ML20113G612
| ML20113G612 | |
| Person / Time | |
|---|---|
| Site: | Vogtle |
| Issue date: | 05/10/1990 |
| From: | Bochhold J GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20092F288 | List:
|
| References | |
| CON-IIT05-343-90, CON-IIT05-344-90, CON-IIT5-343-90, CON-IIT5-344-90, RTR-NUREG-1410 VEGP-00150-C, VEGP-150-C, NUDOCS 9202240395 | |
| Download: ML20113G612 (48) | |
Text
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1 DEFICIENCY CONTROL 1.0 PURPOSE AND SCOPE This procedure describes the requirement and a
responsibilicies for identifying, evaluating, reporting, and dispositioning deficiencies at the i
Vogtle Electric Generating Plant.
The procedure also prc>vides the details for processing Deficiency Cards generated when a deficiency is identified.
2.0 DEFINITIONS 2.1 DEFICIENCY i
A deficiency is a non conforming condition adverse to quality, such as failures, malfunctiens, deviations, and defective material and equipment.
For additional guidance, refer to section 4.0.
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2.2 RADIOLOGICAL DEFICIENCY 1
4 A radiological deficiency is an unsatisfactory radiological condition or personnel performance which i
j could lead to increased personnel exposure.
i 2,3-MATERIAL DEFICIENCY Materials, parts or components which are identified during receipt inspection or during storage, as failing to conform to specified requirements.
2.4 USE-AS-IS A disposition which may be imposed for a deficiency when it can be established that the deficient item will result in no adverse conditions and that the item under consideration will continue to meet applicable requirements including performance, maintainability, i
fit, and safety.
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a 2.5 REPAIR
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A-disposition and the process'of restoring a deficient characteristic to a condition such that the capability of the item to function reliably and safely is unim? aired, even though the item still may not. conform to the original requirement.
2.6 REWORK it t
A disposition and the process by which a deficient item is made to conform to a-prior specified requirement by
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completion, remachining, reassembling, or other j
corrective reans, i'
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2.7 REJECT 1
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A_ disposition imposed when the deficient item in present condition is unacceptable for intended use.
2.8 OBTAIN VALID DOCUMENTATION 1
4-A disposition imposed as a result of incorrect or 1
incomplete quality assurance documentation, including existing issued drawings.
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t 2.9 HARDWARE NOT AFFECTED u
A disposition assigned when a deviation from procedurer 1
or programs occurs that in no.way alters or deviates 1
-from the design or changes any hardware.
9 2.10 NO DEFICIENCY CARD REQUIRED J
A disposition assigned when it is determined that no i
deficiency exists or that the identified deficiency
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should be dispositioned using other administrative
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controls.
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2.11 QC HOLD TAG A tag used to identify non-conforming materials.
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2.12 NOTIFICATION 1
Notification to appropriate regulatory agencies as described in Procedure 00152-C, " Federal And State Reporting Requirements".
2.13 IMMEDIATE CORRECTION ACTION-Actions directed by the Unit Shift Supervisor (USS) to place the plant in a safe condition, comply with license requirements, and return equipment to normal
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operating conditions.
2.14 DEFICIENCY CARD (DC)
-A card,-similar to that shown in Figure 1 used to
- identify deficiencies.
2.15 MATERIAL DEFICIENCY CARD (MDC) c.
-A card, similar to that shown in Figure 2, used to t
identify material deficiencies.
2.16 DEFICIENCY CARD NUMBER A unique number assigned to a yellow Deficiency Card (Figure 1)
(i.e., 1-87-0001 (unit-year-sequential number)).
DCs on common systems will use Unit 1 i
g prefix.
i-1 2.17 MATERIAL DEFICIENCY CARD NUMBER i
A unique number assigned to a white deficiency card j
(Fi;gure 2) (i.e., M-87-001 (material-year-sequential ji nummer)].
j-2.18 LONG TERM CORRr.CTIVE ACTION Actions recommended to prevent recurrence.
