ML18106B058

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Revises 981019 Request to Change QA Program for Hope Creek & Salem Generating Stations,In Response to NRC 981218 Rrai. Details Re Revised Proposal & Responses to NRC Questions, Including Proposed UFSAR Changes for Plants Encl
ML18106B058
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 02/10/1999
From: Mcmahon J
Public Service Enterprise Group
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LR-N990055, NUDOCS 9902180012
Download: ML18106B058 (35)
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Text

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  • Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit FEB 1 0 1999 LR-N990055 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

REVISED 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 This letter revises the request to change the Quality Assurance (QA) Program for the Hope Creek and Salem Generating Stations that was submitted by Public Service Electric and Gas Company (PSE&G) on October 19, 1998. The revisions are in response to questions posed in the NRC's December 18, 1998 Request for Additional Information. Details concerning the revised proposal and responses to the NRC staff's questions are contained in Attachment 1. Attachments 2 and 3 include revised UFSAR pages that replace the corresponding pages of the original submittal. The changes made since the October 19, 1998 submittal are identified in bold font. If you have any questions regarding this submittal, please contact Mr. C. Manges at (609) 339-3234. Director - Quality/Nuclear Training/ Emergency Preparedness Attachments (3) --- -- - ---9902raoo12--990210 ;r--~- ---- ---....,., ~ I , PDR P ADOCK 05000272 PDR,_, I 

                                                                                                 \

The power is in your hands. 95-2168 REV. 6/94

-*Document Control D . C LR-N990055 Mr. H. Miller, Administrator - Region I

  • FEB 10-1999 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)

USNRC Senior Resident lnspedor - 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

~ocument Control D . LR-N990055 HOPE CREEK GENERATION STATION AND SALEM GENERATING STATION UNIT NOS. 1 AND 2 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 RESPONSES TO NRC STAFF QUESTIONS The following provides PSE&G's response tO the NRC's comments concerning the changes to the Hope Creek and Salem Quality Assurance Programs that were proposed in LR-N980154, dated October 19, 1998. The NRC comments were included in the NRC's December 18, 1998 request for additional information (RAI). Each of the NRC's comments is repeated verbatim and followed by PSE&G's response to the comment. NRC RAI Comment 1: "PSE&G proposed the following 'editorial' changes to UFSAR Section 17 .2.1.1.1 on Page 17 .2-5 for the Hope Creek Generating Station (HCGS) and Page 17 .2-4a for the Salem Nuclear Generating Station (Salem): Responsibilities of the Manager-Corrective Action, Emergency Preparedr:iess, and Instructional Technology (Manager-CA, EP & IT) include the following:

1. Administration of the Corrective Action Program
2. Mana9eR=1ent dir:estien and sentrnl ef all sellestien and Overall management of the trending of Corrective Action reports related to human, organizational, and programmatic performance.
3. l#erier:R=1in9 statistisal analysis tr:end r:eperts f9r: R=1ana9eR=ient.

Page 1 of Attachment 1 to PSE&G's October 19, 1998, letter to the NRC states that 'Department managers are responsible for trending their individual departments and Engineering is responsible for equipment failure trending.' The proposed change does not fully describe those individuals responsible for the corrective action and trending programs for areas other than Corrective Action reports related to human, organizational, and programmatic performance. Further, the proposed deletion of Item No. 3 eliminates the responsibility for the performance of statistical analysis trend reports. Please provide additional discussion and address those individuals responsible for trending equipment failures and Corrective Action reports not related to human, organizational, and programmatic performance in the proposed QA Program change." Page 1of9

~ocument Control D . LR-N990055 PSE&G Response to NRC RAI Comment 1: Section 17.2.16 is being revised to state that Engineering and Maintenance are responsible for equipment failure trending and that department managers are responsible for identifying trends within their respective organization. The Manager-CA, EP & IT will be responsible for overall management of the trending of Corrective Action reports related to human, organizational, and programmatic performance as proposed in the October 19, 1998 submittal. Section 17.2.16 is also revised to repeat the responsibilities of the Corrective Action Group such that Section 17 .2.16 provides a complete description of the trending of corrective action requests. With the identified changes to Section 17 .2.16, the individuals responsible for corrective action trending are fully described. Responsibility 3 under the Manager-CA, EP & IT that was proposed for elimination in the October 19, 1998 submittal is being retained; however, the responsibility is being revised to require providing trend data reports rather than statistical analysis trend reports to management. NRC RAI Comment 2: "PSE&G proposed the following 'editorial' changes for the responsibilities of the Manager, Quality Assessment, in UFSAR Section 17.2.1.1.1 on Page 17.2-6 (HCGS) & Page 17.2-5 and 17.2-6 (Salem): ~ 13. PerfQrm Cede related ins~estiens, test ~erfQrmanse, and revievt ef Conduct performance based inspections of selected Code related activities, observe and perform selected testing, and review selected weld procedures for inclusion of QA requirements. ~14. Perform design shange ~aska9e pre-implementation review and closure review for compliance with Inspection Hold Points (IHPs) requirements for selected design change package by periodic assessment and inspection. Also, PSE&G proposes the following changes to UFSAR Section 17.2.6 on Page 17.2-25 (HCGS) and Page 17.2-24 (Salem): QA involvement in work activity includes review of selected work procedures ~rier te a~~reval to assess the~ designation of independent inspection hold points (see Section 17.2. 1 0), observation of selected work activities, and review of selected completed safety-related Work Orders en a sam~lin9_ basis, and during ~eriedis QA s1:1rveillanse and assessments and inspections. Page 2of9

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  • In addition, PSE&G proposed significant changes to the nonconformance control LR-N990055 program for HCGS and Salem as discussed in UFSAR Section 17 .2.15, 'Nonconforming Material, Parts, and Components' UFSAR Page 17.2.39 (HCGS) and Page 17.2.36/37 states, in part, that QA will verify the satisfactory resolution of nonconformances on a selected basis through its normal maintenance program assessment and inspection activities.

