ML13330B518
| ML13330B518 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/21/1989 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13330B510 | List: |
| References | |
| SCE-1-A-A-11, SCE-1-A-A-11-R30, NUDOCS 8904060363 | |
| Download: ML13330B518 (9) | |
Text
SOUTHERN CALIFORNIA EDISON COMPANY TOPICAL REPORT SCE-1-A CHANGE NOTICE Change Notice Number:
30 Affected Amendment:
11 Affected Pages:17.1-37, 17.1-38, 17.1-39, 17.2-43, 17.2-44, 17.2-45, 17.2-46, 17.2-47 Description of Change:
(1) The process for control of nonconformances discovered during Engineering Construction Project (ECP) activities is revised to be consistent with Station operations nonconformance control program.
(2) The responsibilities for nonconformance disposition approvals are being revised to reflect greater engineering involvement.
(3) References to reportability actions have been updated to reflect current requirements.
Reason for change (including basis for concluding that the change satisfies the criteria of 10CFR50, Appendix B, and the quality assurance program commitments previously accepted by the NRC):
The nonconformance process controls are being revised to reflect a consistent process for handling nonconformances discovered at the Station. The process continues to satisfy the requirements of 10CFR50, Appendix B, Criterion XV.
Change does X does not reduce commitments previously accepted by the NRC.
Approvals:
Manager of Quality Kssurance Vice President Date Submitted to NRC:
March 21, 1989 0576Q
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17.1.15 NONCONFORMISMATERIALS,
- PARTS, OR COMPANTS 17.1.15.1 Scope This subsection describes the measures utilized by SCE to control materials, parts, or components that do not conform to established requirements.
17.1.15.2 Nonconforming Materials, Parts, or Components The measures used to control nonconforming items are described by written procedures, These procedures are prepared and implemented by cognizant SCE organizations performing the work of controlling nonconformances. The SCE Quality Assurance Organization conducts periodic audits to assure proper implementation of the procedures and the effectiveness of the nonconformance controls.
Deviations pertaining to a characteristic of a material, component, system or structure, from those specified in the design documents are treated as nonconformances. Procedures for processing and controlling nonconforming items contain the following requirements:
o Measures to identify the nonconforming item.
o Measures to document the nonconforming item, including cause and corrective action.
o Measures to segregate the nonconforming item l11CN30 from acceptable items, where possible o
Method to review and disposition the nonconforming item, including approval authority.
o Method of notification to the affected organizations.
o Method for evaluating deviations to determine if reportable under the requirements of 10CFR50.55(e) 11CN30 or 10CFR21.
Nonconformances are documented on a Nonconformance Report (NCR),
which is initiated by responsible SCE personnel when a noncon forming item is discovered at a jobsite. NCR's contain the item's.identification, description of the nonconformance, cause, dispositioning activities, inspection requirements, corrective action, approval signatures, and the organizations notified of the nonconformance. An SCE nonconformance log / system is main tained and indicates the status of each nonconforming item.
11CN30 Nonconforming items are segregated from acceptable items, where possible, and maintained in a controlled area until properly dispositioned. Nonconforming items discovered after instal lation of the item are not used until final disposition of the nonconformance and associated disposition implementation.
Stamps or tags are utilized to identify the 17.1-37 Amendment 11CN30
17.1.15.2 (continued nonconformance as described in Subsection 17.1.4.
Nonconforming items may be dispositioned Accept-As-Is, repair, rework, or Reject.
An Engineering Review Process is utilized to provide approval of dispositions associated with nonconforming items discovered at the jobsite where SCE is responsible for the work or where SCE technical review of the nonconformance is required. An SCE Engineering Review Board (ERB) is established on each project for Accept-As-Is and repair dispositions and is comprised of the following members who must unanimously concur on the disposition:
o Quality Assurance Organization (QAO) Supervisor, or designee.
o Project Engineer, or designee.
11CN30 o
SCE Project Engineer or Site Nuclear Engineering Supervisor or designee o
Supplier design representative, where supplier design is involved.
When unanimous agreement cannot be reached among ERB members, the disposition will be determined jointly by the Manager, Quality Assurance, and the Project Manager. The Vice President, Nuclear Engineering, Safety and Licensing shall assign the 7
disposition for a nonconformance when normal processes fail to reach a decision.
For Reject and Rework dispositions, the approval of the following individuals is required:
o QAO Supervisor, or designee.
11CN30 o
SCE Project Engineer or Site Nuclear Engineering Supervisor or designee Nonconforming items may be authorized for conditional use either prior to or after installation, providing the following conditions, as applicable, have been met:
o The NCR specifically describes the activity.
o The allowed activity does not constitute actual use in the sense that the item could be called upon to 4
perform its safety-related function of actually preventing or mitigating the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
o The nonconforming condition will not adversely affect the allowed activity or implementation of the 9
disposition.
17.1-38 Amendment 11CN30
17.1.15.2 (continue*
o Identification and traceability of the item is maintained.
4 o
The authorization is approved by the same ERB members required for the disposition approval.
Depending on contract scope of work assignments, an A-E may be required to implement a similar Engineering Review Process and formulate an (ERB) to work in conjunction with the SCE (ERB).
