ML20073G275

Change Notice 94-04 to Operating QA Manaul,Sections 15.7 & 16.4,enabling Reporting of 10CFR21 Via Other Reporting Mechanisms

ML20073G275
Person / Time
Site:	Callaway
Issue date:	09/21/1994
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20073G263	List: ML20073G261 ML20073G275
References
NUDOCS 9410040078
Download: ML20073G275 (5)

Text

_ _ _ _ _ _ _ _

l A T T A C II M E N T 1

////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////

OQAM, CN 94-04 aaa IDENTIFICATION OF CIIANGES

////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////////

941004o078 940921 )

PDR ADOCK 05000483 P PDR

cal #44-o4- i ODAN

~

1904 15.4 Material nonconformances shall be processed in 1905 accordance with documented procedures and shall 1907 identify the specifics of the nonconformance

. stating the particular drawing, specification or other requirement; shall record the disposition; and shall register the signature of an approval authority. Procedures shall prescribe the individ-uals or groups assigned the responsibility and authority to approve and verify the implementation of the disposition of material nonconformance.

1907 15.5 Material nonconformance disposition categories 2334 shall include:

1. "Use-as-is" or " acceptable" (including condi-tional releases)

2. " Reject" or "not acceptable, scrap, Or return to vendor"

3. " Rework" in accordance with approved procedures

4. " Repair" in accordance with approved procedures Material nonconformances shall be reviewed and accepted, rejected, repaired, reworked, or condi-tionally. released in accordance with documented procedures. An approved disposition of a nonconfor-mance which allows a reduction in the requirements of a safety-related structure, system, or compo-nent, shall be treated as a design change subject to the controls prescribed in Section 3.

1848 15.6 Nuclear Engineering shall be responsible for 1905 approving material nonconformance dispositions of 1907 "use-as-is" and " repair". Licensing and Fuels 733's shall be responsible for approving material noncon-formance dispositions of "use-as-is" and " repair" on nuclear fuel which are generated prior to the arrival of such fuel at the Callaway Plant.

Regarding material nonconformances identified on-site, QC personnel shall be responsible for verification that approved dispositions have been implemented and for the final sign-off.

15.7 Nonconformance documents which record defects '

in basic components er d:Jictirne frc= tc;..nical

-scquir;;;ata 43 precur ::t derr ::t:- shall be reviewed for reporting applicability under 10CFR21 y 4M4 and other Federal reporting requirements. Signifi-cant nonconforming conditionA involving a defect or NT PW aaterial. noncompliance in a 5clifered component or 4.

services which could create a substantial safety gr hazard shall be reported to the Nuclear Regulatory gQ Q Commission pursuant to the requirements of 10CFR21.

Co m ms,aA--

A 4

15-2 Rev. 14 6/91 I

l

GQ/\V1

. . OQAM c g gqq w y 16.2 Conditions adverse to quality which are classified as nonconformances shall be controlled in accor-dance with the additional requirements described in OQAM, Section 15.

16.3 Conditions adverse to quality which impede the implementation or reduce the effectiveness of the Operating QA Program shall be considered signifi-cant conditions adverse to quality. Significant conditions adverse to quality may include, but are not limited to, noncompliance with procedural requirements which impact nuclear or personnel safety; reportable occurrences required by regula-tions; adverse nonconformance trends; deficiencies identified in the OQAP; recurring conditions for which past corrective action has been ineffective; and managerial controls which could result in the failure of a plant system to perform it's intended function. Examples of such conditions include those which match the descriptions in Callaway Plant Technical Specification 6.5.1.6f, g, h, 1, m (potential hazards to nuclear safety) and NPDES violations. i 16.4 Conditions adverse to quality which involve defects in basic components or de/intienc frer technical  !

1. -rcquire=ent: ir prc urcacnt d o- me m a s shall be Cd l 44 Ob. reviewed for reporting applicability under 10CFR21

,,- and other Federal reporting requirements. Repor-table conditions adverse to quality are classified i as significant. I 16.5 The nature of the condition adverse to quality may be such that remedial actions must be taken imme-diately, whereas development and implementation of corrective action to preclude recurrence may take substantially longer.

1871 16.6 Nuclear Engineering personnel shall review condi- ,

tions adverse to quality which involve design defi- '

ciencies or which involve recommending design changes as corrective action. Licensing and Fuels should review conditions adverse to quality for fuel-related issues. The ORC shall review signifi-cant conditions adverse to quality.

16.7 Corrective action documents shall be closed by verifying the implementation and adequacy of corrective action. The closure of corrective action documents shall be accomplished as promptly as practicable after the corrective action taken has been verified.. Verification may be accomplished through direct observations, written communica-tions, re-audit, surveillances, or other approp-riate means.

16-2 Rev. 16 6/93

A TT A CII M E N T 2

//#//////NM//##//////#///M//////#//MM///////gg//////g///ggg//g//g//gy/jf/g/g//gffgggggg OQAM, CN 94-04

..n EXPLANATIONS OF AND JUSTIFICATIONS FOR PROPOSED CifANGES TO TIIE OQAM

////M##////////#//////////#/M///////////#///#/////////##/#/M/#/////#//////#///M////#//##/////#//////##

7

. . =

... q l

i OQAM  !

CN 94-04 l

Description of Change: ,

Revise OQAM Sections 15.7 and 16.4 to enable reponing of10CFR Part 21 via other reporting mechanisms. ,

I Justification: i 3

10CFR Part 21.2(c), dated March 31,1994, allows persons operating under 10CFR Part 50 to evaluate and report potential defects under 10CFR50.72,10CFR50.73, or t 10CFR73.71. This satisfies the responsibility to report defects under section 206 of the Energy Reorganization Act of 1974. As discussed in Part 21, Proposed Rule Making dated April 30,1992, this change was made to eliminate potential duplicative evaluation j and reporting requirements.

In an effort to streamline reporting and clarify Union Electric's reporting process, Union Electric will report significant defects to basic components via part 21 for those components that have been receipt accepted by QC, but have not been installed in the system. For items installed in the system that have significant defects, the condition will  !

be reported via plant LER procedures. For items that have not been installed in the system and have not been receipt accepted, reporting is the responsibility of the vendor.  ;

UE will notify the vendor of such problems. The evaluation of material defects is performed as a part of plant corrective action programs. Since there is no change in reporting, only the reporting mechanism, for basic components with significant defects, this change does not result in any unreviewed safety question and the OQAM will  ;

continue to satisfy the requirements of 10CFR50 Appendix B. -

I l

l H

l l