Further, in UFSAR Section 17.2.5 on Page 17.2-23 (HCGS) and Page 17.2-22 (Salem), PSE&G proposed a change that would permit QA to review selected documents affecting safety to ensure incorporation of quality requirements through periodic assessment activities conducted by 'QA personnel or personnel matrixed to QA'. Throughout the proposed revision to the HCGS and Salem QA program descriptions, one change has been made in several places and that change permits QA to perform certain activities on a selected basis. Please describe the criteria that will be used by QA for the above selection processes. In general, the staff would expect QA to select activities based ori their safety significance using probabilistic and deterministic methods and data obtained from various trend reports." PSE&G Response to NRC RAI Comment 2: PSE&G plans to select areas for assessment, activities for inspection, and documents for review using a performance based methodology. This methodology will consider the following factors:

  • Risk significance (high risk significant equipment, Maintenance Rule risk significant systems, etc)
  • Past performance (including results of program, equipment, and human performance trends)
  • Complexity of tasks
  • Frequency of evolution
  • Interfaces (between groups, departments, contractors, etc.)

NRC RAI Comment 3: "There is a conflict between the provisions contained in UFSAR Section 17.2.2 on Page 17.2-13 (HCGS) and Section 17.2.1.1.1 on Page 17.2-6 (HCGS). Page 17.2-13 states that 'all' revisions to NAPs are reviewed by QA and Page 17 .2-6 implies that QA only reviews selected NAPS." Page 3of9

~ocument Control D.

  • LR-N990055 PSE&G Response to NRC RAI Comment 3:

NAPs are the Nuclear Business Unit's upper tier administrative procedures. As stated on Page 2 of Attachment 1 of the October 19, 1998 submittal, in-line review of NAPs will continue to be required as specified in Responsibility 8 under the Manager - QA. Responsibility 9 is intended to apply to lower tier administrative procedures. Responsibility 9 is being revised by inserting the phrase "lower tier" to clarify that the administrative procedures being reviewed on a selected basis are the lower tier administrative procedures. NRC RAI Comment 4: "PSE&G proposed a change for the QA involvement in the design change process in UFSAR Section 17.2.3 on Page 17.2-21 (HCGS) and Page 17.2-20 (Salem) that eliminates the criteria used by QA to select design changes for which it will provide input for certain quality functions. Please discuss the criteria that will be used by QA for the selection of design changes to review to verify proper inclusion of quality requirements. As a minimum, this UFSAR section should require that procedures be established and describe/contain provisions that describe how QA selects design documents for review to assure that the documents are prepared, reviewed, and approved in accordance with company procedures and that the documents contain the necessary quality assurance requirements such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results." PSE&G Response to NRC RAI Comment 4: A sentence has been added to state that procedures have been established that describe the selection criteria for design documents. The response to Comment 2 describes the performance based methodology that PSE&G plans to use in selecting design documents to be reviewed. NRC RAI Comment 5 "In UFSAR Section 17.2.5 on Page 17.2-23 (HCGS) and Page 17.2-22 (Salem), PSE&G proposed a change that eliminates the provision for QA to review certain procedures in the Nuclear Administrative Procedures Manual to ensure that appropriate QA requirements are specified. Further, in the same UFSAR section, PSE&G proposed that QA review selected documents affecting safety to ensure incorporation of quality requirements through periodic assessment activities conducted by "QA personnel or personnel matrixed to QA. Matrixed personnel are qualified in accordance with the QA training program or other equivalent department training program.' Page 4 of 9

0 Document Control oA

  • LR-N990055 Periodic inspection and assessment by QA would require the QA individuals performing such inspection and assessment activities be qualified and certified in accordance with standards such as ANSI N45.2.6 and ANSI N45.2.23. The proposed change to UFSAR Section 17.2.5 would permit personnel matrixed to QA to perform such activities. The organization chart and UFSAR description does not appear to describe this matrixed relationship. It appears that the only organization that this would apply to is the PA Group. Please describe the matrixed organizational structure. Also, please describe the qualification and certification process for the individuals in the 'matrixed organizations' that are permitted to perform the same assessment activities as and in lieu of QA personnel. Further, please address the independence of the organizations and personnel performing such activities. If the individuals performing such activities are technical specialists temporarily assigned to QA to support an audit or assessment, please clarify and revise the UFSAR text as appropriate, to reflect such use of technical specialists."