Interface procedures are developed by both participating organizations in this event.
When the nonconformance report disposition specifies a rework or repair, these actions are accomplished in accordance with approved procedures, drawings, and instructions. The cognizant 4
SCE or A-E quality assurance organization representative verifies that acceptance of the dispositioned nonconforming item is completed by reinspection according to methods initially used. When reinspection methods differ from those initially used, methods at least equal to the original inspection are employed. Items are designated as nonconforming, and are so identified, until repair or rework and the required inspections are satisfactorily performed.
Rejected or scraped items are promptly removed from the jobsite work areas. The status of these items is displayed by 3
appropriate tags. The cognizant SCE or A-E quality assurance organization person verifies the proper use of these tags.
The SCE or A-E design organization responsible for the affected design document reviews and approves Accept-As-Is dispositions for design impact. For an approved disposition, the responsible design organization must issue a written justification for the deviation from the design document or revise the design document in accordance with applicable requirements.
NCR's and associated inspection records are forwarded to the CDM Center for retention purposes. Nonconformance data are 5
periodically analyzed by the SCE Quality Assurance Organization to establish quality trends. The results of these analyses are reviewed by the Manager, Quality Assurance, for possible corrective action and referred to the Vice President, Nuclear 7
Engineering, Safety and Licensing, when a potential serious condition is determined. Deficiencies identified by 10CFR50.55(e) or 10CFR21 are reported to the NRC by the Manager, 11CN30 Quality.Assurance.
A-E's and suppliers must provide nonconformance controls that are equivalent to the controls set forth herein. The four options to disposition nonconformances as described in this subsection are required to be identified, or a suitable alternative scheme used.. Nonconformances dispositioned 1
Accept-As-Is or repair by suppliers must be made part of the 421.11 17.1-39 Amendment 11CN30
17.2.15 NONCONFORMING MATERIALS, PARTS OR COMPOA TS 17.2.15.1 Scope This subsection describes the measures utilized by SCE to control materials, parts, or components that do not conform to established requirements.
17.2.15.2 Nonconforming Materials, Parts or Components The measures used to control nonconforming Safety-Related items are described by written procedures. These procedures are pre pared and implemented by cognizant SCE organizations delegated the work of controlling nonconformances. The SCE Quality Assurance Organization conducts periodic audits to assure proper implementation of these procedures and effectiveness of the nonconformance controls.
Deviations pertaining to a characteristic of a material, component, system or structure, from those specified in the design documents are treated as nonconformances. Procedures for processing and controlling nonconforming items contain the following requirements:
o Measures to identify the nonconforming item including 7
criteria for when to issue a Nonconformance Report (NCR).
o Measures to document the nonconforming item, including cause and corrective action.
o Measures to segregate the nonconforming item from 11CN30 acceptable items, where possible o
Method to review and disposition the nonconforming item, including approval authority.
o Method of notification to the affected organizations.
o Method for evaluating deviations to determine if reportable under the requirements of 10CFR50.55(e),
11CN30 10CFR21, 10CFR50.72, 10CFR50.73 or the Technical Specifications.
17.2.15.2.1 Station and Engineering and Construction Project (ECP) Activities 11CN30 When a nonconforming item is discovered at the Station, an NCR and/or a work order document, as appropriate, will be generated by SCE personnel in accordance with procedural requirements.
Rework/reject dispositions for plant equipment will normally be 1OCN16 controlled by the work order document process.
Nonconformance documentation contains the item's identification, description of the nonconformance, dispositioning activities, 17.2-43 Amendment 11CN30
17.2.15.2.1 (continue )
inspect'ion requirements, approval signatures, and the organiza-10 tions notified of the nonconformance. Cause and corrective CN#16 action are also documented. An SCE nonconformance reporting log/system is maintained and indicates the status of each nonconforming item.
Nonconforming items are segregated from acceptable items, where possible, and maintained in a controlled area until properly dispositioned. Nonconforming items discovered in installed 7
items are evaluated to determine their operability as defined CN#6 by the Technical Specifications and use is controlled until final disposition of the nonconformance and associated disposition implementation.
Stamps or tags are utilized to identify the nonconformance as described in Subsection 17.2.14. Nonconforming items may be dispositioned Accept-As-Is, repair, rework, or Reject.
An Engineering Review Process (ERP) is utilized to provide 5
approval of dispositions associated with nonconforming items.
For the dispositioning of nonconformances, the following approvals are required:
Repair or Accept-As-Is Dispositions o
Quality Assurance Organization (QAO) Supervisor or designee o
Station Technical Manager or designee o
Cognizant Station Functional Manager (Maintenance, 11CN30 Operations, Health Physics, etc.) for non-ECP activities.
o SCE Project Engineer or Site Nuclear Engineering Supervisor or designee for ECP activities Reject or Rework Dispositions o
QAO Supervisor or designee o
Cognizant Station Functional Manager (Technical, Maintenance, Operations, Health Physics, etc) or designee for non-ECP activities.
o SCE Project Engineer or Site Nuclear Engineering Supervisor or designee for ECP activities Nonconforming items may be authorized for conditional use 10 prior to implementation of the final NCR disposition CN#16 providing the following conditions have been met:
o The NCR describes the conditional use.