Thesa actions are detcrmined after root cause determination, t
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l-2,19 CONDITIONAI, RELEASE i
Allowing'an item / component which has been received but has-been found unacceptable, to be installed in the e
plant, but may not be relied upon to perform-its intended function.
Consumable materials are.not conditionally released.
j 2.20 SAFETY-RELATED 2.20.1 Vogtle Electric Generating Plant structures, systems, and components.necessary to assure a.
integrity of the reactor coolant pressure T
- boundary, b.
-capability to shut down the reactor and maintain it in a safe shutdown condition, or PP capability to arevent or mitigate the consequences c.
of accidents which could result in off-site exposures that exceed the guidelines established
-j in 10CFR 100,
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2.20.2 Systems or components designated as nuclear safety class 0, 1, 2, or 3 and listed in FSAR Table 3.2.2-1:
and instrumentation. designated category 1 or 2, as listed in FSAR Table 7.5.2-1: Fire Protection Systems / Components as described in the Fire Protection
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Program (see 92000-C): Radwaste Systems / Components j.
having Project Classification of XX7, where XX are safety class and seismic class, respectively.
Si NOTE Procedure 11850-C,
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" Safety-Related Equipment Classification" contains i-the information listed in L'
FSAR Table 3.2.2-1 and FSAR Table 7.5.2-1.
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.3.0 RESPONSIBILITIES L
3.1 GENERAL MANAGER-NUCLEAR PLANT l
h The General Manager-Nuclear Plant has the - e tall responsibility to implement the deficiency porting
- system, a
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h Li' lf 3.2 PLANT REVIEW BOARD (PRB) i i-The PRB i
3.2.1 Reviews deficiencies designated as 3B or 3C for concurrence with the reportability determination and for detection of potential hazards to nuclear safety.
PRB recommendations regarding corrective actions will be forwarded to appropriate individuals.
3.2.2 Reviews the root cause and corrective actions taken for reportable items.
This review is performed as part of the PRB review of reportable items.
r 3.3 UNIT SUPERVISOR (USS)/0PERATIONS l
The USS:
3.3.1 Evaluates Deficiency Cards for immediate reportability.
The Shift Superintendent (SS)'will make resuired notification to regulatory agencies.
j 3.3.2-Evaluates affect on plant operation and initiates compensatory action as required.
3.3.3 Assigns sequential numbers to Deficiency Cards.
3.3.4 Maintains a number assignment log for Deficiency Cards to include number assigned, date number was assigned, and Deficiency Card topic.
3.4 MANAGER ENGINEERING SUPPORT 1
The Manager Engineering Support (MES) ensures Design Change Recuests (DCRs) or Request for Engineering Review (RER), required as the result of corrective action for a deficiency, are initiated.
3.5 MANAGER TECHNICAL SUPPORT The Manager Technical Support (MTS) ensures:
3.5.1 Deficiency Card tracking is maintained.
3.5.2 Deficiency Cards are reviewed to determine significance and reportability.
3.5.3 Responsibility for disposition of Deficiency Cards is
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3.5.4 A complete Event Investigation is recommended, if apprepriate.
A 3.5.5 DCs and corrective actions are tracked to closure.
L 3,5.6 Deficiency Cards are trended.
l 3.5.7 Completed DCs and applicable documentation are forwarded to Document Control.
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3.5.8 A Licensee Event Report or other report is initiated, Ii if required per 00152-C.
3.5.9 Conditions identified through Deficiency Cards, l
trending of Deficiency Cards or other methods identifying significant conditions advsrae to quality, the cause cf the condition, and corrective action taken is reported to plant management, i
3.5.10 Material deficiencies are controlled to prevent inadvertent use of the material in the plant.
3.5.11 QC Hold Tags are used to identify material deficiencies in the warehouse.
3.5.12 Sequential numbers are assigned to Material Deficiency Cards.
3.5.13 A log is maintained for Material Deficiency Cards to include number assigned, date number was assigned, and Material Deficiency Card topic.
3.5.14 Material Deficiency Cards are sent to Document Control I
after closure.
