:

1. Administration of the Corrective Action Program.

2. Management direction and cont:col 0£ all collection and Overall management of the trending of Corrective .. Action reports related /-to - hum<l.11, brga:~izational, and.programmatic performance.

3. Pe:c£orming statistical analysis t:cend repo:cts fo:c management.

The Manager's responsibilities relative to Emergency Preparedness and Instructional Technology are described in Section 13.1.1.2.1.4.2 .

Responsibilities and authorities of the Manager - Quality Assessment include the following:

1. The authority and responsibility to stop work, through the issuance of a Stop Work Order, when significant conditions adverse to quality requires such action.

2. The freedom and authority to directly access the CNO/PNBU if the need for such access exists for any issue under his responsibility, including those related to non-QA areas under the control of the Director - Quality, NT, and EP.

3. The responsibility and authority for verifying complance with established requirements of the QA program through document reviews, inspections, assessments and audits of non-QA areas under the control of the Director

-Quality, NT, and EP. This includes the authority to interpret QA program requirements during conduct of the above activities.

4. Development and implementation of the QA Audit and Assessment Program.

5. Performing assessments of contractor activities and evaluation of emergent contractor programs and procedures .

17.2-5 HCGS-UFSAR Revision 9 June 13, 1998

6. Planning_,_--and scheduling of stu: veillances, and performing functional area surveillance~/assessments conducted within the Nuclear Business Unit.

7. Performing selected station procedtire reviews and concurrence.

1-e-. Preparation and maintenance of the QA/NSR Department Manual, the QA program description in the UFSAR, and the Operational QA Program description in the Nuclear Administrative Procedures Manual.

~~- Review of the Nuclear Administrative Procedures Manual for compliance with the Operational QA Program.

Performing assessments-review of PSE&S Program selected NEU administrative

""' "" '"

• u . . . . . . _... "" ** ****:*** **:***

and implementing procedures through periodic assessment and inspection.

(a:s necessar:J!, these assessrnents ma:J! also include station adrltinistrative and implementing procedures) .

H:Q. Conducting QA Program orientation for NBU personnel and administering the training and certification program for QA personnel involved in inspection, assessments, and auditing activities, maintaining the QA training plan, and maintaining QA training records.

12"1.* Review of new regulatory requirements for QA program impact.

Coordination of the comntitment verification p:cograni Ve:i;ify compliance with

.u ****** ******-**

the procedures ,that implement the commitment management program by review of selected commitments through periodic assessment and inspection activities on a selected basis.

1314. Perform Code related inspections, test performance, and review of Conduct performance based inspections of selected Code related activities, observe and perform selected testing, and review selected weld procedures for inclusion of QA requirements.

15!. Perform design change package pre-implementation review and closure review for compliance with Inspection Hold Points (IHP-s) requirements for selected design cha~qe package by periodic assessment and inspection.

Performing performance based inspections.

1~§. Implementation of the onsite independent review.

18-1. Monitoring/auditing.of nuclear fuel installation.

1~§_. Mani tor the ability of the PA group_ t;o continuously function .independent:.fy a:3 d~ij,~eate<;l _under the re:3p()nsibilities of the i?A Manager - and pe_rfqrm periodic au.di ts of PA review functions. The fo,:t.lowihg p:r:9yid~9 gu}danc~

on the conduct and content of the s_~bject audits:

conduct interviews, surveys, etc. of selected,_ pe:r:E;onnel_ who. are involved tnprocurement or procurement assessme:r:it a,<:;tivities.or who are .in a p9sti:icin *.to observe these acti vit:ies observe selected procurerµ_ent. and procurement assessment. act;tvi ties assess' selected reviews, eval1:1at:lons, . ~mrv~ys, .Ciudit;E), and surveiTiances e:*ohductecC by !?A. personnel.

17.2-6 HCGS-UFSAR Revision 9 June 13, 1998

At least fifty percent (50%) of the personnel performing the onsite independent review shall have a Bachelor Degree in Engineering or a related field. For the discipline of Operations, a senior reactor operator license or certification may be used as an alternative qualification instead of a Bachelor Degree in Engineering or a related field.

Personnel performing the onsite *independent review function shall possess knowledge of nuclear power plant operation and knowledge of the discipline or activity in the assigned area of review. A single individual may be qualified to perform reviews in more than one discipline. The requisite experience may have been gained concurrently in related disciplines.

The Director - Quality, NT( and EP will approve and document the qualifications of those personnel performing the onsite independent review who are qualified based on at least eight (8) years related experience.

17.2.1.2 Maplewood Testing Services The Manager - Maplewood Testing Services reports to the Director Service Company (Servco) in the PSE&G Fossil Generation Business Unit.

Maplewood Testing Services performs calibrations, analyses, and evaluations on systems, equipment, and materials, as requested by NBU departments, and maintains compliance with its quality assurance program as approved by NBU PA ~-

17.2.1.3 Deleted

• HCGS-UFSAR 17.2-7k Revision 9 June 13, 1998

The NRC shall be notified of changes made to . this QA Pro9ram

• description as required by 10CFR50.54(a).

Substantive organization changes to the QA program described herein will be submitted to the NRC within 30 days of implementation. Nonsubstantive u

• u*

organization changes will be identified in the annual periodic UFSAR updates

'submitted in accordance with. ioctlso. 7i <~>.

The station General Manager has instituted and will maintain a station administrative procedures (SAP) manual.

Regulatory Guide 1.33 requires that plant activities affecting quality-related i terns and services be conducted in accordance with written administrative controls prepared by management. The procedures and instructions by which plant activities are performed are prepared by the responsible organization as required by Nuclear Administrative Procedures Manual, reviewed by the organization responsible for the activity, reviewed as required by Q:A and SORC, and 17.2-12 HCGS-UFSAR Revision 8 September 25, 1996

approved by the department manager. Nuclear Administrative Procedures (NAPs) and Station APs and all subsequent revisions thereto are reviewed by QA and SORC and are approved by the Station General Manager. Station Administrative, procedures and subsequent revisions thereto are reviewed by SORC and approved by the Station General Manager., Procedures cannot be implemented unless the review/approval process is accomplished. The Nuclear Administrative Procedures Manual provide a means to accommodate on-the-spot changes to subtier implementing procedures. The routine practice for revising a procedure is to repeat the original review and approval sequence.

Implementation of the QA program is verified by means of independent inspections, assessments, monitoring, and audits conducted by QA.

QA and PA reviews and anall'zes assess problems affecting quality that occur during the operational phase. Items subject to review include:

l. Documented nonconformances occurring at the supplier's facility and those identified during receiving, storage, installation, test, and operation, e.g., Deficiency Reports, Nonconformance Reports, Work Orders, Licensee Event Reports, etc.

2. Documented corrective actions taken on conditions adverse to quality and actions to prevent recurrence on significant conditions adverse to quality.

3. NRC inspection findings, notifications, bulletins, etc.

The Director - Quality, NT, and EP, -mtd the Manager - Quality Assessment, an(:i the PA Manager, or their designees, have the authority to stop work through the issuance of a Stop Work Order where continuance of an activity would seriously compromise quality or constitute a persistent and deliberate failure to correct a significant condition adverse to quality.

QA and PA reports significant conditions adverse to quality affecting the quality assurance program to respective management along with:

• HCGS-UFSAR 17.2-13 Revision 9 June 13, 1998

1. Measures taken to improve QA program controls

2. Appropriate recommendations to achieve compliance with applicable requirements.

Management administrative procedures provide all personnel with awareness and direction for reporting of defects and noncompliance pursuant to 10CFR21.

The QA program requires that safety-related activities and activities affecting the fire protection of safety-related areas, be accomplished under suitably controlled conditions. The program takes into consideration the need for procedures, special controls, cleanliness, special processes, test equipment, tools, and skills to obtain the required quality and the verification-of quality by inspection, test, examination, monitoring, assessments and independent review and audit. These activities include, but are not limited to, designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, reworking, repairing, refueling, and modifying .

• Personnel who have the responsibility to implement the QA program also have the responsibility and authority to escalate unresolved quality problems to the level of management necessary to effect resolution. Escalation is applied by QA or PA personnel to increasingly higher levels of management, up to the CNO/PNBU, as required.

Personnel performing Q, F, and R-designated activities are trained or indoctrinated as necessary to assure that suitable proficiency is achieved and maintained. Personnel outside the QA organization who perform inspections and tests are trained and qualified in QA concepts and practices.

17.2-14 HCGS-UFSAR Revision 9 June 13, 1998

1. Criteria are provided to specify when verification should be by test.

2. 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 beyond the point when the installation would be irreversible.

3. Tests will be performed under conditions that simulate the most adverse design conditions, as determined by analysis.

New drawings or revisions to existing drawings are prepared for inclusion into a design/configuration change by, or under the supervision *of a designer from information received from the responsible engineer, manufacturer's drawings, etc.

After implementation, approved design/configuration change information is transferred onto permanent drawings by a designer or drafter and peer reviewed and initialed as being checked by another designer or responsible design supervisor. New drawings or revisions to existing drawings receive final approval by the responsible design supervisor or authorized designee .

Specifications and changes thereto for i terns covered by the QA program are prepared by Nuclear Engineering and are reviewed by PA Supplier J\33e33ment for QA content.

eh PA review assures that the documents are prepared, reviewed, and approved in accordance with company procedures and that the documents contain the necessary QA requirements such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results .