PSE&G Response to NRC RAI Comment 5: The phrase "or personnel matrixed to QA" and the sentence that defined matrixed personnel are being deleted. Although intended to add clarity, these changes, in fact, added confusion and are therefore unnecessary. NRC RAI Comment 6: "UFSAR Page 17.2-31 (HCGS) and UFSAR Page 17.2-32 (Salem) has added the words visual inspection after the term NOE, thus limiting the scope of the NOE activities addressed by this UFSAR section to visual inspection. Please discuss the applicability of this section to the other types of NOE such as a liquid penetrant examination of a root pass on a weld or an end prep on a piece of pipe. It is unclear as to why the visual inspection limitation was placed on NOE activity. Does the visual inspection limitation also include ASME Section XI visual examinations (e.g., VT-1, VT-2, VT-3)?" PSE&G Response to NRC RAI Comment 6: The change that added the phrase "visual inspection" is being withdrawn. This change has been determined to be unnecessary. NRC RAI Comment 7 "The last paragraph of UFSAR Section 17.2.15, 'Nonconforming Material, Parts, and Components," has added the word selected as follows: Page 5of9

~ocument Control D . LR-N990055 QA and other organizations in the Nuclear Business Unit review selected nonconformance reports for quality problems, including adverse quality trends, and initiate reports to hi9her appropriate levels of management, identifying significant quality problems with recommendations for appropriate actions. The addition of the word selected could have an impact on the trending program and its results. If only selected nonconformances are reviewed, there is a potential that generic or repetitive problems that are considered insignificant may be ignored and not trended. However, collectively those nonconformance reports may be significant or reflect a trend. It is unclear as to why the word selected was used in this paragraph. The use of the word selected does not appear to be appropriate for this application. PSE&G Response to NRC RAI Comment 7: Salem received Notice of Violation 98-81-02 for failure to comply with a PSE&G procedure that required monitoring Significance Level 1, 2, and 3 condition report issues for adverse trends. The procedure non-compliance involved failure to trend Significance Level 3 condition reports. PSE&G responded to the NOV in a letter dated June 22, 1998. In response to the NOV, PSE&G began trending Significance Level 3 data and published the results in the quarterly trend reports. Based on the results, PSE&G concluded the Significance Level 3 data was of limited value, and on October 15, 1998, PSE&G revised the corrective action program procedure to make trending of Significance Level 3 condition reports optional. Subsequently, the NRG closed out the NOV in Inspection Report 98-09, dated November 19, 1998. In conclusion, PSE&G judges that trending of Significance Level 3 data is of limited value and considers the addition of the word "selected" to be appropriate. NRC RAI Comment 8: PSE&G proposed the following changes to UFSAR Section 17 .2.16: Responses to SCAQ action re~1:1ests documents are required to includebase9 en the f91:1r elements gf serrestive astien, whish are:

1. Identification of the cause of the deficiency
2. Action taken to correct deficiency an9 res1:1lts ashieve9 te date
3. Action taken or to be taken to prevent recurrence 4:- Dat8 >.olh8R fblll SQR=lf;)lianse ,,,<<a& gr '*ill bs ashi8':'8Gt Page 6of9
 ~ocument Control D .                                                         LR-N990055 Attachment 1 Responses to CAQ corrective action documents are required to include:
1. Identification of defieiency
2. Action taken to correct deficiency For significant conditions adverse to quality, sblsh as kERs and f)JRC/lf)IPO/CMAP findin9s, the QA Cgrrective Actign <dm1.1~ Department is involved in the review gf s1.1ch cgndifams and provides oversight to assure timely follow-up and close out through assessment and inspection activities.

lter:Rs ~ and 4 are g~tignal fQr cgnditigns adverse tg ~1.1ality. For SCAQ:

a. What organization is responsible for identifying and accepting the date when*

SCAQ actions will be achieved? What organization is now responsible for reviewing and assuring timely closeout of SCAQS? . b. In UFSAR Section 17.2.16, 'Corrective Action,' PSE&G proposed to delete the provision for QA to review all responses to nonconformances and to only review selective responses for Conditions Adverse to Quality. Does QA review all responses to SCAQ for adequacy? What criteria is used by QA to select the CAQs for review?

c. With the deletion of Item 4 under the SCAQ process and the deletion of the word timely (on HCGS Page 17.2-40), it appears that PSE&G has eliminated the controls to assure timely completion of actions for SCAQS. Follow up action should be taken by the QA organization to verify closeout of the corrective action in a timely manner.

The rewrite of the last paragraph on Page 17.2-39 (HCGS and a similar one for Salem) has inadvertently eliminated identifying who is responsible for dispositioning nonconformances such as CAQs and SCAQs for conditions outside the scope of the paragraph (e.g., design nonconformances, operator errors, and administrative nonconformances that are not associated with nonconforming equipment, but may place the plant in nonconformance with other requirements). QA and other organizational responsibilities need to be described for the definition and implementation of activities related to nonconformance control. This includes identifying those individuals or groups with the authority for the disposition of nonconforming items. Page 7of9

~ocument Control D . LR-N990055 PSE&G Response to NRC RAI Comment 8: Response to Comment Ba The condition report (CR) Owner is a department or higher level manager who is responsible for ensuring that a SCAQ is evaluated. The CR Owner is also responsible for ensuring that appropriate corrective actions are identified and that corrective action responsibilities and due dates are negotiated. The Corrective Action Review Board (CARS) reviews the planned corrective actions as well as the corrective action schedules and accepts the dates for completion of corrective actions. Effectiveness reviews are also conducted at a date agreed to by CARS to ensure that the SCAQ has been addressed. CARS membership is composed of various plant managers and QA; however, QA is not required to be present to constitute a quorum. In summary, line management is responsible for identifying corrective action schedules and plant management is responsible for reviewing SCAQs, accepting the corrective action schedules, and assuring timely closeout. Section 17.2.16 is revised.to identify these responsibilities. Response to Comment Sb QA does not review all responses to SCAQs for adequacy. As noted earlier, QA is a member of CARS, and CARS is required to review SCAQs. QA currently selects a representative sample of SCAQs/CAQs for review during periodic assessments. In addition, responses to QA-initiated SCAQs as well as audit-identified CAQs are reviewed for adequacy by QA unless exempted from review by a QA supervisor. Review of responses to other QA-initiated CAQs are optional with the need for review determined by the initiator. As part of the performance based inspection program, QA will select SCAQs and CAQs for review based upon criteria similar to the criteria discussed in the response to Comment 2. Response to Comment Be Item 4, will be retained and revised to state "Responsibilities and due dates for corrective actions." In addition, the word "timely" will be retained. Response to Question on Section 17.2.15 Section 17.2.15 addresses nonconforming materials, parts, and components. Other nonconformances (e.g., related to design nonconformances, operator errors, and administrative nonconformances that are not associated with nonconforming equipment, but may place the plant in nonconformance with other requirements) are covered within the scope of Section 17.2.16, "Corrective Action." A sentence stating that line management is responsible for dispositioning action requests within their areas of responsibility has been added to Section 17.2.16. With the addition of this statement, Page 8of9