3.6 MANAGER PLANT ADMINISTRATION I
The Manager Plant Administration ensures:
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3.6.1 The Materials Group provides the disposition for I
material deficiencies including the required corrective actions.
3.6.2 The Supervisor Materials approves material deficiencies i
dispositioned "use-as-is" or " repair".
3.6.3 The Materials Engineering Group Supervisor approves all l
l other dispositions for material deficiencies.
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-3.7 DEPARTMENT MANAGERS u
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b Department managers are responsible for:
1 3.7.1 Dispositioning assigned-deficiencies.
3.7.2 Ensuringtherootcauseisdeterminedforass'iined deficiencies and the required corrective actions are identified and itnplemented as assigned.
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4.0 INSTRUCTIONS FOR INITIATION OF A DEFICIENCY CARD 4.1 Plant personnel are required to initiate a Deficiency Card (Figure 1) when a deficiency is identified, with j
the-exceptions noted in 4.2.
4.2 Deficiency Cards are required to be generattid for safety-related equipment, conditions, or activities i
that do not conform with specified requirements of 9-design documents, procedures, and/or regulatory 4
commitments except as delineated in 4.2.1 through 4.2.4.
DC's are also required for all conditions determined to be rep' Federal And State Reporting ortable in accordance with Procedure 00152-C, Requirements".
The.following are conditions where 4
deficiency cards are NOT required.
4.2.1-For installed equipment malfunctions or failures i
requiring " Maintenance",-Procedure 00350-C, " Work i
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Request Program" and appropriate Outage and Planning l
Department procedures are to be used to document, E
perform and trend ?orrective maintenance actions and to 1
assess operability and reportability, t
4.2.2 For_ Security-related deficiencies, other than events requiring a 30-day written report (Licensee Event Rapart) Securi.ty De.nartment. procedures are to be used i
l-to document and trend' security deficiencies and their j
resolution.
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4.2.3 For._ fire protection related deficiencies, other than i
those requiring a 30 day written report (Licensee Event Report), the appropriate Operstions Department Fire ll Protection procedure is to be used to document and l
. trend fire protection deficiencies and resolution.
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VECP 00150-C 10 8 of 22 4.2.4 Administrative deficiencies that are documented and rescived through departmental processes, do not require Deficiency Cards, as defined by this procedure.
The departmental process should trend the deficiencies if appropriate, and take corrective action.
If.
significant trends develop, as determined by the TpKTeable department manager, a Deficiency Card should be initiated in accordance with this procedure.
Examples of these administrative deficiencies include
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ove:Jue whole body counts, overdue training, emergency preparedness audit findings, document control audit i
findings, etc.
4.3 DeficiencyCardsarere!uiredwhenthefollowing conditions are identifi d on safety-related componentst 4.3.1 Significant discrepancies between design documents and installed equipment.
4.3.2 Identification of significant design a riors.
I 4.3.3 Noncompliance with a specification of the VEGP Technical Specifications (e.g., when the requirements of the LCO and associated action requirements are not met within the specified time).
4.3.4 Significant failure of, or damage to, a safety-related item which keeps the system from performing its intended function.
4.3.5 Deficiencies involving safety-related components which are to be dispositioned "Use-as-is or Repair".
4.3.6 Other conditions involving safety-related components which require Engineering Support or other technicci assistance to determine if the component is deficient.
4.3.7 Failure to satisfactorily pass a fi.1al QC inspection or other significant problem identified by QC 4.3.8 Any radiological deficiency as follows:
4.3.8.1 An individual exceeds an authorized administrative limit as i,pecified in 00920-0, " Radiation Exposure Limits".
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QEvisioM DAGE No.
'vtGP 00150-0 10 9 of 22 4.3.8.2 A knovn high radiation area is found improperly posted, or a high radiation area having general area dose rates greater than 1000 millirem per hour is found without proper locks or barricades in place.
l 4.3.8.3 An entry is made to any costed high radiation area without an RWP and/or without proper monitortn'g as described in 00930-C. " Radiation And Contamination Control".
