ML20065G557

Requests Approval to Change QA Program Description by Transferring Organizational Responsibility for Receipt Insp Function to Matls Mgt Section at Each Station

ML20065G557
Person / Time
Site:	Peach Bottom, Limerick
Issue date:	03/31/1994
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9404130067
Download: ML20065G557 (9)

Text

,

. StLti:n tupp:rt Diputmint ,

e u- 10CFR50.54

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I)ECO ENERGY =gg;;;;;_,, -

965 Chos.1mbrook Doulevard Wayne, PA 19007 5691 March 31,1994 Docket Nos. 50-277 50-278 )

50-352

> 50-353 ~

Ucense Nos. DPR-44

. DPR-55__

NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Centrol Desk Washington, DC 20555

SUBJECT:

Peach Bottom Atomic Power Station, Units 2 and 3 I Umerick Generating Station, Units 1 and 2 ,

Request for Approval to Change the Quality Assurance Program Description by Transferring Organizational Responsibility for the Receipt _.

1 Inspection Function

Dear Sir:

This letter is being submitted in accordance with 10CFR50.54(a)(3), which requires

~

prior Nuclear Regulatory Commission (NRC) approval for changes to the Quality Assurance Program _ description that reduce the commitments contained therein.1 The-

- Quality Assurance Program, as described in PBAPS UFSAR Appendix D, Section 17.2 ,

(7/93) and LGS UFSAR Section 17.2 (11/93),' commit PECO Energy Company (PECO '

Energy) to perform Receipt inspection activities using ANSI N45.2.6 - 1978' certified .

Ouality Verification (OV) personnel from the Nuclear Quality Assurance _(OA)'

Department. Quality Support (OS) personnel also perform some receipt inspection -

activities. PECO Energy is proposing that both OV and OS receipt ins'pections be transferred to the Materials Management Section at each station, and that the NRC

- review and approve this change. This reduction in commitment does not reduce the ,

PECO Energy commitment to quality, nor.to compliance'with 10CFR50, Appendix B.

Receipt inspection performed either by OV or Materials Management personnel is

. organizationally independent of both the vendor producing the items inspected and of-t5e user group. Thus, we do not consider'this to be a peer inspection initiative, a_nd Criteria Vil, Control of Purchased Material, Equipment and Services, and X, inspection,'.

of 10CFR50 Appendix B are satisfied.  ;

[fg' g M 9404130067:94o331 r -

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March 31,1994

, Page 2 This change in commitment is consistent with receipt inspection program changes approved by Region 1 for Baltimore Gas & Electric at Calvert Cliffs.

PECO Energy has developed a transition program to ensure that the receipt inspection process applied to quality assured items will remain at or above the currently provided level of quality. This transition program will involve evaluating, training, qualifying and certifying Materials Management personnel as Receipt inspectors per the requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58.

Materials Management personnel will be evaluated for Level I and ll Receipt inspection Certification. Following the successful completion of a one-week training program, eligible Materials Management personnel will undergo an On-the-Job Training (OJT)

Program, in which they will examine incoming items under the cognizance of currently qualified OV Receipt inspectors, who will continue to perform Receipt inspection for product acceptance. The OJT will continue until the Level lli Examiner (currently assigned from NOA during the transition) has verified and certified the Materials Management personnets' competence to perform Receipt inspections independently.

This transition period is expected to last from three to six months.

Station Materials Management will use performance indicators during and following the transition, to compare levels of product quality-related receipt inspection deficiencies against historical baseline data. Performance indicators will be reported periodically to senior management. NOA will assess this transition via surveillance activity and will continue to include receipt inspection in the scope of quality audits.

Based on this data, adjustments will be made as required to ensure the continued high quality of receipt inspections during and after the transition period.

PECO Energy recognizes that the transfer of the Receipt inspection function from NOA to the line organizations is a significant change, and chose this strategy after extensive research and planning. This proposed change in the PECO Energy OA Program will provide greater effectiveness in the Receipt inspection function because of the following:

. Integration of Receipt inspection with commercial receiving activities will aid in Material Management self-identification and implementation of material handling enhancement opportunities.

. Receipt inspection by Materials Management will expedite notification of Procurement Engineering of incoming product quality problems. Currently, such problems are identified by OV personnel, then routed to Engineering via Mat 9 rials Management.

The additional proposed changes to the OA Program descriptions in the PBAPS UFSAR Appendix D, Rev. 11, 07/93, and the LGS UFSAR, Chapter 17.2, Rev. 3, 11/93, are provided in attachments 1 and 2 respectively.

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- March 31,1994

, Page 3 i l

Preliminary training of Materials Management personnelin Receipt inspection principles and techniques has already begun. However, elimination of receipt inspections by QA personnel for product acceptance will not occur without NRC 1 approval; therefore, we are requesting your prompt review and approval.-

If you have any questions or need additional information, please contact George J. Siefert (610) 640-6768 of my staff.