The Station Operations Review Committee (SORC) reviews proposed changes affecting nuclear safety and makes recommendations concerning implementation of the change to the station general manager. The design change process provides for sign-off of the design change by the appropriate department head for the purpose of identifying required procedure change. If the proposed modification involves a Technical Specification change, or is considered by the SORC to involve an unreviewed safety question (10CFR50.59), the 17.2-20 HCGS-UFSAR Revision 9 June 13, 1998

matter is submitted to the Nuclear Review Board (NRB) for a determination of its safety implication before a license change request is submitted for NRC approval.

During the preparation of design changes, Nuclear Business Support assigns a project manager, as necessary. The project team consists of members of various organizations, both internal and external to Nuclear Engineering. The project team members are responsible for providing technical and administrative input to the entire design change process, which consists of design, installation, testing, and closeout phases. The technical and administrative input is guided by the requirements of those organizations which comprise the project team. The project manager ensures that the specific requirements of each organization on the project team are considered to ensure the overall quality of the product.

For design changes important to safet'.}', the QA rep:resentative on the project teaI!'I p:ro'1ides inp1:1t and ass1:1:res that design changes incl1:1de q1:1ali cy ass1:1rance requi:rements st1ch as inspection and test reqt1i:ren:1ents, acceptance reqt1i:rements, test :result doc1:1rnentation, and p:roject t::ea:m: con:tpliance with compan'.}' p:rocedn:res during prepa:ration, review, and approval of design changes

Ln'clus'ion' of quality requirements :Ln selected design changes through per:Lod:Lc assessment and inspect:Lon.

Updating of records, including drawings, blueprints, instructions and technical manuals, and specifications resulting from design changes, is the responsibility of the Senior Vice President - Nuclear Engineering. Design change procedures provide for the timely update of affected drawings following design change implementation to reflect as-built configuration.

17.2.4 Procurement Document Control Procurement documents and changes thereto for the purchase of Q, F, and R-designated material, equipment, or services are reviewed and approved by ~ PA prior to issuance by the Purchasing Department to the prospective supplier. ~

PA review assures that spare and replacement parts a11d serv:Lces 'are procured using controls which are commensurate with current QA program requirements .

• HCGS-UFSAR 17.2-21 Revision 9 June 13, 1998

The review also assures that procurement documents adequately and correctly:

• 1.

2.

Identify applicable QA program requirements Reference applicable regulatory requirements, codes, and standards

3. Provide right of access for source surveillance and audit by ~ ,PA or its agents

4. Provide for required supplier documentation to be submitted to PSE&G or maintained by the supplier, as appropriate

5. Provide for PSE&G review and approval of cri t-ical*--procedures* prior to fabrication, as appropriate.

Procurement documents require suppliers and contractors of other than commercial grade items to provide services or components in accordance with a QA program that complies with applicable parts of 10CFR50, Appendix B. The requirement for notifying PSE&G of procurement requirements that have not been met is conveyed to the supplier through the standard warranty provision contained in each purchase order. In addition, where 10CFR21 is imposed, suppliers are required to comply with applicable reporting requirements.

17.2.5 Instructions, Procedures, and Drawings Organizations engaged in Q, F, and R-designated activities are required to perform these activities in accordance with written and approved procedures, instructions, or drawings, as appropriate.

Simple routine activities that can be performed by qualified personnel with normal skills do not require a detailed written procedure. Complex activities require detailed procedures. The designation of those activities requiring detailed procedures is

• HCGS-UFSAR 17.2-22 Revision 8 September 25, 1996

made by cognizant department heads., and as a minimum, complies with applicable requirements of Regulatory Guide 1.33 .

Procedures include, as appropriate, scope, statement of applicability, references, prerequisites, precautions, limitations, and checkoff lists of inspection requirements, in addition to the detailed steps required to accomplish the activity. Instructions,* procedures, and drawings also contain acceptance criteria where appropriate.

The appropriate General Manager or Director is responsible for assuring that procedures are prepared, approved, and implemented in compliance with the Nuclear Administrative Procedures Manual. Documents affecting nuclear safety are reviewed by the SORC for technical content, b~ QA fox: QA x:eqnix:emenl::s, - and are approved by the responsible station department manager or his designee .~

assesses *selected documents .affectinq nuclear safety to ensure incorporation of quality requirements through. periodic assessment and inspection activities conducted by QA personnel or per:sonnel matrixed to QA. MatrixedHpersonnel*are qualified in accordance with* the QA or other equilvalent department training proqram.

The Director Nuclear Business Support is responsible for issuing specifications, drawings, blueprints, procedures, administrative and technical manuals associated with Q, F, and R-designated structures, systems, and components. Approved and implemented modifications and design changes are incorporated in these reference documents for the life of the station. Master lists of current editions or revisions of these documents are maintained by Nuclear Business Support to assure that only current and approved referenced documents are used.

QA reviews and app:roves selected procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair and changes thereto through periodic assessment and inspection activities. Changes l::o these docmnenl::s a:re also :reviewed and app:roved. In addition, QA is responsible for review and approval of selected specifications, test procedures, and results of testing through periodic assessment and inspection activities .

• HCGS-UFSAR 17.2-23 Revision 9 June 13, 1998

17.2.6 Document Control Instructions, procedures, drawings, and changes thereto are reviewed for the inclusion of appropriate QA requirements approved by appropriate levels of management of the PSE&G organizations producing such documents, and distributed on a timely basis to using locations. Measures are provided for the timely removal of obsolete or superseded documents from the using location. Supplier documents are controlled according to contractual agreements with suppliers.

The following is a generic listing of key documents for the operational phase, showing minimum organization responsibility for review and/or approval, including changes thereto:

1. Design specification - Nuclear Engineering, ~PA.

2. Design modification, manufacturing, construction, and installation drawings Nuclear Engineering, Nuclear Maintenance, station operations

3. Procurement documents initiating Nuclear Business Unit Organization, Nuclear Business Support, ~ 'PA

4. Nuclear Administrative Procedures Manual - Nuclear Business Unit organizations responsible for implementation, QA

5. Nuclear Business Unit second tier manuals, including station administrative procedures - cognizant department head, anc?: seilecb:!d

~anuals .,;_ndproi::edures by QA

6. Maintenance, modification, and calibration procedures for Q, F, and R designated station work activities - Nuclear Maintenance

7. Operating procedures - station operations 17.2-24 HCGS-UFSAR Revision 9 June 13, 1998

8. UFSAR Nuclear Engineering and other Nuclear Business Unit organizations responsible for implementing applicable sections. In addition, QA reviews subsequent changes to UFSAR sections to the extent necessary for assuring compliance with applicable QA program requirements

9. Maintenance, inspection, and testing instruction - Nuclear Business Unit implementing organizations

10. Post modification test procedures - Nuclear Engineering

11. Design Change Requests - Nuclear Engineering, and selected DCRs/DCPs by QA QA involvement in the work activity includes review of selected work procedures prio:i:: to approval to assess the :for-designation of independent *inspection hold points (see Section 17.2.10) , . ob~ervatio?1 o-f !:l~-lec:j:ed-wor:Jc aci::LYii:.:LE!s, . and review of 'selected completed safety-related Work Orders on a santpling basis, and during periodic QA surveillance and assessments and inspections .

The establishment and maintenance of a document control system for all instructions, procedures, specifications, and drawings received from the Nuclear Business Unit, or prepared at the station for use in operating, maintaining, refueling, or modifying i terns and services covered by the QA program, is the responsibility of the Director Nuclear Business Support. The Nuclear Administrative Procedures Manual describes the controls for specific documents.

Control of station practices is included in the administrative procedures and in department directives authorized by the responsible department managers.

Measures are established to assure that the administrative procedures and department directives are up to date, properly authorized, changed only after the required review and approvals are obtained, and distributed to appropriate personnel. Design change procedures provide for the timely update of affected drawings, following design change implementation, to reflect as-built configuration. Computerized databases maintained by the NBU organization are used to control drawings and specifications .

• HCGS-UFSAR 17.2-25 Revision 9 June 13, 1998

Revision control of procedures and instructions is accomplished through the control of computerized databases. Controls of software affecting nuclear safety are identified in the Nuclear Administrative Procedures Manual. These controls are based on applicable guidelines provided by the NRC and include software review and approval as well as access controls to prevent unauthorized software changes.

17.2.7 Control of Purchased Material, Equipment, and Services

~ PA maintains an up-to-date listing of approved suppliers of material, equipment, and services covered by the QA program. This list identifies suppliers and contractors who have demonstrated the ability to supply acceptable material, equipment,* or services. The list *includes manufacturers of *commercial grade items. All QA program procurements are made from approved suppliers.

The responsible engineer and ~ PA personnel select and evaluate prospective bidders and suppliers. The responsible engineer determines the technical competence of the supplier, while~ PA evaluates the prospective supplier's QA program for the capability of meeting applicable requirements of 10CFR50, Appendix B, and for extending applicable program requirements to subtier suppliers.

Qualified~ PA personnel evaluate the prospective supplier's QA capability using one or more techniques, including but not necessarily limited to:

1. Evaluation of supplier's or contractor's procedures or manuals and significant (i.e. r non-editorial) changes thereto

2. ASME code stamp approval

3. Nuclear Utility Procurement Issues Council (NUPIC) or Nuclear Fuel Users Forum (NFUF) Audits.

4. Satisfactory past history of providing similar items

• HCGS-UFSAR 17.2-26 Revision 8 September 25, 1996

5. Survey of supplier's facility

• The evaluations checklist form of the designed Appendix B, as appropriate.

prospective to include suppliers the 18 are conducted quality criteria using of standard 10CFR50, Surveys of suppliers' capabilities include evaluation of management systems, manufacturing processes and adherence to QA-fft.I procedures. The results of supplier evaluations are documented by the appropriate checklist form and filed.