4.3.8.4 VEGP licensed radioactive material is lost, stolen, or discovered unattended outsidc of an established RCA or radioactive material storage area.
NOTE Report requirements for on-site e >.
es licensed :o a vendor.
adt grapher, or other contractor use decided on a case-by-case basis by Manager HP/ Chemistry.
4.3.8.5 Radioactive contamination exceeding station limits for uncontrolltd release is discove.ed outside of an RCA.
4.3.8.6 An individual receives exposure to airborne radioactivity exceeding 40 MPC-hours in any seven consecutive days.
4.3.8.7 An individual is contaminated and sustains an injury necessitating on-site first-aid actions only.
4.3.8.8 Work is stopped and personnel are evacuated because of an unexpected deterioration of radiological conditions in the immediate work area.
4.3.8.9 An individual's work actions result in repeated radiological deficiencies.
4.3.9 Deficiencies in ecmputer codes / program classified as basic components.
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NOTE Individuals identifying deficiencias may consult with their supervisor or I
the Technical Support Department for assistance in determining whether the condition requires a Deficiency Card.
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l 4.4 COMPLETION AND PROCESSING OF DEFICIENCY CARDS The individual identifying the deficiency should complete Block 1 of the Deficiency Card and deliver the Deficiency Card to the Unit Shift Supervisor (USS).
I N0'tE Completion of the Deficiency Card and submittal to the Control Room should be completed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> j
after determining that a deficiency j
r.xists.
Do not use the mail to forward Deficiency Cards to the Unit Shift Supervisor.
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- 1 4.5 The originator should include sufficient information to clearly identify the deficient condition.
Additional sheets should be attached, if needed.
4.6 The USS may require the initiator to provide additional I
information for any DC that does not contain sufficient information to evaluate the deficiency.
4.7 After receiving the Deficiency Card the Unit Shift l
Supervisor will assign the card a Deficiency Card Number.
This number will be of the form N-YY-XXXX where N is he applicable unit. YY is the last two digits of tne current year and XXXX is a sequential number beginning with 0001 for each new year.
4.8 The USS will review the Deficiency Card to decemine if I
conditions.y action is required to maintain safe plant compensator This review should include consideration for placement of Clearance, Caution tags and/or Information tag,s.
The Unit Shift Supervisor should I
request technical assistance from applicable plant technical staff to asrist in evalucting specific components that may be deficient and the effect that equipment has on plant operations.
(These items include, but are not limited to containment isolation valves and snubbers.)
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1 4.9 The USS will review the Deficiency Card to determine the need for immediate reporting in accordance with i
Procedure 00152-C, " Federal And State Reporting I
Requirements".
If technical assistance is needed to I
determine reportability, assistance should be requested from appropriate plant staff.
NOTES j
a.
All Immediate Correctivt. Actions I'
taken by the Unit Shift Supervisor i'-
should be noted on the Deficioney Card.
This includes Work Request Tags (WRT) initiated per Procedure 00350-C and Limiting Conditions for Operation (LCO) initiated per i
Procedure 11875-C, "LCO Status Sheet",
b.
The Unit Shift Supervisor review **
I should be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> af ter submittal.
4.10 After completing the reviews required in Steps 4.8 and 4.9 the USS should complete Block 2 on the Deficiency l
Card and forward the Deficiency Card to the Technical Support Department.
4.11 The Technical Support Department will process the Deficiency Card in accordance with Procedure 80014-C.
" Handling Of Deficiency Cards".
4.12 The Technical Support Department will review each Deficiency Card for reportability in accordance with Procedure 00152-C.
The Technical Support Department review is independent of the USS review.
The Technical Support Department will receive concurrence from HP on determination of significance for deficiencies relating to radtological conditions.