Ve truly yours,

, H.

George A. Hunger, Jr., Dire [ctor Licensing Section Attachments cc: T. T. Martin, Adminictrator, Region I, USNRC, w/ attachments W. L Schmidt, USNRC Senior Resident in.spector, PBAPS, w/ attachments N. S. Perry, USNRC Senior Resident inspector, LGS, w/ attachments  !

M. C. Modes, USNRC Region I, w/ attachments l

l 1

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l

a

. i

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. PBAPS j I

a

~1 10. -Direct the scheduling, planning, and performance of ,

.~l_ technical monitoring. In the areas of operations, <j l health. physics,- radioactive waste, chemistry,-

1. security,- post-maintenance / modification testing,-  ;

-I surveillance testing, maintenance, fire. protection,' 1 i plant' modifications, and emergency planning. j

'l

] 11. Development and approval'of Monitoring-Guidelines.

'l I 12. Interface with station management to . provide-I feedback and obtain corrective action to identified l problems.

17.2.1.2.3.1.2 Quality Verification Section '

The Quality Verification Section is under the direction l of a Superintendent, who reports to the site Quality-Division Manager.

The Superintendent has the following responsibiliti_es:

1. Provide administrative _ supervision and technical #

1 direction of the activities of the NQA Quality i Verification (QV) personnel.

2. Oversee the inspection _ activities in the areas of receipt incpcction; radwaste/radmaterial packaging, handling, and shipment; maintenance and modifi-cation activities performed on safe.ty-related-equipment.

l 3. Consult with the Assessment Superintendent,-Quality Support- Superintendent, .and .the site Quality-Division Manager when significant problems affecting quality are identified.

.I 4. Overview of the QV Section activities, schedules,:

and results.

5. Identify -the need for the preparation .of NQA-procedure supplements relating to;QV activities.

6. Ensure; that -the~ personnel- involved in the implementation of the QV InspectiontActivities~are-trained, qualified, and certified to perform-assigned activities.

D.11-6 Rev. 11, 07/93

PBAPS

'l 7. Ensure that verification results are documented in accordance with NQA procedures, and unacceptable results are identified and rescheduled in inspections, as appropriate. .

8. Review of work requests for inclusion of QA Plan i requirements and QV activities. J

9. Document conditions adverse to quality resulting from QV activities and verify corrective action.

10. Provide independent verifications in mechanical, electrical, I&C and welding disciplines.

11. Provide visual, liquid penetrant, magnetic particle

, and ultrasonic inspections.

l

12. Coordinate NDE activities with appropriate plant technical and craft supervision personnel. -1 l

17.2.1.2.3.1.3 Quality suppoct Section The Quality Support Section is under the supervision of a Superintendent, who reports to the site . Quality Division Manager. The Superintendent has the following responsibilities:

1. Provide administrative supervision and technical direction of the activities of the Quality Support Section.

2. Consult with the Quality- Verification Superin-I tendent, Assessment Superintendent, and the Site i Quality Division Manager on significant problems affecting quality. .

j 3. Ensure that personnel involved in performing NQA l Quality support activities are trained and l

qualified.

4. Review and coordinate revision of NGA Procedures. I

5. Review of selected Station Administrative Procedures and implementing procedures.

6. Review and approval of procurement documents and technica4-rhptr-i-nepeot-lon-documentes for safety-related items and servicas.

D.ll-7 Rev. 11, 07/93 J

PBAPS 17.2.7.1.3 Evaluation of vendor, supplier, or contractor capabilities are based on records of previous supply or performance and review of quality assurance programs or audit of supplier facilities, practices, or a combination thereof.

17.2.7.144 Review of vendor, supplier or contractor qualifications shall. be assessed at periodic intervals by -NQA -

commeneurate with the importance, complexity, quantity of the product or services being purchased.

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

17.2.7.2 Requisitions for Safety-Related items shall contain a phrase that clearly indicates the quality status of such items.

17.2.7.2.1 Procurement documents shall include the identification of nonconformances that require approval by PEco for disposition.

17.2.7.3 Documentary evidence that material and equipment conform to the procurement requirements shall be available at the site prior to installa'.lon or use of such material, in .

accordance with PBAPS Administrative Procedures. j Mahr6ak Mon 6fjVMT %pTidA j.

17.2.7.4 Receipt inspection is the responsibility of the^NGA Gile 0"ality Di"icica and shall be performed in accordance with the3 NO.'. Preceduras .

Procat emtn4~ ProceNa ch and GuldeWnd 17.2.7.4.1 Receipt inspections are performed to verify that received materials, components or parts conform to the purchase order requirements.

17.2.7.4.2 Receipt inspection includes, as appropriate, visual examination of physical properties, determination and identification of marking or labeling, review and inspection of quality assurance documentation to verify conformance with the purchase order specifications and requirements.