~ocument Control D .

  • LR-N990055 responsibility for dispositioning nonconformances not related to nonconforming materials, parts, and components is defined. Section 17.2.15 has also been changed to more clearly assign the responsibility for dispositioning nonconforming materials, parts, or components that ;;ire to be scrapped or restored to design conditions by replacement in kind or other standard maintenance practice. Specifically, a sentence has been added to state that line management is responsible for dispositioning these nonconformances.

The previous proposal stated only that these nonconformances would be dispositioned using the maintenance program. With the addition of this statement, responsibility for dispositioning nonconformances related to nonconforming materials, parts, and components is completely defined. Page 9of9

~ocument Control D . LR-N990055 PROPOSED HOPE CREEK UFSAR CHANGES

-6 7 

   *~..

9. Monitoring/auditing of nuclear fuel fabrication and in3tallatio11. Review of NBU fuel specifications for inclusion of QA requirements. B- 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.

of , *the trending of Corrective Action reports related to 'human,' 

        *6rga'l.li'zati'orial t and Drdgramrnafic petformance'  o data:   reports      ta 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~--m:rd scheduling of s nr., "'i ::.1 ai,c.e5:;= .an*a* 'performing f(l;:;;;EToi~aI":aie'a
         'surve-1 l:fances /asses!:imeHts:                  conducted within the Nuclear Business Unit.

g-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.

r*'.*:'.-*'.~*cc*~: Performing <'LS5e:ss,rcent5 ir:eview: of PSE&G adrnin_'._., t:..ctti v e m,d implementing procedure a)

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

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Perform design ch,.,mge package pre-implementation review and closure review for compliance with Inspection Hold Points ( IHPs) ie:"(iuirement.S7'[;'::-f'Oj3 

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Performing performance based inspections.

17£. Implementation of the onsite independent review. 1-&].. Mon.i.toring/auditing of nuclear fuel installation. l~lL .B9-r1lfqr:;_the. eibili ty of. t[le; Pk\ gr;ol,lp. t() contiirnousiy f~ll.Ctiog 'fnd~~Q~}-);(ien'tiy ras c:lelJneated_ 11n.d_er the _:responsib:j,)i ties. ()f_ tl}~\:_J?h".}ICJ.f1a,g<:ii_~ a!15J. P'e:rfgrni pef~od:j,(;,_ au.cii t;s of_

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assess... '3:~~.E!9lE!ci',:~~:r;§yJ_~~~r. :.,**~-~~~li§tt:i<?l1'3r. ....... '31J.;EYE!Y:3r . Cl..\lciii~i-~ --a-Ed sgrveiiiai:icEi~ _C:o_i}C[li~I~<:i :t~'./~-i'l'i;pe'is<Jilfi.et:~;; 17.2-6 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 deoig11 e~1a11ges intpt)rtant to :safety, tLe QA representati \le on the proj eet teanc test :r~:sult c:k;eur .. eni::aLiem, a.re~ project Leam Cv!Hp::..ia1,*j'! .v.:..:.:.L Cvll1pany p .... oce...:.ul'.es durin,, pLepo..dl:tiOJ,, ..._e,rie~~, and approval of de:sii;ir, wlti'UJgeo  ::'.;j"QAiViw'fll "v'e.JS:Jif\;I tiSi-i'c::iu:si:()n of ** Ci'\1ail'tv .rec:ju-iL-emenI.si 'in:*:g*;;;:i'feC.ted'7desig!i:

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t11a:t:rth~:aafl:irii~riEs'~-~~~7J;f~f?'i:iii~&':~i:e-J.i~t.;~c:r-:;;;:n:a****;aJ?l?~BvJ§ia:**rK--ii;;*;;o+/-d:i;;.:rl6~****t:r:iJ&i*~;;ifur;~rr¥ p~d&~~ti~e*;;r~rici?Bli~_~_-t:he** c:i~~~Eiti-~t;dfii,~ih_~*ffillf_.*::~~e:~~~§-~IE!~~A:-'.~'~cm~_:t~~ri:~'~-i; 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 ~ BA prior to issuance by the Purchasing Department to the prospective supplier. ~

!:'~ review assures that spare and replacement parts ~1;-a:*:_'.k~efvi-'C:~~s-Jare procured using controls which are commensurate with current QA program requirements.