Supplier control is maintained through a planned inspection, moni taring, and audit program by eR FA,.

eR PA and the responsible engineer conduct a review of the manufacturing process for complex manufactured items, such as pumps, valves, heat exchangers, vessels, electrical panels, etc. This review establishes critical inspection points and establishes a notification point program for the identified inspection or surveillance activities. The established inspection or surveillance activities are implemented by qualified eR PA personnel or eR P,A agents . Commercial Grade Items are dedicated in accordance with recognized industry standards, e.g. EPRI NP 5652.

Monitoring of suppliers/contractors during fabrication, installation, modification, rework, repair, inspection, testing, and shipment of Q, F, and R-designated materials, equipment, and services, is conducted by qualified eR PA personnel or eR .J?A agents at the supplier's/contractor's facility or at the generating station. Surveillances are conducted in accordance with written procedures and are designed to assure conformance with procurement requirements, in accordance with the safety significance of the item or service.

17.2-27 HCGS-UFSAR Revision 8 September 25, 1996

identification is directly marked on the item, or on records traceable to the item. The data review conducted at receiving assures that proper documentation of received items is available. Materials and i terns received without proper identification are tagged or segregated unti-1 satisfactory documentation and identification is obtained.

Procedures require Q, F, and R-designated materials, parts, and components to be marked or otherwise identified, and require that such identity be maintained either on the item or on records traceable to it throughout receipt, storage, installation, and use. Protection against use of incorrect or defective items is also provided.

Material identification and traceability is maintained for rework)

• repairs, and modifications throughout operation.

Identification and control of materials, parts, and components are the responsibility of Nuclear Maintenance, Nuclear Engineering, and Nuclear Business Support. Procurement document controls are the responsibility of Quality A33urance PA. Receipt, storage, installation, inspection and test activities are the responsibility of Nuclear Business Support, QA, PA, and Nuclear Maintenance.

17.2.9 Control of Special Processes Special process controls provide for the use of qualified procedures, equipment, personnel, and documentation of satisfactory completion of an activity. Special processes are generally those processes where direct inspection is impossible or disadvantageous.

Procedures have been established for special processes such as welding, brazing, soldering, concreting, protective coating, cleaning, heat treating, and nondestructive examination (NOE) to assure compliance with codes and design specifications. The Senior Vice President - Nuclear Engineering is 17.2-29 HCGS-UFSAR Revision 9 June 13, 1998

responsible for preparing special process procedures such as concreting, protective coating and cleaning, while the General Manager - Nuclear Maintenance is responsible for preparing specifications for processes such as welding, brazing, soldering and heat treating. Nuclear Engineering is responsible for preparing specifications for non-destructive examination (NOE). These specifications are reviewed and approved by the Nuclear Maintenance Code Assurance Specialist for necessary QA program requirements. QA moni taring assessments and audits assure that qualification of special processes, equipment and personnel have been satisfactorily performed.

Procedures for implementing the requirements of the specifications are prepared either by the Nuclear Business Unit or by supplier personnel, and are reviewed by a *. quaI.i.f:ied specialist QA &nd the &ppropri<'l:te genernl m&Mger or their designees, with the exception of special process procedures prepared by code suppliers holding a valid certificate of authorization. ~* qua~i~ied ~p~~ial~~t is~ a. *person who has cert:Cfied pro¥idencyTn th.e_§rea c:;¥ rey~ew . (~. g-., persormei reviewing NOE procedures_ are ~equired tci have Level iii .. certifi,cation In the subject NOE area, and personnel reviewing other procedures or reports are

cequiredtp be qualified iri accor¢ance with PSE&G' s Enginee:cing_ Support Per.sonriel

• • ~ .. .. .

P:r;ograrnl ~.

Qualification records of procedures, equipment, and personnel associated with special processes are retained as stated in Section 17.2.17.

17.2.10 Inspection A planned inspection program is conducted and documented by personnel appropriately qualified in accordance with Section 17.2. 2. The inspection program verifies conformance to the established procedure, code, or standard, consistent with the item's or activity's importance to safety.

The inspection program for maintenance and modification activities is based upon the following three important levels of inspection:

1. Worker Checks Quality cannot be achieved unless the worker performs the activity in a quality manner. The worker is the individual best able to control the quality of work performed. Work steps that contain 17.2-30 HCGS-UFSAR Revision 9 June 13, 1998

elements impacting plant equipment or systems have provisions for signoff by the worker. This worker sign-off establishes accountability for the activity and is acknowledgement that the activity has been performed as specified in the work step.

2. Supervisory Inspection Al though the work supervisor may have overall responsibility for the conduct and performance of the work activity, certain conditions at the work location require supervisory inspection to increase confidence that work activities are completed as specified through familiarity of the work activity, work group, or past experience. Supervisory inspections are established in* the appropriate work procedure ****and *accomplished through direct observation of the work activity.

3. Independent Inspection - Independent inspections are not intended to dilute or replace the responsibility of the worker check or supervisory inspection for quality of work. Independent inspections provide the maximum confidence attainable that the work activity has been performed in accordance with the overall objective. '!'ypical gnidelines for establishing independent: inspections incl tide conditions similar to the following.

Work activit:'.il affecting rednndant equipment or potentiall:'.il catising cascading failtire.

Retest will not verify the applicable at:t:ribnte.

Establishing a baseline in a ne~ process or procedtire.

It is deerrced necessary to :maintain confidence in the ~ork process.

17.2-30a HCGS-UFSAR Revision 4 April 11, 1992

This gnidance is conside:i:ed b:'i' the :i:esponsible QA o:i:ganization in the establishment of inspection activities.

Guidelines for establishing independent - inspections are defined in the - QA Inspection Program.

Independent inspections are identified as Inspection Hold Points (IHPs) in the applicable work instructions and are performed by qualified individuals independent of the work activity. IHPs cannot be passed without authorization from the applicable management representative responsible for the inspection activity.

General guidelines for - the inspection criteria are established- --by QA and incorporated into various administrative and work instructions.

Independent inspections are performed by QA or other qualified individuals who are independent of the work activities. If the individuals performing inspections are not part of the QA organization, the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are reviewed for acceptability by the QA organization prior to initiation of the activity.

Work procedures and inspection instructions include, as required, characteristics to be inspected, method of inspection, acceptance/rejection criteria, required measuring and test equipment, and required reference documents. Documentation includes inspection identification and results of inspection performance.

As a result of its review, the Station Operations Review Committee (SORC) may recommend additional or different hold points to the organization performing the work activity.

Periodic inspection, other than IHPs, is performed by qualified individuals other than those who performed or directly supervised the activity being inspected.

These cypicall:11 inclnde pe:riodic inspections of the following .

• HCGS-UFSAR 17.2-30b Revision 4 April 11, 1992

1. Storage areas

2. Hottsekeeping (general)

3. Fire protection eqttipncent

4. Special handling tools and eqttipment

5. UDE ~isttal inspection reqnired b'.}' the inser~ice inspection program.

Typ.icalperiodic.inspections are described in QA Program procedures.

An independent organization shall perform NOE visual* inspection as required, using qualified individuals other than those who performed or directly supervised the activity.

When inspections are performed by individuals other than th?se . '."fh.o performed or directly supervised the work, but who belong to the same work group, and the activity involves breaching a pressure-retaining boundary, the quality of the work is demonstrated through appropriate testing, unless restrictions such as ALARA considerations prevent such testing.

The applicable inspection and retest requirements necessary to assure that

• modifications, retest rework, or repairs have been accomplished correctly are included in the design change package, requirements for work order, modification, original inspection and test program, or procedure.

rework, and repair The inspection and are based as well as the nature and scope of the on the modification or repair activity.

Evaluation and review of inspection results are conducted by personnel certified I Level II in ANSI/ASME N45.2.6 and SNT-TC-lA, as applicable.

A planned and documented QA monitoring perform~nce-:based inspection program is conducted by QA for selected Quality Program activities, including the inspection program and personnel qualifications. Monitoring of the 17.2-31 HCGS-UFSAR Revision 8 September 25, 1996

implementation of the QA program by station and site contractor personnel is conducted by QA, in addition to offsi te supplier activities as appropriate.

Conditions adverse to quality found during the conduct of monitoring are brought to the attention of the management responsible for the activity.

'!'he Manager Qualit11 Assessment, or designee,' A representative fi-~m; QA routinely attends and participates in plant work schedule and status meetings to assure that they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualification of personnel to carry out QA assignments .

17.2-32 HCGS-UFSAR Revision 8 September 25, 1996

17.2.14 Inspection, Test, and Operating Status

• Nuclear Business Unit procedures are required to specify the periodic tests and inspections required for equipment covered by the QA program, and to include the necessary management controls to assure that inspections are completed in accordance with specified requirements.

such required tests and/or Equipment awaiting repairs, under repair, or repaired, and received materials are marked to indicate the status of inspection and test requirements and/or acceptability for use. Procedures provide for tagging valves and switches to prevent inadvertent operation. These procedures control the application and removal of tags and are designed to prevent operation of valves and/or switches that could result in personnel hazard or equipment damage.