D.11-26 Rev. 11, 07/93

. . /

LGS UFSAR

f. Ensure that items requiring corrective action. are' properly identified and documented in accordance with NQA procedures.

g. Ensure that personnel involved in performing-NQA audits, .

surveillance, and technical monitoring are trained, qualified and certified.

h. Assure timely follow-up of committed corrective action.

1. Assure that corrective action performed in response _to' previously identified conditions adverse to quality,.is adequate and effective to preclude. repetition,

j. Direct the scheduling, planning,' and ' performance of technical monitoring in the areas of operations, health.

physics, radioactive waste, chemistry, security, postmaintenance/ modification testing, surveillance testing, maintenance, fire protection, plant modifications, and emergency planning.

k. Development and approval of Monitoring Guidelines.

1. Interface with station management to provide feedback and obtain corrective action to identified problems.

17.2.1.2.3.1.2 Quality Verification Section The Quality Verification Section is under the direction _ of -a Superintendent who reports to the site. Quality Division Manager. )

The Superintendent has the following responsibilities:

a. Provide administrative supervision and technical- ,

direction of the. activities )f the 'NQA Quality verification (QV) personnel.

b. Oversee the inspection activities.in the areas of-receipt l inepection;- radwaste/radmaterial packaging, handling, and shipment; maintenance and modification activities performed on safety-related equipment.  ;

i

c. Consult with' the Assessment Superintendent, Quality H Support Superintendent, and site' Quality Division. I Manager, when significant prublems af fecting quality' are

H identified. R

d. Overview of the QV section activities, schedules,-and results.

1

e. Identify the need for the preparation of NQA-procedure a supplements relating to QV activities.

17.2-9 Rev. 3 July /93- .;

'l u

LGS UFSAR

.f <

g. Encuro that verification' results aro documnnted ' in accordance with NQA procedures, and unacceptable results are identified and rescheduled in inspections, as appropriate.

h. Review of work requests for inclusion of QA Plan requirements.and QV activities.

1. Document conditions adverse to quality resulting from QV activities and verify corrective action.

j. Provide independent verifications in mechanical, electrical, I&C and welding disciplines,

k. Provide visual, liquid penetrant, magnetic particle, and ultrasonic inspections.

1. Coordinate NDE activities with appropriate plant technical and craft supervision personnel.

17.2.1.2.3.1.3 Quality Support Section The Quality Support Section is under the supervision of a Superintendent who reports to the site Quality Division Manager.

The Superintendent has the following responsibilities:

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

b. Consult with the Quality Verification Superintendent, Assessment Superintendent, and the site Quality Division Manager, on significant problems affecting quality.

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

d. Review and coordinate revision of NQA Procedures.

e. Review of selected Station Administrative Procedures and Implementing Procedures.

f. Review and approval of procurement documents and-teshnical roccipt incpection documento for safety related items and services. .

g. Review NCRs for conditions adverse to quality.

h. Tracking and trend analysis of Verification and Monitoring Activity reports and CARS.

1. Document conditions adverse to quality identified during 1 Quality Support activities. l l

i l

17.2-10 Rev. 3 July /93

. PBAPS 13.3.5.2 Quality Assuranca R3ceipt Inspection Personnel Training V See belc4

'a % uclear N Operations Quality Assurance Division Pr yodurd QAD - 00, titled " Training, Qualifying and rtTfication of Nuclea rations Quality Contr sonnel", defines the qualificat o r pe n in this group.

b. Periodic rea fication of P AN(SI 74 receipt inspection o[el in accordance with 2.6-1973 is required by Procedure QADP-100.

13.3.5.3 Reactor Engineering Personnel Training

a. Each reactor engineer is involved in sufficient startups to insure that he retains his proficiency in reactor engineering startup activities. This provides on-the-job experience and reinforcement of previous training.

b. Before any unit startup, discussions are held as appropriate to review new procedures or methods which may be pertinent to reactor engineering startup activities.

Unusual conditions and potential problems are discussed to insure a clear understanding of the startup procedure.

c. Non-licensed reactor engineers participate in training programs covering BWR systems and technology including automatic depressurization, emergency core cooling, fuel and core configuration, instrumentation, radiation monitoring, and other major systems.

13.3.5.4 Results Engineering Personnel Training

a. Test engineers normally participate in training programs covering BWR systems and technology.

b. A meeting is held each normal workday morning to' discuss plant status and job assignments. Any special problems and possible solutions are discussed.

13.3.5.5 Health Physics and Chemistry Personnel Training

a. PECO health physics technicians can progress through four levels of qualification based on training and plant experier.ce. Progression from

)( Mahrirds baMjcNienh pg rSonne f Wjlf bc evAf a .,

tres t /W I M N C QCCorbo V MI 2 ~

13.3-14 Rev. 8 01/90