17.2-44 Amendment 11CN30
17.2.15.2.1(continue) o Use of the item is controlled such that the safety functions of the system are not adversely affected.
1OCN16 o
Identification and traceability of the item is maintained.
o The authorization is approved by the same ERP members required for the disposition approval.
When the nonconformance disposition specifies a rework or repair, these actions are accomplished in accordance with approved procedures, drawings and instructions. SCE quality assurance organization personnel verify acceptability of reworkand repair dispositioned nonconforming items by reinspection according to methods initially used. When reinspection methods differ from those initially used, methods at least equal to the original inspection are employed. The responsible work 11CN30 organization manager is responsible for assuring that rework and repair activities are accomplished in accordance with approved procedures, drawings, and instructions. Items are designated as nonconforming and are so identified until rework or repair and the required inspections are satisfactor ily performed.
Rejected or scraped items are promptly removed from the station work areas. The status of these items is displayed by 10 appropriate documentation.
Quality Assurance Organization CN#16 personnel verify the proper disposition of these items.
The SCE design organization responsible for the affected design 5
document reviews and approves Accept-As-Is and Repair dispositions for design impact.
For an approved disposition, the responsible design organiza tion must issue a written justification for the deviation from the design document or revise the design document in accor dance with applicable requirements.
When the participants in the Engineering Review Process 10 cannot agree, the final disposition is made by the Manager CN#16 of Quality Assurance. Significant nonconformances of unusual complexity or involvement are submitted to the Vice President, 7
Nuclear Engineering, Safety and Licensing for resolution.
NCR's, work order documentation and associated inspection 10 records are forwarded to the CDM Center for retention purposes.
CN#16 Nonconformance data are periodically analyzed by the SCE Quality Assurance Organization to establishquality trends. The results of these analyses are reviewed by the Manager of Quality Assurance, for possible corrective action and referred 17.2-45 Amendment 11CN30
17.2.15.2.1 (Contin d) to the Vice President, Nuclear Engineering, Safety and 7
Licensing, when a potentially serious condition is indicated.
CN#6 Deficiencies identified by 10CFR50.55(e) or 10CFR21 are reported to the NRC prior to issuance of the operating license by the NRC. Thereafter, deficiencies are reported to the NRC in accordance with Technical specification requirements, 11CN30 10CFR21, 10CFR50.72 or 10CFR50.73.
11CN30 17.2.15.2.2 Contractor and Supplier Activities Nonconformances in onsite contractor work are controlled by SCE in accordance with Paragraph 17.2.15.2.1.
Nonconformances dispositioned Accept-As-Is or repair by off site suppliers must be made part of the inspection records and forwarded to the responsible engineering organization for 11CN30 review and assessment. The responsible SCE engineering organization approves these dispositions for SCE procured items.
Conditions adverse to quality discovered by SCE personnel 10 at a jobsite, contractor's manufacturing facility or design CN#16 office, or supplier's manufacturing facility, are processed as described in Subsection 17.2.16.
17.2-46 Amendment 11CN30
17.2.16 CORRECTIVE ACTION 17.2.16.1 Scope This subsection describes the measures utilized by SCE to assure that corrective action is promptly identified and implemented when conditions adverse to quality are determined to exist.
17.2.16.2 Corrective Action As described in Subsection 17.2.15, nonconformance and correct-11CN30 ive action associated with material, parts, or components are controlled at a jobsite by the nonconformance reporting system.
Additionally, a system for initiating corrective action associ ated with conditions adverse to quality is controlled by the SCE Quality Assurance Organization by means of written procedures.
This system implements corrective action system forms to docu-1OCN#20 ment conditions adverse to quality discovered by SCE personnel at the SCE General Office or jobsite, at A-E's design offices, and at NSSS Suppliers and other suppliers' facilities. This corrective action documentation is also used for hardware problems discovered at NSSS Supplier or other suppliers' facilities. Procurement specifications may specify the requirement for SCE approval of nonconforming hardware disposition if discovered by SCE at a supplier's facility.
The corrective action documentation provides for item or system identification, description of the adverse condition, cause of the condition, corrective action to resolve problem, and the corrective action to prevent recurrence as appropriate to the problems identified.
Corrective action documentation is promptly initiated with a request for corrective action directed to the responsible organization as a result of review, inspection, audit or surveillance activities.
The responsible organization to which corrective action docu mentation is directed determines the cause of the adverse condition, the action taken to resolve the problem, and the 10CN#20 action to be taken to prevent recurrence as appropriate to the problems identified. They also provide dates for imple mentation of the corrective action where appropriate. The corrective action documentation is returned to the responsible SCE Quality Assurance Organization Supervisor for review and concurrence. Revised corrective action documentation is requested if corrective action proposed is unacceptable.
Follow-up reviews, inspections, audits, or surveillance are performed by SCE personnel to verify corrective action implementation. Significant conditions adverse to quality, 17.2-47 Amendment 11CN30