Valve and equipment status boards or logs are maintained to indicate status.

17.2.15 Nonconforming Materials, Parts, or Components Organizations involved in material receipt, installation, test, design modification and other operating activities are responsible for identifying, and documenting nonconformances. Nonconforming materials, where practical, are segregated to prevent installation or use until proper approvals are obtained.

Materials, parts, or components that have failed in service are identified and, where practical, segregated. Procedures control the application and removal of tags.

Documentation of the nonconformance includes a description of the nonconformance, review by Operations S1:1perintendent/Control Room S1:1peroisor licensed Senior 13eactor Operator for Limiting Condition for Operation (LCO) applicability when appropriate and the disposition and inspection or retest requirements, as appropriate. The Action Request (Notification) Process, Corrective Action Program, and/ or Maintenance Program are used to identify and disposition nonconformances, as appropriate to.the condition.

The maintenance program will be used to disposition nonconforming materials, parts, or components, which are to be scrapped, or restored to design condition

, . *.. . .. . ... **~

by replacement in kind or other standard maintenance practices. Retesting will be in accordance with nor*~~l post-niaintenance testing, and p'~st-maintenan.Ce operability retesting* practices. QA will verify the satisfactory resolution of

such nonconformances, on a selected basis, thr:ouqh its normal maintenance p;rogram assessment and inspection activities.

The responsible Engineer dispositions each nonconfo:rmance :report materials',

parts, or components that are to be repaired to other than curre_nt design specifications Dispositions for :_repair to other than current design specifications" or "use-as-is" are required to be reviewed and approved by QA prior to implementation 'as required per* NBU procedures Rework or----rEepair of nonconforming material, parts, 17.2-39 HCGS-UFSAR Revision 9 June 13, 1998

or components is inspected or retested or both in accordance with specified test and inspection requirements established by the responsible engineering representative, based on applicable requirements. QA or P]\ shall verify the satisfactory completion of the disposition of these nonconformances.

QA and other organizations in the Nuclear Business Unit review selected nonconformance reports for quality problems, including adverse quality trends, and initiate reports to higher appropriate levels of management, identifying significant quality problems with recommendations for appropriate action.

17.2.16 Corrective Action Organizations involved in activities covered by the QA program ~re require~ to implement corrective action for significant conditions adverse to quality (SCAQ) and conditions adverse to quality * (CAQ) identified within their scope of activity. Such conditions are documented and controlled by issuance of an action request. The QA Couec_tive.. ~~t:;iox_~: Srol"l:]? I>ep~:r1::I11lr11:: reviews 's~l~ct~d :t:esponses to action requests- responses for adequacy_*_t_h~r_o_u_g~h~~~~~~~~~~~==~~==

activities. and :monito:t:s these action :t:equests th:t:ongh ?periodic summary and status reports of the overall c6rrective Action

• Program' are provided *to management through either the performance indicators or the periodic qA report.

Responses to SCAQ action reqnes ts d.6duments 'are :retjui:red to *include based on the four elements of cor:t:ectill'e action, which are:

1. Identification of cause of deficiency

2. Action taken to correct deficiency and results achieved to date

3. Action taken or to be taken to prevent recurrence

4. Date when full compliance was or will be achieved.

Responses to CAQ corrective.action documents are reguired*to include:

• Identification of deficiency

• • _,. ** ,,. * ****-* u.

Action taken to correct deficiency For significant conditions adverse to quality, such as LERs and NRC/INPO/CMAP

findings, the QA Co:r::r:ecti1:1e Action S:r:oup Departmeil.t is involved in the review of snch conditions and provides oversight to assure timed:'i!

17.2-40 HCGS-UFSAR Revision 8 September 25, 1996

follow-up and close out through as*sessment and inspection activities.

Items 3 and 4---a:t:e optional fo:t: conditions adve:t:.se to q1:1al:itj!.

Proper implementation of corrective action is verified through surveillance, inspection, assessment or audit, as appropriate.

The appropriate general manager or director is responsible for assuring that conditions adverse to quality are promptly identified and corrected for all activities involving station operation, maintenance, testing, refueling, and modification.

Administrative procedures *that govern station activities *covered by the QA program provide for the timely discovery and correction of nonconformances. This includes receipt of defective material, failure or malfunction of equipment, deficiencies or deviations of equipment from design performance, and deviations from procedures. In cases of significant conditions adverse to quality, the cause of the condition is determined, and measures are established to preclude recurrence. Such events, together with corrective action taken, are documented and reported as described in Section 17.2.15. Corrective action is initiated by the responsible department head.

QA closely monitors station conditions requiring corrective action.

Repetitive deficiencies, procedure or process violations at the station that are not classified as operational incidents or reportable occurrences, or nonconformances under the QA program, are documented via the issuance of an action request. This request provides a formal administrative vehicle to alert management of conditions adverse to quality that require corrective action.

17.2-41 HCGS-UFSAR Revision 9 June 13, 1998

17.2.17 Quality Assurance Records

• Records necessary to demonstrate that activities important to quality have been performed in accordance with applicable requirements are identified maintained in accordance with Regulatory Guide 1.88, as noted in Section 17.2.2.

Records shall be considered valid only when authenticated by and authorized personnel. Record types as a minimum, comply with applicable technical specification requirements and include operating logs, maintenance and modification procedures and related inspection results and reportable occurrences.

The Nuclear Business Unit is responsible for the permanent storage of station records. The retention period for records*; permanent** storage *-location; and methods of control, identification, and retrieval are specified by administrative procedure. Individual station department heads are responsible for submitting applicable department records to the designated location for retention.

17.2.18 Audits Audi ts of PSE&G and supplier organizations that implement the QA program are preformed by QA and PA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records as required. Performance based assessment should be an integral part of the auditing program and should evaluate activities on the basis of their effect on the safe and reliable operation of the facility. An annual audit schedule is developed to identify the audits to be performed and their frequency. A dominant factor in audit schedule development is performance in the subject area. Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR. Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that a-t least biennial ( 2 years) audits of safety related activities are performed. A list of operational phase activities subject to the audit program is provided in section 17.2.1.1.2.3 and in Table 17.2-1 .

• Audi ts are conducted by audit teams comprised of a certified lead auditor and certified auditors, and technical specialists (when deemed necessary).

HCGS-UFSAR 17.2-42 Revision 9 June 13, 1998

PROPOSED SALEM CHANGES

Assurance Program, independent auditors from outside the company audit the program every 2 years for compliance with 10CFR50, Appendix B, and other regulatory commitments. Reports of such audits are made directly to upper management.

Quality Assurance (QA) policy statements are issued by key management representatives, including the Chairman and Chief Executive Officer and the Chief Nuclear Officer and President - Nuclear Business Unit (CNO/PNBU). These policy statements are mandatory throughout the Company for nuclear facilities.

Key policy elements, as they apply to nuclear safety, include the following:

1. Nuclear safety is of the highest priority anq sh,all take p:r::~cedence over matters concerning power production.

2. The public's health and safety is the prime consideration in the conduct and support of PSE&G's nuclear operations and shall not be compromised. All decisions which could affect the health and safety of the public shall be made conservatively .

3. The Operational Quality Assurance Program is an essential part of the PSE&G commitment to safe and reliable nuclear power operation.

Applicable program requirements shall be strictly adhered to in the performance of activities covered by the Operational Quality Assurance Program.

PSE&G requires its suppliers and contractors to assume responsibility for establishing and implementing Quality Assurance/Qnalit~ Ve~ifieation (QAffX-1) programs, as applicable, to meet 10CFR50, Appendix B. However, responsibility for the overall QA program is retained and exercised by PSE&G. (;2fs: ':i?rocuiement Assessment (PA)' reviews those programs and conducts appropriate monitoring and auditing as required to assure that the suppliers are properly implementing

• SGS-UFSAR 17.2-2 Revision 15 June 12, 1996

2. An annual assessment of the QA program that is preplanned and documented. This assessment addresses the scope, status, and adequacy of the QA program. Corrective action is identified and tracked.

17.2.1.1.1 Quality Assurance The Director - Quality, NT and EP is responsible for defining, formulating, implementing, and coordinating the QA program. The Director has been delegated the authority and has the independence to interpret quality requirements, identify quality problems and trends, and provide recommendations or solutions to quality problems for all areas except those non-QA areas under his coptrol. The Director is responsible for app:r:oval of the QA/NSR Department Manual used during the operations phase of the nuclear stations. The Director also is responsible for verifying compliance with established requirements for the QA program through document review, inspection, monitoring, assessments and audits for all areas except those non-QA areas under his control. QA provides a centralized coordinating function for QAff2V activities applied to the operations phase .

The Director - Quality, NT and EP has the authority and responsibility to stop work, through the issuance of a Stop Work Order, when significant conditions adverse to quality require such action.

The PSE&G policies and organization structure assure that the Director -

Quality, NT and EP has sufficient organizational freedom and independence to carry out his responsibilities.

The full attention of the Director will be in support of QA activities and will take precedence over his non-QA activities. In the event of a conflict, the Director will delegate all QA authority to the Manager - Quality Assurance, if necessary. The Manager - Quality Assessment has the authority to report directly to the CNO/PNBU for these matters.