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

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, by QA foi: QA _,_u;iui~ernet.Ls, and are approved by the responsible station department manager or his designee. ::::;..:.Qfi; assesses se1ec.:tect documents a:Efect:Lng nuclear safetv to ensure: 'in.corporat:.:Lc)n: of Quality iegu+/-r.ements 'fl~roua:h* periodic .*.assessment*. and inspection adtivities 'f(.~'.f\(i\1cr:e'2F F§ QA per*s611rie1 OJ: pe:i:somxel mat:i:i:x:ed to ~- '/ ~~:i::i::ic:.~~ J~~'.!::-!i9#i~~~-*~q;~

  • ~_;~+/-fi~~ .in *a:*ccordanee w+/-t:h th~:*~ ~:i:.a:;ifi:n;g~El:C?9l:.~~j 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 oLd a.ppro,e., selected procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair and to tlr~we doL...unteL.t.w are also ..i...eviewed auu ctpp.1...0\*ed . In addition; QA is responsible for review a.rd ap~roJal of selected specifications, test procedures, and results of testing throuah pe:riodic assessment and inspection activities. 17.2-23 HCGS-UFSAR Revision 9 June 13, 1998

An independent organization shall perform NOE .~istia1 :;n~p§:e:~~§I~ 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-lA, as applicable. A planned and documented QA mo,iit..:iri1,9 berfotr(iancE~;;;;basei:.'l '_Lrisoecitiori 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

17.2.14 Inspection, Test, and Operating Status N,uclea:r:: 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 such required tests and/or inspections are completed in accordance with specified requirements. 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 Superintendent/Control Room Supervisor for Limiting Condition for Operation (LCO) applicability when appropriate and the disposition 

                                                                                                     * ~m.- , ~~C>>W '

and inspection or retest requirements, as appropriate. The: '+Act:i:on Request lfrJ(ji:Xfl'catlon) . Process r Corrective:' Act:i.on. Program, . ariCi/6'r'. t1a~i.11tenance ProoraTii 'a*re used* to identify B.11ci7 cti:Si/6sition' noncoi'{t6rn1a'nce.s., as 'app}'opria'f7e-:-~to . the' 'condition.* Tfo~ maintenance p:roqrarn will b.e llSed to d:i:sDositioh 'ricmconforminci materials,: Fa:t'.'t.S;** :c,*r cornpo11.er;t::s;**;,fiiich.are'.to **se '.Scrapped;* 01.:-*::r:estqreCi-tS ..ctes.{ gn *.con;Ii'ti'oE bv.re[)ia(:ernent* i.n 'kT£1ci 'or ()T:E*er. st.and-a.ref. main te!1.ar~-Ee 'r?ract.T<.~~;.s*......Reiestina l~IJ..T be in acr.ordance with normal' post-maintenance

  • testing, and post'-maint'.'eri.ance operability retest.i.ng practices. Th.ese noncon£ormanc.E!s wil_l be disposiho1led ~Y line* management. *.QA
  • wHT**. verifv the *satisfactofy' ::*reso'iutioil.. u6~i "-:*su.c11

assessment B:nct lnsbecti6n aci::i'Vities. 

                                                                                                      *          -,-*-~~; *~*-*.**"~;-~-***-*-***--

rila:irrtena:nce .orOaram The responsible Engineer dispositions ea._,lr i.onco11f._,rma.i...,e i_epor t I;;J:te!Slfhis"',' i?ci:f r:s,* 1 

               *or  '2onrp8'nE:fr1~.::§v; 'EBiiE'    1
                                                   *~ re.'?'t:.c;,:be ;: rEitiai:i'E:;ff 7 'f<:;, ;c:z:l'Hier  .:Elian* 6\5.H'.E:;n'E. a;;:s:rg:r; Dispositions               for Jrepair itd ot:he:t:.~t-,nciH b'la1tr'eii.'t:  d.~slian's.D~/ci'f:ibiit cbc:i':n's'i or 1
                                                                "use-as-is" are required to be reviewed and approved by QA prior to                           implementation.                Re~~ork          or      . I3;epair 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 r~prese?tative, based on applicable requirements. QA or P:A. shall verify the satisfactory completion of the disposition of ltl~ese.nonconformances. QA and other organizations in the Nuclear Business Unit review nonconformance reports for quality problems, including adverse quality trends, and initiate reports to h: g:rer hnpronriate

  • 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 are required to implement corrective action for significant conditions adverse to quality (SCAQ) and conditions adverse to quality i{C.1\0) ;identified within their scope of activity. Such conditions are documented and controlled by issuance of an action request. The QA

uil::ouc!L *'J?j::ieriodic summary and status reportsi bf***** the :c;:;jE;'i:CiiJ?c*cof'.r~'et.[v'~ ... A:ctloK .. pJ_:()'d'Farrr' are '*p:r,:;;\;Icied *:to management ::th.i'.C[~u(iff'eHher *the perfdrn;anc~t' fndiEafo~*s 'or Eiie.oe.i'.:i()dic: ();!\ *:tepott.

~fl:9°ir1e!rJ.ncf _an:a*

  • Ma::Lnt<Sinanbe' * *are *re:Sp6ri~ibie .for-. ~_ffi:iipmdnt:. faiitire * .* t:i;erid.in<i.

bep<:1.rtmdnt ME<ih~qers' are: *:re:Sp6nsfble for: ':i.d.entij:y:Lrig

  • trendg. *.;;Tith.ii{. ::the:L.f
                                                        ** *****~-.,- ~--~**m*:vn**~--*-nwv,v:;'"'<" ""'""7 mvw**u****;-vvv* u*

?i:f:lSpf:lCtiVS oJ::gi:iniza boris; The Correct':Lve Action. Gr():tip is re::;pohsible for overall' management* 'of the trending t~:f cti:t+/-'~ct.:L\;-e,; A.c'ti;;n. reports * ~ela.ted<H to h~a.rif