4.13 If the Technical Support Department review determines the deficient condition does not recuire a Deficiency I
Card or the item should be processsec. using a different control program (i.e., 00350-C, " Work Request Program"i 90018-C, Incident Report Review", 92040-C, " Fire Protection LCO Frogram") the Tachntcal Support Department reviewer will perform the following:
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CEvtSicN DAGE No VEGP 00150-C 10 12 of 22 4.13.1 Check Block 3A of the Deficiency Card and provide an explanation of why a deficiency card is not required.
l 4.13.2 Sign and date the Reviewer section of Block 3 on the Deficiency Card.
4.13.3 Denote the responsible department based on clie item identified b
4.13.4 "N/A" the disposition section (Block 4) of the i
Deficiency Card and forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.13.5 Forward the original DC to the MTS for concurrence and signature in Block 4.
4.13.6 Forward a coay of the Deficiency Card to the appropriate Jepartment Manager for further action.
4.13.7 Forward the original Deficiency Card to Document Control for storage as a permanent record in accordance with 00100-C, " Quality Assurance Records Administration".
4 4.14 If the Technical Support Department review determines the identified deficiency is reportable, requiring a NRC vritten report, the Technical Support Department reviewer will perferm the following:
4.14.1 Check Block 3B in the Deficiency Card and provide an explanation on why it is reportable.
4.14.2 Sign and date the Peviewer section of Block 3 on the Deficiency Card.
4 4.14.3 Denote the Technical Support Department as the responsible department for dispositioning the deficiency.
4.14.4 Forward the DC to the NSAC Supervisor for concurrence and signatura in Block 3.
4.14.5 Forward a copy of the DC to the PRB for concurrence with the reportability determination and for review of potential hazards to nuclear safety.
4.14.6 If an evaluation has been initiated per Procedure 00057-C, " Event Investigation", then attach a copy of the Root Cause Determination Worksheets from the completed Event Report.
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'VEGP 00150-C 10 13 of 22 4.14.7 If no investigation is to be cerformed per Procedure 00057-C, then perform an investigation and complete a Root Case and Corrective Acti6n (RCCA) evaluation in accordanen with Procedure 00058.C. " Root Cause Determination".
4.14.8 Pre 1are a Licensee Event Report (LER) in accdrdance wita Procedure 81030-C, " Preparation And Processing Of Draft Licensee Event Reports And Special Reports" if required.
4.14.9 Denote the LER number or other special report number in Block 3B, if applicable.
4.14.10 Obtain the signature of the Manager Technical Support
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in Block 4 to close the Deficiency Card.
4.14.11 Forward the original Deficiency Card to Document Control for storage as a permanent record in accordanes with 00100-C, " Quality Assurance Records j-e.
Ade'nistration".
t 4.14.12 The Technical Support Department will enter completed L
corrective actions that require tracking and corrective j
actions awaiting implementation and/or require long term tracking in the Open Item /Cecmitment Tracking system in accordance with Procedure 00409-C "Open Item / Commitment Tracking".
4.15 If the Technical Support Department review determines i
che identified deficiency is not reportable and does not require a written report, the DC will be processed l[
as follows:
j 4.15.1 The Technical Support Department reviewer will check Block 3C, include an explanation as to why the DC is I,
not reportable and assign a responsible department to disposition the Deficiency Card and forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.15.2 The Technical Suaport Department will forward the original DC to the responsible department and a copy to the Plant Review Board for their concurrence with the reportability determination and review of potential hazards to nuclear safety.
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The responsible department assigned the DC will perform 4,15.3 the following within 30 days, Complete Block 4 of the DC with an appropriate
'4.15.3.1 disposition.
Examples of dispositions includes Use-As-Is, Repair, Rework, Reject, Obtain VSlid Documentation, Hardware Not Affected, or No-Deficiency Card Required.
Refer to Sections 2.4 to 2.10 for definitions of these dispositions, u,15.3.2 If dispositioned "No deficiency Card Required" Provide justification in Block 4 and return DC to a.
the Technical Support Department for review and concurrence.
Steps 4.15.3.3 through 4.15.3.5 may be omitted, If the Technical Support Department concure with I
b.
the disposition Block 3A vill be checked and the NSAC Supervisor will re-sign and date Elock 3.