The Director Qm1lity, N'P, and EP Procurement Assessment. (PA) Manager, who

r;eports to the McinagE;lr - t:Juc~Ela:r: Pr9c;ure11.1Eint and Mater,:kal . Ma,11agell\.ent JNJ?&cMM},

• is ~ responsible for the Quality Services activities provided by the llaterial & Sopplier Pl~mt Sopport PA group~, Hhich incl ode~.

activities ofthe Manager - MP&MM will take precedence over his non-PA aC:ti yi t~es ~

The PA In the event of a C()nflict, he will delegate al) ?,1]tho:r;i ty in the

area of PA to -the PA Manager if necessary:

1.- The authority anci respo11s_ibHity t.o stop work, through the issuance ofa Stop Work Order, when signifiC::?P:i: c;::o_ndi tions adv_~:i;"se to ql!al.~i:Y requires such action.

2 .* The freedom and authority to directI,y access the .Ma.nager - Quali:t:y Assurance if the need for such access exists for ar:iy ~ssu~under his p~spofl.~ibil~ty: -* In the event* of a ..conflict C()nc:;erning- the implementation of fhe QA progr::am between N?&MM anci J?A.;, the reporting. line "7i:Ll be <:l:iiecf

.from PA to the Manager -:Quality ~s,s~ssment,:

~ 3. Review of engineering documents such as equipment spe_d,fication~ for inclusion of QA requirements.

2 4. Review and approve specifications for Q-listed materials, equipment, and services.

17.2-4 SGS-UFSAR Revision 16 January 31, 1998

3 5. Review of procurement documents for insertion of QA requirements.

• ~- Conduct of supplier surveys, audits and surveillances.

5 7. Evaluation of prospective and existing Supplier QA Programs.

6- :s. Mani taring/auditing of nuclear fuel fabrication &.rd _;_ll..,talla :..ior..

7- *~.* Review of NBU fuel specifications for inclusion of QA requirements.

a- 10. Perform material evaluation activities on items subject to the QA Program.

Responsibilities of the Manager - Corrective Action, Emergency Preparedness I

and Instructional Technology (Manager - CA, EP & IT) include the following:

1. Administration of the Corrective Action program.

2. Management direction and control of all collection and Overall management of the trending of Corrective Action reports related to hrnan,

• orqani.zational, and programmati.c performance:.

3. Performing statistical analysis trend reports for management.

The Manager's responsibilities relative to Emergency Preparedness and Instructional Technology are described in Section 13.1.1.2.1.4.2 .

• SGS-UFSAR 17.2-4a Revision 16 January 31, 1998

Responsibilities and authorities of the Manager - Quality Assessment include the following:

1. The authority and responsibility to stop work, through the issuance of a Stop Work Order, when significant conditions adverse to quality requires such action.

2. The freedom and authority to directly access the CNO/PNBU if the need for such access exists for any issue under his responsibility, including those related to the non-QA areas under the control of the Director - Quality, NT and EP.

3. The responsibility and authority for verifying compliance with established requirements of the QA program through document reviews, inspections, assessments and audits of non-QA areas under the control of the Director - Quality, NT and EP. This includes the authority to interpret QA program requirements during conduct of the above activities.

4. Development and implementation of the QA Audit and Assessment Program.

5. Performing assessments of contractor activities and evaluation of emergent contractor programs and procedures.

• ****Y * **vn* ****-.

6. Planning_,_--and scheduling of snrveillances 1 *and performinq*functional

'are~ surveiliC:nces/~$$e;;ssments conducted within the Nuclear Business Unit.

7. Performing selected station procedti:re revieo<1s and conc1:1rrence .

• SGS-UFSAR 17.2-5 Revision 16 January 31, 1998

e1. Preparation and maintenance of the QA/NSR Department Manual, the QA Program description in the UFSAR, and the Operational QA Program description in the Nuclear Administrative Procedures Manual.

~~- Review of the Nuclear Administrative Procedures Manual for compliance with the Operational QA Program.

M~. Performing assessments review of PSE&S Program select'ed NBU administrative and implementing procedures through periodic assessment anc:l. ;Lns:i:?ectioh; (as necessar:i, these assessments nca'.}' also inclnde station administrative and implementing procedm::es) .

• 11:0. Conducting QA Program orientation for NEU personnel,, adm.inist~ring the training and certification program for QA personnel involved in inspection, assessments~ and auditing activities, maintaining the QA training plan, and maintaining QA training records.

lr1. Review of new regulatory requirements for QA Program impact.

l~;,,_. Coordination of the conmcitment verification program Verify* compliance with the procedures that implement the commitment management program by review of ,selected commitments through periodic assessment and inspection activities on a selected basis.

14-3. Performing Code related inspections, test performance, and review of Conduct pt:irformance based inspections of selected Code related activities, observe ~ndpe~forro.-seieC::ted te~t:i..ng, and review selected weld procedures for inclusion of QA requirements.

15!. Performing design change package pre-implementation review and closure review for compliance with Inspection Hold Point (IHP) requirements for

'selected.design change packages by periodic assessment and inspection.

1~~- Performing performance Based Inspections.

17§. Implementation of the onsite independent review .

• 161. Random assessments are performed on the cable S'.)'stem to ensn:r:e Verify that they selected cables have been installed, identified, and routed as specified per procedure through periodic assessment or inspection of

selected cable systems.

19. Q1:1ality verifications are pe:rformed on field installed cables to ens1:1re that the cables a:re p:rope:rly installed, identified and ro1:1ted as specified pe:r proced1:1re.

Mol1itor:i,ng/auditing of.nuclear fuel installation.

2-19. Mon:i.ior the a):):f:.1J ~y of the PA group to COI1t:i.nuousiy function indep.ericiently*: as deifneated under the responsibil,ifles of. the PA Mariager and perforrp. periodic audits of PA review functions. .The following provides 9l1ici<mc;e on the conduct and content Of the subject audits:

concluct.Interv:i.ews, survE:Jys, etc. of. selec.ted-personne,l who are

_involvt?d in_ procurement or procurement assess_ment a_Gtivities or who.

are in a: pos:i,tJori t,o observe thes.e. a:ctt vit:i,es.

observe selected procurement and_ procurement assessment activities.

• assess selected. revie>Vs, eya)uatiori_s,. surveys., audit,s, a:n<:f

surveillances conducted* by PA personnel.

17.2-6 SGS-UFSAR Revision 16 January 31, 1998

b. Review of selected facility features, equipment, and systems.

c. Review of selected procedures and plant activities including maintenance, modification, operational problems, and operational analysis.

d. Surveillance of selected plant operations and maintenance activities to provide independent verification that they are performed correctly and that human errors are reduced to as low as reasonably achievable.

The personnel performing the onsite independent review shall have: 1) at least three (3) years related experience of which at least two (2) years are nuclear related, and a Bachelor Degree in Engineering or a related field; or

2) at least eight (8) years related experience, of which at least five (5) years are nuclear related. At least fifty percent (50%) of the personnel performing the onsite independent review shall have a Bachelor Degree in Engineering or a related field. For the discipline of Operations, a senior reactor operator license or certification may be used as an alternative qualification instead of a Bachelor Degree in Engineering or a related field.

Personnel performing the onsite independent review function shall possess knowledge of nuclear power plant operation and knowledge of the discipline or activity in the assigned area of review. A single individual may be qualified to perform reviews in more than one discipline. The requisite experience may have been gained concurrently in related disciplines.

The Director-Quality, NT and EP will approve and document the qualifications of those personnel performing the onsite independent review who are qualified based on at least eight (8) years related experience.

17.2.1.2 Maplewood Testing Services The Manager Maplewood Testing Services reports to the Director-Service Company (Servco) in the PSE&G Fossil Generation Business Unit.

Maplewood Testing Services performs calibrations, analyses, and evaluations on

• systems, equipment, and materials, as requested by NBU departments, and maintains compliance with its quality assurance program as approved by NBU PA

~.

SGS-UFSAR 17.2-7i Revision 16 January 31, 1998

14. Regulatory Guide 1.137, Fuel-Oil Systems for Standby Diesel Generators.

15. Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants.

16. Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants.

17. BTP 9.5-1, Appendix A, Guidelines for Fire Protection for Nuclear Plants Docketed Prior to July 1, 1976.

Commitments to Regulatory Gµides, with respect to revision level, exceptions, etc, are contained in Section 3, Appendix 3A.

The code QA requirements are used for the procurement of systems, components, and structures covered by ASME Boiler and Pressure Vessel Code B31.l and B31.7 or evaluated to be an acceptable replacement. The standard QA program controls apply to Q-Listed code items following receipt at the station. In addition, applicable requirements of Regulatory Guide 1.38 are applied to ASME Code procurements where necessary to assure safe shipment .

The NRC shall be notified of changes made to this QA Program description as required by 10CFR50.54(a) ~

Substantive orgCinization changes to the QA program described herein will be submitted to the NRC within 30 days of implementation. Nonsubstantive organization changes will be identified in the annnal periodic UFSAR updates submitted in accordance with 10CFR50.71(e).

17.2-11 SGS-UFSAR Revision 15 June 12, 1996

The station General Manager has instituted and will maintain a station administrative procedures (SAP) manual .

Regulatory Guide 1.33 requires that plant activities affecting quality-related items and services be conducted in accordance with written administrative controls prepared by management. The procedures and instructions by which plant activities are performed are prepared by the responsible organization as required by the Nuclear Administrative Procedures Manual, reviewed by the organization responsible for the activity, reviewed as required by QA and SORC, and approved by the department manager. Nuclear Administrative Procedures (NAPs) and station APs and all subsequent revisions thereto are reviewed by QA and SORC and are approved by the Station General Manager.