~rg~n:~~~t_i.?!l_a.ir
1. Identification of cause of deficiency
2. Action :taken to correct deficiency ulld U~0ull:s c[,_Lleve...:. to dnte
3. Action taken or to be taken to prevent recurrence
          '4.!     Re~ponsibilities and              due dates £6:i::':6orrective ii.ctioii.s'

                                                                                  ~ ,, m¥* *"';¥ .,._.,.,..,., ' *              ,.,,,_,,, * **** --,., ****w.w,._. ,* .*,,* ,,._,.,
  • _, '* * ~

actforl ~effii~_s'ts ~with1n 'theil:J For significant conditions adverse to quality, 'plant-:ma:ri~-ge~ent >is: ;e;;;.p~-n;s'i};i~ \f'6f  ;;;11.S'll:t°_~nq 't~lI\E:l:lY'~~;;~-B*;,;;~-e:: :SthJr o5 K'.R:s a1,C.: t;RC/INPO/CHAP :E::.udbg:s, tgjhe QA cone~~ive Actloa Group Dep;J.rt'ine'nB is involved in the review bf ~eil.edti:iid ScAQ~ c,i: :suv:1 condi L.:..on.:> and provides oversight to assure 1E:~~~I~ 17.2-40 HCGS-UFSAR Revision 8 September 25, 1996

follow-up and close out t.hrouqh' assessment. and fr1spect.:Lor1 ac~ti vi ties. 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

~ocument Control De. LR-N990055 PROPOSED SALEM CHANGES

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

~ ~. Conduct of supplier surveys, audits and surveillances. ~ ~* Evaluation of prospective and existing Supplier QA Programs. '~. Monitoring I auditing of nuclear fuel fabrication cn,d i11slallat.:.011. =t- !9-;. Review of NBU fuel specifications for inclusion of QA requirements. -& if9:. Perform material evaluation activities on i terns 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. Meuageme11L JirecL.:.on a,rd control of all .._,ollection ar,d oVer~TJJ ma:nacremenF':(;:;r::rE:h~ trending of Corrective Action reports :rel'a'E;:;B~t:o:

i1\1man:,* ordaniza.BT8na:;t; and J'.)fogrammatii~. B~el2'f'ormttnce'. 

               ,~.,,, ....
               ;t:p        management.

The Manager's responsibilities relative to Emergency Preparedness and Instructional Technology are described in Section 13.1.1.2.1.4.2. 17.2-4a SGS-UFSAR Revision 16 January 31, 1998

fr}. 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 assesmnc;11t._, :review of FSE&C P1,,gu\!,:.::5f~l'ec:i.eci NBU lower:* t:Ler administrative and implementing procedures 1::i1r6uc:ifr ..periodic. j::ssessment 11¥6. Conducting QA Program orientation for NBU personnel, administering the training and certification program for QA personnel involved in inspection, assessmentsQ and auditing activities, maintaining the QA training plan, and maintaining QA training records. 1.Z:~. Review of new regulatory requirements for QA Program impact . 

       .wI1::11'*t.11Ei *J2rHci1d.U:res"fha'tIITioTeffie*n:t**rhe:          60ilL~I"tffienF management                          pt'ograffi hv tre"V'iie"w**'.of*': se*J;~~(~:ted:<.Sommit:mEl:nts i.:.hi!:'Sh<xn:': PE)r}(5di(~. "asse"ssmer1t: . ahd rrr:;spe-ct-:ff.:on! t;"C:fivIFieS'    ,,!l ct .,e.:.ected basi"'.

H-3. Performing Code r el<"d:::ed ir,spect.iol!s, te.,,t per .'.:o ... 1L<ai1ce, and review of weld procedures for inclusion of QA requirements. 15-'_i. Perform+/-rrq des_;_g1" clran'o)e packag.:. pre-implementation review and closure review for compliance with Inspection Hold Point (IHP) requirements £61:1 

       'se'iia.s:t:eff-des :Ca11**~<iI1at1*0e**;v;a:ck:aa*e*:;** *1;:v*:;;-ei+/-ii:lci 1*(~--*a-;:, :5e.s*:;tr;;;;;:1:e*:~1*fia'1:;1:n:;y;;;;;*;;t:T01:1 .

Performing performance Based Inspections. Implementation of the onsite independent review.

r that they s'elect.ed cables have been installedi

  • ident:if'iedf~ and routed as specified per procedure fhrtlugh oe:tiodi',y assessment'. and *inspection On
19. E:~L:S tl.:... e tLat the cable., dre r_,r,)perly _;_u"talled, ide.it_;_fied and routed as zt9*~. H2ni~9:rJJi~:--@i3*~IHiY:~2t!:-t'.JiI'\I>if.g~~0u:.Q_~1c:;:=c:_0*Ji~Kiili'..9.~*8-rY." . ¥iI5:c;tJ'BE
        ~ncf~R~_ri"ii.ei:i*1::~J*Y.i1s>.::st~nJi""'~-~fe..c:i ~rief~f tii~:::i;_e:i~i?,qifaI!?~iit~i~2~91 . :t:K~3J5 N:lia~~9.~5 1a11qJ?e:r:::Sc:i:r::rr\-:p~r}()dic       a,.~~~~~*   ot*:PJ.\  J::(2!yJ~w ~i.lnc1::ions '. ... Tr\~ ~()~J9r,viri9]

p_~()'Y~.4~§~ ,gµ~s{"~~-~~~~()~ }h:~:_:c()~-~~s:L and . .S:<?!l.t en t of the .*. §.~~I~~.~=~~4Eii! 