The DC mey then be orecessed in accordance with Steps 4.13.5 througa 4.13.7.
If the Technical Support Department does not c.
concur with the disposition, the MTS and the responsible department manager will resolve any impasse.
Determine the root cause and corrective actions (RCCA) 4.15.3.3 in accordance with Procedure 00058-C, " Root Cause Determination".
The corrective actions should include actions to resolve the deficiency and actions to prevent recurrence, and milestone dates for completion i
of the actions.
Ensure corrective actions assigned to another 4.15.3.4 department have the receivin g department's concurrence.
(Corrective actions are tracted against the department assigned to complete the action.)
l Return the di'spositioned DC and'the completed =RCCA 4.15.3.5 worksheet(s) to the Technical Support Department for j
tracking.
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i VEGF 00150-C 10 15 of 22
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4.15.4 The Technical Support Department will enter completed corrective cetions that require tracking and corrective actions awaiting implenentation and/or require long term tracking in the Open Item / Commitment Tracking system in accordance with Procedure 00409-C, "Open i
Item / Commitment Tracking".
4.15.5 The Technical Support Department will close out the DC and forward the original and any supporting documentation to Document Control for storage as a permanent record in accordance with 00100-C, " Quality i
Assurance Records Administration".
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4.15.6 The Technical Support Department will provide management with a periodic status of open DCs.
t 5.0 MATERIAL DEFICIENCY CARD INITIATION 5.1 When material deficiencies are identified.,t;he individual will initiate a Material Deficiency Card (Figure 2). The individual identifying the material deficiency should complete Blocks 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12. 13, and 14 and forward the i
Material Deficiency Card to Quality Control receipt inspection personnel.
5.2 Quality control (QC) will assign the card a Material Deficiency Card Number.
This number will be of the form M-YY'-XXXX where M denotes Material Deficiency, YY is the last two digits of the current year and XXXX is a sequential number beginning with 0001 for each new i
- year, g
e 5.3 After receiving a Material Deficiency Card QC will ensure Hold Tags are cttached to the deficient 1'
material / components identified and complete Block 15 of i
the Material Deficiency "ard.
a 5.4 QC ensures the deficient material /componencs are uniquely tagged or segregated' frem' acceptable material to prevent inadvertent use in the plant.
5.5 QC will fcrward the Matarial Deficiency Card (MDC) to the Materials Engineering Group (MEG) for l
dispositioning.
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EgylgioN p4gg gg-VEGP 00150 C 10 16 of 22 5.6 HEG will disposition the Material Cerd.
The l
disposition will identify corrective actions and implementing documents for completion of corrective action (i.e., MWO numbers, RERs, etc. ).
Dispositioning of Material deficiencies will be in accoroance with Procedure 70546-C, " Evaluation And Disposition of Material Deficiency Cards".
5.7 Material deficienciee dispositioned as "use-as-is" or j
" repair" require approval by the Suaervisor Materials.
I Material deficiency dispositions otter than "use-as-is" or " repair" require approval by the MEG Supervisor.
l 5.8 MEG w.ll forward the MDC to Technical Support t
Department.
Corrective actions may be performed concurrently with the Technical Support Department review.
5.9 The Technical Support Department will determine if the is reportable in accor4Ance with material deficiency" Federal And State Reporting Procedure 00152-C, Requirements".
5.10 Material Deficiencien determined reportable will be evaluated by MEG in accordance with 00058-C, " Root i
Cause Determination".
Completed Root Cause Determination worksheets will be attached to the Material Deficiency Card.
5.10.1 The MEG will be responsible for ensuring completion of l
all correceiv.* action.
5,10.2 Upon completion of corrective action, the MEG will i
forward the Material Deficiency Card to QC for closure and hold tag removal.
l 5.10.3 For MDC's dispositioned "Use As Is" or Repair", a copy of the MDC and associated paperwork are to be mado i
part of the Quality Assurance documentation associated with the item.