Station Administrative procedures* and subsequent revisions.thereto are

• -** ***>>*- '"*- ***- *O**

reviewedby SORC and a@rovedby the S:t:ati6n Gener<:1:L~riag:er~ Procedures cannot be implemented unless the review/approval process is accomplished. -The Nuclear Administrative Procedures Manual provides a means to accommodate on-the-spot changes to subtier implementing procedures. The routine practice for revising a procedure is to repeat the original review and approval sequence .

• Implementation of the QA program is verified by means of independent inspections, assessments, monitoring, and audits conducted by QA .

QA and PA reviews and assess anal~zes problems affecting quality that occur during the operational phase. Items subject to review include:

1. Documented nonconformances occurring at the supplier's facility and those identified during receiving, storage, installation, test, and operation, e.g., Deficiency Reports, Nonconformance Reports, Work Orders, Licensee Event Reports, etc.

2. Documented corrective actions taken on conditions adverse to quality and actions to prevent recurrence on significant conditions adverse to quality.

3. NRC inspection findings, notifications, bulletins, etc .

• SGS-UFSAR 17.2-12 Revision 15 June 12, 1996

The Director - Quality, NT and EP, ttttd the Manager - Quality Assessment,, and the PA Manager, or their designees, have the authority to stop work through the issuance of a Stop Work Order where continuance of an activity would seriously compromise quality or constitute a persistent and deliberate failure to correct a significant condition adverse to quality.

QA :and, PA report-e significant conditions adverse to quality affecting the quality assurance program to respective management, along with:

1. Measures taken to improve QA program controls.

2. Appropriate recommendations to achieve compliance with applicable requirements.

Management administrative procedures provide all personnel with awareness and direction for reporting of defects and noncompliance pursuant to 10CFR21.

The QA program requires that safety related activities and activities affecting the fire protection of safety-related areas, be accomplished under suitably controlled conditions. The program takes into consideration the need for procedures, special controls, cleanliness, special processes, test equipment, tools, and skills to obtain the required quality and the verification of quality by inspection, test, examination, monitoring, assessments and independent review and audit. These activities include, but are not limited to, designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, reworking, repairing, refueling, and modifying.

Personnel who have the responsibility to implement the QA program also have the responsibility and authority to escalate unresolved quality problems to the level of management necessary to effect resolution. Escalation is applied by QA or PA personnel to increasingly higher levels of management, up to the CNO/PNBU, as required.

17.2-13 SGS-UFSAR Revision 16 January 31, 1998

testing will be def erred, but not beyond the point when the installation would be irreversible.

3. Tests will be performed under conditions that simulate the most adverse design conditions, as determined by analysis.

New drawings or revisions to existing drawings are prepared for inclusion into a design/configuration change by, or under the supervision of, a designer from information received from the responsible engineer, manufacturer's drawings, etc. After implementation, approved design/configuration change information is transferred onto permanent drawings by a designer or drafter and peer reviewed and initialed as being checked by another designer, drafter or responsible design supervisor. New drawings or revisions_to exi~ting drawings receive final approval by the responsible design supervisor or authorized designee.

Specifications and changes thereto for items covered by the QA program are prepared by Nuclear Engineering, and are reviewed by PA Supplier fi:33e33ment for QA content.

eA PA review assures that the documents are prepared, reviewed, and approved in accordance with company procedures and that the documents contain the necessary QA requirements, such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results.

The Station Operations Review Committee (SORC) reviews proposed changes affecting nuclear safety and makes recommendations concerning implementation of the change to the station general manager. The design change process provides for signof f of the design change by the appropriate department head for the purpose of identifying required procedure change. If the proposed modification involves a Technical Specification change or is considered by the SORC to involve an unreviewed safety question (10CFR50.59), the matter is submitted to the Nuclear Review Board (NRB) for a determination of its safety implication before a license change request is submitted for NRC approval.

During the preparation of design changes, Nuclear Business Support assigns a project manager, as necessary. The project manager leads a project team. The project team consists of members of various 17.2-19 SGS-UFSAR Revision 16 January 31, 1998

I -

organizations, both internal and external to Nuclear Engineering. The project team members are responsible for providing technical and administrative input to the entire design change process, which consists of design, installation, testing, and closeout phases. The technical and administrative input is guided by the requirements of those organizations which comprise the project team. The project manager ensures that the specific requirements of each organization on the project team are considered to ensure the overall quality of the product.

Po:i: design changes: pirnpo:r.t;~~*~ to safe~, the QA :i:ep:i:esentati1;1e on the p:i:oject team p:i:ovides input and ass1:1:i:es that design changes include qualitl' ass1:1rance

i:eq1:1i:i:ements s1:1ch as inspection and test :i:eq1:1i:i:ements, acceptance l:eq1:1i:i:ements, test :i:es11lt documentation, and pl:oject team co:n:i:pliance with compaIIl' p:i:oced1:1res d1:1l:ing p:i:epal:ation, :i:e1;1iew, and app::r:ottal of design changes

• ~. ~ .. , .

QA will verify inclusion of gualityreguirements in: selected design changes through period:Lc assessment*arid*inspection.

Updating of records, including drawings, blueprints, instructions technical manuals, and specifications resulting from design changes, is the responsibility of the Senior Vice President - Nuclear Engineering. Design change procedures provide for the timely update of affected drawings following design change implementation to reflect as-built configuration.

17.2.4 Procurement Document Control Procurement documents and changes thereto for the purchase of Q-Listed material, equipment, or services are reviewed and approved by ~ PA prior to issuance by the Purchasing Department to the prospective supplier. ~ PA review assures that spare and replacement parts and services are procured using controls which are commensurate with current QA program requirements.

17.2-20 SGS-UFSAR Revision 15 June 12, 1996

The review also assures that procurement documents adequately and correctly:

1. Identify applicable QA program requirements.

2. Reference applicable regulatory requirements, codes, and standards.

3. Provide right_ of access _for source surveillance and audit by f2H PA or its agents.

4. Provide for required supplier documentation to be submitted to PSE&G or maintained by the supplier, as appropriate.

5. Provide for PSE&G review and approval of critical procedures prior to fabrication, as appropriate.

Procurement documents require suppliers and contractors of other than commercial-grade items to provide services or components in accordance with a QA program that complies with applicable parts of 10CFR50, Appendix B. The requirement for notifying PSE&G of procurement requirements that have not been met is conveyed to the supplier through the standard warranty provision contained in each purchase order. In addition, where 10CFR21 is imposed, suppliers are required to comply with applicable reporting requirements.

17.2.5 Instructions, Procedures, and Drawings Organizations engaged in Q-Listed activities are required to perform these activities in accordance with written and approved procedures, instructions, or drawings, as appropriate.

Simple, routine activities that can be performed by qualified 17.2-21 SGS-UFSAR Revision 10 July 22, 1990

personnel with normal skills do not require a detailed written procedure.

Complex activities require detailed procedures. The designation of those activities requiring detailed procedures is made by cognizant department heads and, as a minimum, complies with applicable requirements of Regulatory Guide 1.33.

Procedures include, as appropriate, scope, statement of applicability, references, prerequisites, precautions, limitations, and checkoff lists of inspection requirements, in addition to the detailed steps required to accomplish the activity. Instructions, procedures, and drawings also contain acceptance criteria where appropriate.

The appropriate general manager or director is responsible for assuring that procedures are prepared, approved, and implemented in compliance with the Nuclear Administrative Procedures Manual. Documents affecting nuclear safety are reviewed by the SORC for technical content, b~ QA £or QA requirements, and are approved by the responsible station department manager or his designee.

q~assessesselected documentsaff~cting nuclear safety to ensure

':L!lc~iporation of guali ty regu:Lre~ents through periodic assessment and

• inspect:Lori. activities conducted by QA personnel or personnel matrixed t6 QA; Matrixed personnel* are qualified in accordance with the QA training* proqram or bther eguilvalent department training.

The Director - Nuclear Business Support is responsible for issuing specifications, drawings, blueprints, procedures and administrative and technical manuals associated with structures, systems, and components covered by the QA Program. Approved and implemented modifications and design changes are incorporated in these reference documents for the life of the station.

Master lists of current editions or revisions of these documents are maintained by Nuclear Business Support and are available at the station to assure that only current and approved referenced documents are used.

QA reviews and appro~es selected procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair az:ui. chanqes .. t~ereto through periodic*. as~eif::SID.ent ;;;.!ld inspecti'?n. activities.

Changes to these doc1:1ncents are also re1riewed and approved. In addition, QA is responsible for review and approval of selected specifications, test procedures, and results of testing through periodic assessment*and inspection activities. 17.2-22 SGS-UFSAR Revision 16 January 31, 1998

17.2.6 Document Control

• Instructions, procedures, drawings, and changes thereto are reviewed for the inclusion of appropriate QA requirements, approved by appropriate levels of management of the PSE&G organizations producing such documents, distributed on a timely basis to using locations.

and Measures are provided for the timely removal of obsolete or superseded documents from the using location. Supplier documents are controlled according to contractual agreements with suppliers.

The following is a generic listing of key documents for the operational phase, showing minimum organization responsibility for review and/or approval, including changes thereto:

1. Design specification - Nuclear Engineering, ~PA.

2. Design modification, manufacturing, construction, and installation drawings - Nuclear Engineering, Nuclear Maintenance, station operations.