        .-,         ;¢()'petf2:cfr: *~Ii't.EilbEf~Y~ ~. §il_ry~~:i:.s:z ~ §.i::f"2\. <?. E_:;i~t'.~.c;;i:~si: r:)fa.?i!lti:~.1= ~ll_o~::~J.:g
                    .~QYQ~YfaLJJ!, Pl:.<!9~F~t:GE?Jl1::* ::<fr,,p:i;,9<;:µ:r;,~l]~IT:!= Cl:§? ~.§,§1]~!1:1:: Cl 9.1:::.i:Yit::t. ~.f? ':() ri wiis:~:a.:;:~: ~n--:a. *:p:osTtT0Ii~---to:0ss~r_ve* 't!les-e~ a,~IV-UI~$
        ,_,         ~*.~*~*~*~:~::**i§I~sI~.~::~~~xI~~i~:=~y~aj:li~I~~9ii.~i';:;:~:~~y~y~::;, **;21~.~-~ii§:~**~*~~~~~

cs*1:lf-::v<~It1fill~~§=~0..!1,<:i_~S::f§~~~~i~?~:i=>ii:§,5:fon~I:£J 17.2-6 SGS-UFSAR Revision 16 January 31, 1998

organizations, both internal and external to Nuclear Engineering. The project t~am 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. Learn prvv i~e"' input and i'l.:'3u-. e., Lim;_ de.,ign cLa119e., inc.lode quality ct.:,,.,u .. anr_e requirentl"'Lt.,,,  :..e"'t .. e.sult do...,umei.tation, ct.r-..: project team cc:.n,plictr.ce 11.:. th

Pfci;;e<l~*;;e;$F:ha.4f~7,b"~~n ***e;R;t:~i+/-§h'e!,;ci

~ti.a:: *c;0n::ta.in. .i>i-6~I 6.iei:ns*:**tila.f- d.es:Cribe' :ho;,--oi\T :SeIEict:S:'.'Ci9s+/-9-ri -d.~&innen f:S *;ifo:t

fev.iew to assure that the documents are prei:;ared:>'*'fe;ieii'ec:f'and.*approved +/-n

'ac6ordacnde: .wf th:. do:;n.P-~b;-y* pfo cedttres arid. thii1:th:~ .Cl.6di.mu~rit.s '\§6rita£n the;

.~-;;~
s~'ia.?& q~ - ~~Sffi~;;J!heri!t-6-.J 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 e:i"t R~ prior to issuance by the Purchasing Department to the prospective supplier. e:i"t -~~ review assures that spare and replacement parts '.anci.-services- are procured using controls which are commensurate with current QA program requirements. 17.2-20 SGS-UFSAR Revision 15 June 12, 1996

personnel with normal~ills do not require a detailed41titten 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, by Q}\ for Qli .r."'qu.:.rt.IHd1ts, and are approved by the responsible station department manager or his designee. bA*asseis.es' s'eiectecFd6Sunl.enfs. a'.ffef:.tinc{.nucGI£l'i':sa:Ee'tv* t.O eiisute i:Lb8or'o6l:'at £or1. o{ quc.,;:Iit'v'-:teguTr.e'rnei-{t.'.S:~tltFoucih ::pe'ri()di2- as:s'e-s's.inent--'ari d

nsoeEt.10n
:;c;~:rv--:Gfies- c8nCISC:ted:bv*;caK*oEn:.;86r:111;*r*?:i:... :12~;§<?I~~~:1:. *~1':tJ:::L#~_cl:*.i:: 2 .*~.J

~~i+/-';;l!:d l?e~_;g~;;;J_:L~;,.~ i*~-z;,-i,i :S:i~srl'ii ~~~d~;f"J.a,~;;;;;:-;*~~~1 t:;:i:e,,. ~ t:; aininc::r . P;F o~.l: mn..:: 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 apprcJ"'s selected procedures that implement the QA program, including testing, calibration, maintenance, modification, rework, and repair ~11Ci:C:hailO.'es -thiiiil:i:t:6-.fl1roucih-oed:c)cii'c **asses.Sffi8fit:: kdcf Iilspec.t'isri** act:Evifif.{5. CLan~es Lo the.se docume,rt., a~e also i.ev ie,oeJ 1L1__: app~o~e,:I. In addition, QA is responsible for review aud approval of selected specifications, test procedures, and results of testing throuah period.Tc assessrt1ent anct i!1sPection: 'ac-t:hr:i.. ties. 17.2-22 SGS-UFSAR Revision 16 January 31, 1998

3. 

                                                      * * * '     ** *<    ~

An independent organization shall perform NOE ;11:i;sual, :i;rt<?J?ect:j:cm :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 n"'.)ILL tor iJ,~ performance,-.:. based:- insnect+/-on program is conducted by QA for seh~cted 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

procedures control th~pplication and removal of tags~d 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 Superintendent/Control Room Supervisor OS/CRS for Limiting Condition for Operation (LCO) applicability when appropriate and the disposition and inspection or retest requirements, as appropriate. Th~::A.C:tiion~.Regue.St>*.(No.fifl.tati6r1) Prbcess ,-~ Corrective Ac:tion ii?Jibgram,. a.:nd/or Maintenance Program are.-us.ed.: tHid.entl:t\'. and disposition hor1co:6£ormand"s I. as anpropriate. fo the. "26nctTti0hf;'~: ;--*1

i'Ee m'trintenaiice *program .w+/-11* be. tfsecFfo 'aisr)6.STt
l"0Y:{ *hori(h)ni:Srmlria* materfai.S:'i1 parts 1 or con'<oone11tsf .~h:Ccfi are to be scrarried, or restored*io d."esTgn