5.10.4 MDCs will be forwarded to Document Control upon closure 00100-C, ge as a permanent record in accordance with for stora Quality Assurance Records Administration",
l-1 NOTE l
Use of_ conditionally released materials will be in accordance with Procedure 00853-C, " Material Identification, Control And Issue".
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6.0 DUPLICATE DEFICIENCY CARDS When a deficiency card is found to be a duplicate of a previously identified deficiency, the deficiency card will be stamped e: marked " DUPLICATE", and closed out by Technical Support.
Technical Support will forward the " duplicate" DC to Document Control for storage.
7.0 TRENDING s
7.1 All DCs should be trended to identify recurring deficiencies which night indicate procedural or programmatic breakdowns that could adversely affect the quality of the plant and associated equipment.
A trend is identified w1en a repetitive occurrence or a sustained increasing frequency of occurrence is observed and is not explainable as an occasional or isolated procedural or programmatic inadequacy.
7.2 A quarterly trend report should be prepared by the Technical Sunoort Department and distributed to Department Managers and the General Manager-Nuclear J
riant.
A copy of the trend report will also be forwarded to the Supervisor Safety Audit Engineering l
Review.
7.3 Pepartment managers should perform root cause determination in accordance with Procedure 00058-C,
" Root Cause Determination" and take appropriate corrective actions as necessary for trends identified within their departments area of responsibility.
7.4 Material Deficiency Cards (MDCs) will be trended by the Supervisor Materials.
l lj i
'l 8.0 RECORDS i
Deficiency Cards and supporting documentation shall be l
handled and maintained in accordance with Procedure 00100-C, " Quality Assurance Records Administratica".
1 4
l l
UD-o-ru ut N 1-tm MM GO 4045545314'#O99'P19 -
e PRoCfDWet No.
M,VilloN P AM no.
i
~
vgcP 00150-C 10 18 of 22-t 9.0 REFEREN_CES 9.1 ANSI N18.7 - 1976 9.2 ANSI N45.2 - 1977 I
9.3 Title 10CFR$0 Appendix B, Criteria XV and XVD 9.4 Title 10CFR$0.59, Changes, Tests & Experiments k
9.5 Title 10CFR21, Reporting of Defects and Noncompliancea
- 8; t
9.6 Title 10CFR50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors
- 9. 7_
Title 10CFR50.73, License Event Report System 9.8 Title 10CFR$0.45 (X), Conditions of Licenses-f
-9.9 Title 10CFRb0.55 (e) 9.10
' Regulatory Guide 1.33, Quality Assurance Program Requirements e
Regulatory Guide 1.38, Qua'lity Assurance Re Packing, Shipping, Receiving, Storage,andhuirements 9.12 andling of Items for Water-Cooled Nuclear Power Plants'.
'9.13 Regulatory Guide 1'123, Quality Assurance Requirements for Control of Procurement of Items and Services for.
Nuclear Power Plants.
3 1-9.14 PROCEDURES h[.
9.14.1 00057-C,
" Event Investigatiens" y
9.14.2 00058-C,
" Root Cause-Determination" l
9.14.3 00100-0,
" Quality Assurance Records Administration" 9.14.4 0015 2'-C,
" Federal And State Reporting
- Regtriremettes" 9.14.5 00350-C,
" Work Request Program" 9.14.6 00400-C,
" Plant Design Control" 9.14.7:
00409-C, "Open Item / Commitment Tracking" 9.14.8 00853-C,
" Material Identification, Cont.rol, And Issue" p
l L
o5-23-90 13:31 T-CA PtR Co 404M45214 t:0?? FIO Ii~~l f
.-PaoCEDvM No.
metnsioN PAQtNQ.
'}
VEGP 00150-0 10 19 of 23 I
l' j
9.14.9 00920-C.
" Radiation Exposure Limits" 9.14.10 00930-C,
" Radiation And Contamination Control" l
9.14.11 11875-C, "LCO Status Sheer."