3. Procurement documents - Initiating NEU organization, Nuclear Business Support, ~ ,PA.

4. Nuclear Administrative Procedures Manual - NEU organizations responsible for implementation, QA.

5. NEU second-tier manuals, including station administrative procedures

- Cognizant department head, and selected manuals and procedures by QA.

6. Maintenance, modification, and calibration procedures for Q-Listed designated station work activities - Nuclear Maintenance.

7. Operating procedures - Station operations.

17.2-23 SGS-UFSAR Revision 16 June 12, 1996

B. UFSAR - Licensing and Regulation and other NBU organizations responsible for implementing applicable sections. In addition, QA reviews subsequent changes to the UFSAR sections to the extent necessary for assuring compliance with applicable QA program requirements.

9. Maintenance, inspection, and testing instruction - NBU implementing organizations.

10. Post-modification test procedures - Nuclear Engineering

11. Design Change Requests - Nuclear Engineering, and selected DCRs/DCPs.

f1y_QA

'*w ** ***** *' * ***~ "'

QA involvement in the work activity includes review of selected work procedures p:cio:c to a-pp:coval to ~ssess-th~ for-designation of independ~J:l.t inspection hold points (see Section 17.2.10), observation of selected work activities, and review of 'selee:t~d completed safety-related Work Orders on-a sampling basis, and during periodic QA sn:cveillance and assessments: and inspections.

The establishment and maintenance of a document control system for all instructions, procedures, specifications, and drawings received from the NBU or prepared at the station for use in operating, maintaining, refueling, or modifying items and services covered by the QA program is the responsibility of the Director - Nuclear Business Support. The Nuclear Administrative Procedures Manual describes the controls for specific documents. Control of station practices is included in the administrative procedures authorized by the responsible department managers. Measures are established to assure that administrative procedures are up to date, properly authorized, changed only after the required review and approvals are obtained, and distributed to appropriate personnel. Design change procedures provide for the timely update of affected drawings, following design change implementation, to reflect as-built configuration. Computerized databases maintained by the NBU organization are used to control drawings, specifications, procedures and instructions .

17.2-24 SGS-UFSAR Revision 16 January 31, 1998

Controls of software affecting nuclear safety are identified in the Nuclear Administrative Procedures Manual. These controls are based on applicable guidelines provided by the NRC and include software review and approval as well as access controls to prevent unauthorized software changes.

17.2.7 Control of Purchased Material, Equipment, and Services

~ PA maintains an up-to-date listing of approved suppliers of material, equipment, and services covered by the QA program. This list identifies suppliers and contractors that have demonstrated the ability to supply acceptable material, equipment, or services. The list includes manufacturers of commercial-grade items. All QA program procurements are made from approved suppliers.

The responsible engineer and ~ RA personnel select and evaluate prospective bidders and suppliers. The responsible engineer determines the technical competence of the supplier, while~ PA evaluates the prospective supplier's QA program for the capability of meeting applicable requirements of 10CFR50, Appendix B, and for extending applicable program requirements to subtier suppliers.

Qualified~ PA personnel evaluate the prospective supplier's QA capability using one or more techniques, including but not necessarily limited to:

1. Evaluation of supplier's or contractor's procedures or manuals and

'siqnificant J~ :. e. ', no:z:i-:-eic:J.i toriG\l) changes thereto.

2. ASME code stamp approval.

3. Nuclear Utility Procurement Issues Council (NUPIC) or Nuclear Fuel Users Forum (NFUF) Audits.

4. Satisfactory past history of providing similar items.

17.2-25 SGS-UFSAR Revision 15 June 12, 1996

5. Survey of supplier's facility .

• The evaluations of the prospective suppliers are conducted using standard checklist form designed to include the 18 quality criteria of 10CFR50, Appendix B, as appropriate.

Surveys of suppliers' capabilities include evaluation of management systems, manufacturing processes, and adherence to QAffl'r! procedures. The results of supplier evaluations are documented by the appropriate checklist form and filed.

Supplier control is maintained through a planned inspection, monitoring, and audit program by ~ PA.

~ PA and the responsible engineer conduct a review of the manufacturing process for complex manufactured items, such as pumps, valves, heat exchangers, vessels, electrical panels, etc. This review establishes critical inspection points and establishes a notification point program for the identified inspection or surveillance activities. The established inspection or surveillance activities are implemented by qualified ~  ?~ personnel or ~

PA agents. Commercial grade items are dedicated in accordance with recognized industry standards, e.g. EPRI NP-5652.

Monitoring of suppliers/contractors during fabrication, installation, modification, rework, repair, inspection, testing, and shipment of Q-Listed materials, equipment, and services is conducted by qualified ~ PA personnel or~ PA agents at the supplier's/ contractor's facility or at the generating station. Surveillances are conducted in accordance with written procedures and are designed to assure conformance with procurement requirements, in accordance with the safety significance of the item or service.

Periodic evaluations of the supplier/contractor quality program are also conducted, consistent with the importance or complexity of the

• SGS-UFSAR 17.2-26 Revision 15 June 12, 1996

parts, and components received can be properly identified. The identification is directly marked on the item or on records traceable to the item. The data review conducted at receiving assures that proper documentation of received items is available. Materials and items received without proper identification are tagged or segregated until satisfactory documentation and identification is obtained.

Procedures require that Q-Listed materials, parts, and components be marked or otherwise identified and that such identity be maintained either on the item or on records traceable to it throughout receipt, storage, installation, and use. Protection against use of incorrect or defective items also is provided.

Material identification and traceability is maintained for rework, repairs, and modifications throughout operation.

Identification and control of materials, parts and components are the responsibility of Nuclear Maintenance, Nuclear Engineering and Nuclear Business Support. Procurement document controls are the responsibility of Quality A55urance PA. Receipt, storage, installation, inspection and test activities are the responsibility of Nuclear Business Support, QA, PA and Nuclear Maintenance.

17.2.9 Control of Special Processes Special process controls provide for the use of qualified procedures, equipment, personnel, and documentation of satisfactory completion of an activity. Special processes are generally those processes where direct inspection is impossible or disadvantageous.

Procedures have been established for special processes such as welding, brazing, soldering, concreting, protective coating, cleaning, heat treating, and nondestructive examination (NOE) to assure compliance with codes and design specifications. The Senior Vice President - Nuclear Engineering is responsible for preparing special process procedures such as concreting, protective coating and cleaning, while the 17.2-28 SGS-UFSAR Revision 16 January 31, 1998

General Manager - Nuclear Maintenance is responsible for preparing specifications for processes such as welding, brazing, soldering, and heat treating. Nuclear Engineering is responsible for preparing specifications for nondestructive examination (NOE). These specifications are reviewed and approved by the Nuclear Maintenance Code Assurance Code Specialist for necessary QA program requirements.

QA monitoring assessments and audits assure that qualification of special processes, equipment, and personne~ have been satisfactorily performed.

Procedures for implementing the requirements of the specifications are prepared either by the NBU or by supplier personnel and are reviewed by a qualified specip.list QA and the 11ppropriate general 1ttlll!llger, or their designee, with the exception of special process procedures prepared by code suppliers holding a valid_ certificate of authorization.

spec:iailst is a person whq has cerl:::ified pro:fIClenC::y iri th~ area of review

'(e.g., personf1el reviewing NDE procedures ar_~ required to have Level IIT c~rtific~tion lrr the subject NDE area, and personnel reviewing other procedur-es or report's are requirE}d_ to be qualified in accordance with PSE&G' s Engineering SuppC?rt Personnel Programf:

• Qualification records of-procedures, equipment, and personnel associated with special processes are retained as stated in Section 17.2.17.

17.2.10 Inspection A planned inspection program is conducted and documented by personnel appropriately qualified in accordance with Section 17.2.2. The inspection program verifies conformance to the established procedure, code, or standard, consistent with the item's or activity's importance to safety.

The inspection program for maintenance and modification activities is based upon the following three important levels of inspection:

1. Worker Checks - Quality cannot be achieved unless the worker performs the activity in a quality manner. The worker is the individual best able to control the quality of work beLng performed. Work steps that contain elements impacting plant equipment or systems have provisions for signoff by the worker. This worker signoff establishes accountability for the activity and is 17.2-29 SGS-UFSAR Revision 16 January 31, 1998

acknowledgement that the activity has been performed as specified in the work step.

2. Supervisory Inspection - Although the work supervisor may have overall responsibility for the conduct and performance of the work activity, certain conditions at the work location require supervisory inspection to increase confidence that work activities are completed as specified through familiarity of the work activity, work group, or past experience. Supervisory inspections are established in the appropriate work procedure and accomplished through direct observation of the work activity.

3. Independent Inspection - Independent inspections are not intended to dilute or replace the responsibility of the worker check or supervisory inspection for quality of work. Independent inspections provide the maximum confidence attainable that the work activity has been performed in accordance with the overall objective. Typical guidelines Gui.del_ines for establishing independent inspections include conditions simila:i:

to the following.

Wo:i:k activity affecting :i:edundant equipntent or potentiall:'l catising cascading failn:i:e.

Retest l"lill not: ve:i:ify the applicable att:ribtite.

Establishing a baseline in a nel"I p:i:ocess o:i: p:i:ocedtire.

It is deemed necessa:i:y t:o maintain confidence in the l"l'ork p:i:ocess.

This gnidance is considered b:'l the :i:esponsible Qfi organization in the establisl11nent: of inspection activities. are defined in the 'QA program_ manual;.