.26r!ciitioh . by .* r_:epiacerr:enF-Tr~ .I'.lnd *.**or .. 6t.n"er-*5tandarci malntei1*a-nce--i;i:i~-a ct ices*~--* Ret e stina \-i:CE .Fe::Ti1'"3acc"0rcia1ic"e" 7~i:CtTi." 11'ormaE:Oast:?):'fi1a:cl'.Etel:l"anC'e ie:Sti"Iig",' :*a:n:a \?Ssf::irn"alrifer1al1ce'Z6P~i:~GTl'ity':ietfesting. pract:L2es*.** . *The~e n~nc;~:Eorni.ances w+/-1ci.l t;e;:.:d:hpositio:ried :by *.T:ine >kanagemen t. *' CiA.'Iwi IT -veX:iIY:~the -sa ti.S tact.Or'¥

.t~861lit
T0K0i' slicfr.non'C-on.£*0r:rr;-a::n:2e;;, *;;h:-~C'.8IE;C:t.ce;;rc-15;;sTs-::~i:IG::oli9-il~-1t-s'. 110-rrri~JJ maiiltenal:i"Ce p rogr am~as'sesEirnent~ancf Inspe-ct:Con-actTiiit:Tes:*

The responsible Engineer dispositions C"1h.-11 .ic_,nccr.fon,oncc rcp,Jrt Inaii;ei:iais> }:_)B.rt'sy~. or components. tha1:'.': are to be *repi3.:ire~:i.::~t::ci';oc-th:e"0 thar'i curre-.r,1::-~+/-e"s'lgri !,Specif'ications or t()-be--G:sed as-=is. Dispositions for jrepair to bttl~rqtha*rr 'Eurrerit desian so.Sc:C:f:CcatYor1s"i or "use-as-is" are required to be reviewed and approved by QA prior to implementation. R~tcork or rEepair of nonconforming

~a~erial, parts, or c~onents is inspected or reteste~or both, in accordance with specified test and inspection requirements established by the responsible engineering representative, based on applicable requirements. QA or PA s,hall verify the satisfactory completion of the disposition of these nonconformances. QA and other organizations in the Im~J-J~iidear

  • B-lis-ine-ss-tJnit review nonconformance reports for quality problems, including adverse quality trends, and initiate reports to higlrer ;aoproo:i::iate levels of management, 17.2-37 SGS-UFSAR Revision 16 January 31, 1998

identifying significa~quality problems with recommen.ions for appropriate action. 17.2.1[ Corrective Action Organizations involved in activities covered by the QA program are required to implement corrective action for significant conditions adverse to quality

( SCl\Q) ,and conditions adverse to quality *. (CAQ)i identified within their scope of activity. Such conditions are documented and controlled by the issuance of an action request.

reupc,L><:~..:,  :~o action requests;:res6onses for adequacy'.t_"h.t'<)[J.iii~;i;s*s~ssment and In"Eipe:ctTon~>actIV:i5tTes:: al1cl met *..L::..ors tLde acLo.i r<::,C1Ud ~s tl~ioi:i(:i:-:J?t,eriodic summary and status reports!~)£ the bver;U,1 bbi:i::et:ti:,_;e'. ActfBh' Pt'oaran'i 'afe* Br:ovided" to management'.:';tT1f<Su&!l. ehne:r;.t;h?e J;ig:rf8'i:Th.an8e' *<i:nct+/-::cat'ci*Zs**or*':tn:e* beII~)dI~E-;bK*i.-@pcirt:. E;nq;j_ne~f~!lcP:~ria Mai.nteriarice *are 'fesponsible for' egui.pinent 'f~i*lure t+/-:ericii.!l.g_: bJpartineiil.t M:iri£i.q~i;s' --~;;~ *:t~kp§hk:Lbiei fbr i<l~ilti:f:Yiher fferid.k within tb.ei.:t for 6vefa11*h:i~;{~qE;'lme!l.tof the*trendirig'of ~c::>rrective Action rep()rts related.th 

          """" ~*>* , ** -****>"""'"'-'                  ***{<N*<>* -'"'"""""'!""~"'i"N'"*" *uo** C'>
  • hiiman'i ()~9aJ'.li:zatio!l~:l:r . 9:I1c:l_p:i:oqr~~atic J2~rformance .i
1. Identification of cause of deficiency.
3. Action taken or to be taken to prevent recurrence.
4. Dat~ ,1he1" ful; complid.icc i-va.5 o,_ w.:.11 be ac:riecc.cl.

Respons.ibilities

§l~ea~ *. o,f .r~~p~~~{l:>1ici.ty '.

Line rnanagernent is r~.sponsible for dispositioni.nq action requests withi.n their For significant conditions adverse to quality, plant<managem~:O.t is :t:esponsibl~*

f6:r** ens~+/-inqt:i.niely :r.~sponse. Sdc,h d.S :'..,EP.., ,md r~F.C/INP0/01AP L.ddi.ng.s, t;+/-:he QA C:,)u.cc:...Lvc r"... U~.1, G ... cup Department is involved in the review of t\el.e~ted !:;C!AQs oi' ..,uc,li c.)i!-..:iti.01,s and provides oversight to assure 't.irn~ly followup and closeout through' assessment* *and inspection: activities. 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 17.2-38 SGS-UFSAR Revision 16 January 31, 1998}}

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