17.2-30 SGS-UFSAR Revision 9 July 22, 1989

Independent inspections are identified as Inspection Hold Points (IHPs) in the applicable work instructions and are performed by gua1ified individuals independent of the work activity. IHPs cannot be passed without authorization from the applicable management representative responsible for the inspection activity.

General guidelines for the inspection criteria are established by QA and incorporated into various administrative and work instructions.

Independent inspections are performed by QA or other qua1ified individuals who are independent of the work activities. If the individuals performing inspections are not part of the QA organization, the inspection procedures, personnel qualification criteria, and independence from undue pressure, such as cost and schedule, are reviewed for acceptability by the QA organization prior to initiation of the activity.

Work procedures and inspection instructions include, as required, characteristics to be inspected, method of inspection, acceptance criteria, required measuring and test equipment, and required reference documents.

Documentation includes inspection identification and results of inspection performance.

As a result of its review, the Station Operations Review Committee (SORC) may recommend additional or different hold points to the organization performing the work activity.

Periodic inspection, other than IHPs, is performed by qualified individuals other than those who performed or directly supervised the activity being inspected. 'f'hese typicallj? include periodic inspections of the following.

1. Storage areas.

2. Housekeeping {general) .

17.2-31 SGS-UFSAR Revision 11 July 22, 1991

3. Fire p:rotection eq11ipment.

4. Special handling tools and eq11ipment.

5. NDE vis11a3: inspection :req11i:c:ed b~ the inse:c:viee inspection p:c:og:ram.

Typical periodic inspections are described in QA Program procedures ..

An independent organization shall perform NOE visual inspection as required, using qualified individuals other than those who performed or directly supervised the activity.

When inspections are performed by individuals other than those who performed or directly supervised the work, but who belong to the same work group, and the activity involves breaching a pressure-retaining boundary, the quality of the work is demonstrated through appropriate testing, unless restrictions such as ALARA considerations prevent such testing.

The applicable inspection and retest requirements necessary to assure that modifications, rework, or repairs have been accomplished correctly are included in the design change package, work order, or procedure. The inspection and retest requirements for modification, rework, and repair are based on the original inspection and test program, as well as the nature and scope of the modification or repair activity.

Evaluation and review of inspection results are conducted by personnel certified Level II in ANSI/ASME N45.2.6 and SNT-TC-IA, as applicable.

A planned and documented QA monito:ring performance-based inspection program is conducted by QA for sel:ected quality program activities, including the inspection program and personnel qualifications. Monitoring of the implementation of the QA program by station and site contractor personnel is conducted by QA, in addition to offsite supplier activities as appropriate.

Conditions adverse to quality found during the conduct of monitoring are brought to the attention of the management responsible for the activity.

17.2-32 SGS-UFSAR Revision 15 June 12, 1996

The Manager Q11alit~ Assessment, or his designee, A representative from QA routinely attends and participates in plant work schedule and status meetings to assure that they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage relative to procedural and inspection controls, acceptance criteria, and QA staffing and qualification of personnel to carry out QA assignments.

17.2.11 Test Control Q-Listed equipment and components that must be tested periodically to assure satisfactory performance, or have been replaced, modified, or repaired, are t~sted by qualified personnel in accordance with written procedures that provide acceptance criteria based on requirements contained in applicable design and procurement documents.

Provisions are implemented that assure that nonconformances are corrected or resolved prior to the initiation of the preoperational test program on the item.

Retest requirements are provided by engineering specifications and/or the responsible engineer, or both as were the original test requirements. The Nuclear Engineering, Nuclear Maintenance and operations departments are responsible for preparation of test procedures incorporating the engineering parameters.

Test procedures prescribe, as applicable:

1. Prerequisites, including completeness of test item(s).

2. Instructions for performing the test.

3. Instrumentation and equipment for conduct of the test adequate to the test objective.

4. Suitable environmental conditions and adequate test methods.

17.2-33 SGS-UFSAR Revision 16 January 31, 1998

procedures control the application and removal of tags and are designed to prevent operation of valves and/or switches that could result in personnel hazard or equipment damage.

Valve and equipment status boards or logs are maintained to indicate status.

17.2.15 Nonconforming Materials, Parts, or Components Organizations involved in material receipt, installation, test, design modification, and other operating activities are responsible for identifying and documenting nonconformances. Nonconforming materials, where practical, are segregated to prevent installation or use until proper approvals are obtained. Materials, parts, or components that have failed in service are identified and, where practical, segregated. Procedures control the application and removal of tags.

Documentation of the nonconf ormance includes a description of the nonconformance, review by Ope:rat:ions S1:1pe:rint:endent:/Cont::rol Room S1:1pe:r~isor OS/CRS li.c~!ls;~d Senior.Re:act:<JiC:Ji,~Fato,i for Limiting Condition for Operation

• (LCO) applicability when appropriate and the disposition and inspection or retest requirements, as appropriate. The Action Request.* (Notification):

identify <:l;d dispositi<Jn noncon:fofmances; as appropriate f~'the~condit:ion.

are used t6 The mal.ntenancep.:i::ogramwill be used to dispcisition nonconformi?g*materials, condition by replacement in kind or other. standard* maintenance.practices.

Retesting will.be.in. accordance* with normal post-maintenance testing, and pci~t:~1Il<:L:ii:ite~i:ll1C:~ . ope~~:it:it:Y*ii:;;~~~ting p~a:c:t::ic:i:s~ . QA: will :v~~{:f}T. the si:ttisfactocy *+/--esoltition .*of.. i:iuch nonconformances, on* a ~~lect.,,;cf:bii.~:i.s *; through

• its normal maintenance. program assessment and *inspection activities.

The responsible Engineer dispositions each nonconformance report: niaterials, parts, or components that are to . . be repaired to other than cuirent design

~P*ecif.iC~tions or*. to be **u~~d as-i~.

Dispositions for ~repair to other than current desiqri specifications": or "use-as-is" are required to be reviewed and

.,...... . .. ,.... .,., -**** ****-* *****~

approved by QA prior to implementation as required per NBU procedure. Rework or-rgepair of nonconforming material, parts, or components is inspected or retested, or both, in accordance with specified test and inspection

requirements established by the responsible engineering representative, based on applicable requirements. QA or PA shall verify the satisfactory completion of the disposition of these nonconformances.

QA and other organizations in the NE'Ef Nuclear Business Unit review selected nonconformance reports for quality problems, including adverse quality trends, and initiate reports to highe:c ;;;_.pp~opriate levels of management, 17.2-37 SGS-UFSAR Revision 16 January 31, 1998

identifying significant quality problems with recommendations for appropriate action.

17.2.16 Corrective Action Organizations involved in activities covered by the QA program are required to implement corrective action for significant conditions adverse to quality (SCAQ) and conditions adverse to quality' (CAQ), identified within their scope of activity. Such conditions are documented and controlled by the issuance of an action request. The QA Co,:r:r:ecti~~ Ac:tion Szonp i:ie;;p~rtm~I1t reviews s~lf::!Ct~c:l responses to action requestsresponses' for adequacy through assessment and inspection activities. and monitozs these action reqtlests tlu:otlgh Pperiodic summary and status reports of the overall Corrective Action Program are provided to management thr()Uqh either th~rnperfoi:mance indicators or the periodic QA report.

Responses to SCAQ corrective' action reqti:ests, documents are required to include' based on the fotlr elements of co:i::rective action, 1>1hich are:

• 1.

2.

Identification of cause of deficiency.

Action taken to correct deficiency and restllts achieved to date.

3. Action taken or to be taken to prevent recurrence.

4. Date when ftlll compliance was oz 1>1ill be achieved.

Responses to CAQ corrective action documents are required to include:

'1. Identification of deficiency.

2 . , Action taken to correct deficiency.,

For significant conditions adverse to quality, stlch as LERs and HRC/INPO/CMAP findings, the QA Corrective Action G:rotlp Department is involved in the review of stlch conditions and provides oversight to assure timely f ollowup and closeout through assessment and inspection activities.

Items 3 and 4 are optional

Proper implementation of corrective action is verified through surveillancek inspectionk assessment or audit, as appropriate .

The appropriate general manager or director is responsible for assuring that

17. 2-38 SGS-UFSAR Revision 16 January 31, 1998

The NBU is responsible for the permanent storage of station records. The retention period for records; permanent storage location; and methods of control, identification, and retrieval are specified by administrative procedure. Individual station department heads are responsible for submitting applicable department records to the designated location for retention.

17.2.18 Audits Audits of PSE&G and supplier organizations that implement the QA program are performed by QA and PA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records as required.

Performance based assessment should be an integral part of the auditing program and should evaluate activities on the basis of their effect on the safe and reliable operation of the facility. An annual audit schedule is developed to identify the audits to be performed and their frequency. A dominant factor in audit schedule development is performance in the subject area. Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR. Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that at least biennial (2 year) audits of safety related activities are performed. A list of operational phase activities subject to the audit program is provided in Section 17.2.1.1.2.3 and in Table 17.2-1.

Audits are conducted by audit teams comprised of a certified lead auditor, certified auditors, and technical specialists (when deemed necessary).

Audits are conducted using preestablished written procedures and checklists.

Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner. Required corrective action is documented and verified. Followup action, including reaudit of deficient areas, is performed.

The audit program conducted by QA includes, but is not limited to, the following activities covered by the QA program:

1. Operation, maintenance, and modification.

L

2. Preparation, review, approval, and control of design, specifications, procurement and requisition documents, instructions, procedures, and drawings. 17.2-40 SGS-UFSAR Revision 16 January 31, 1998