9.14.12 20100-C, "ASME Section XI Repair /Replacemerit
- Program" 9.14.13 50011-C,
" Engineering Evaluation And Disposition Of Deficiency Reports" r
9.14.)
70546-C.
" Evaluation And Disposition of Material Deficiency Cards" 9.14.15 80014-C,
" Handling of Deficiency Cards" 9.14.16 81030-C,
" Preparation And Processing Of Draft Licensee Event Reports And Special Reports" 9.14.17 90018-C,
" Incident Report Review" 9.14.18 92040-C,
" Fire Protection LCO Program" l
1-il j
END OF PROCEDURE TEXT L
1
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05-23-90 17:32 T-M Pl* CO 404% C 314 00?? e4 A PA06140
~PWOCEDUREtdO.
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05-23-90 13:32 T-GA PtA CO 404554S314 nO?? F22 PAOCEDUME NO.
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03-23-90 13:33 T-GA PLP CO 4045545314 u093 P23
' PRO,CEDWAE NO.
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'PAGEHO.
~
VEGP 00150-0 10 22 of 22 MATERIAL DEFICIENCY CARD 1
MATERIAL DC NO. M-2.
P.O. No.
3.
P.O. ITEM NO.
4 No OF ITEMS 5.
M.I.R. NO.
6.
PROCUREMENT LEVEL 7.
SAFETY CLASS 8.
ITEM DESCRIPTION 9.
ITEM LOCATION 10.
VENDOR / SUPPLIER _
LOCATION 11.
DEFICIENCY 12.
CAUSE (IF KNOWN) 13.
OTHER INFORMATION 14 ORIGINATOR (PRINT)
DATE 15.
QC HOLD TAG (QTY).
QC INSPECTOR 16.
DISPOSITION:
I l'
17.
APPROVAL:
USE-AS-IS/ REPAIR (SUPV Mt.TERIALS)
DATE
{
OTHER(MEG SUPV)_
, _ DATE 18.
REPORT REQ'D YES N0 f
19.
TECH.. SUPPORT REVIEW BY:
DAIF.
20.
QC CLOSURE:
DATE FIGURE 2 (WHITE)
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. FR0f4 TILICOPY EDBER (M4) (404) 826-3611 or 8-695-M11 Ytl1FICATION 3R#tilR (404) 826-3811 or 8-695-3611 E@!PMENT: CA40R FAIPHONE 20 raccorr exam on4 mas cam 5-23-90 sins 2: 00 AL CHAFFEE Che<&
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Vogtle Electric Cenerating plant NUCLEAM OPERATIONS
-C OWON Georgia Power f O [8 Unit e.s. w..
1 of 22 MANUIL '[
DEFICIENCY CONTROL 1.0 PURPOSE AND SCOPE This procedure describes the requirement and responsibilities for identifying, evaluating, reporting, and dispositioning deficiencies at the Vogtle Electric Generating Plant.
The procedure also provides the details for processing Deficiency Cards generated when a deficiency is identified.
2.0 DEFINITIONS 2.1 DEFICIEN'.Y A deficier.cy is a non conforming condition adverse to quality, such as failures, malfunctions, deviations, and defective material and equipttent.
For additional guidance, refer to section 4.0 2.2 RADIOLOGICAL DEFICIENCY A radiological deficiency is an unsatisfactory radiological condition or personnel performance which could lead to increased perennel exposure.
- 2. 3-MATERIAL DEFICIENCY haterials, parts or components which are identified du ing receipt inspection or during storage, as failing to conform to specified requirements.
2.4 USE-AS-IS A disposition which may be imposed for a deficiency when it can be established that the deficient item will rcoult in no adverse conditions and that the item under consideration will continue to meet applicable requirements including performance, maintainability, fit, and safety.
w
f (15-2!-90 !!ilb T-Ce R A CO 4D4b545214 120.via P03 f%OQEDUwE NO.
REViblON PAGE 40 VEGP 001$0-C 10 2 of 22
__f 2.5 REPAIR A disposition and the process of restoring a deficient characteristic to a condition such that the capability of the item to function reliably and safely is unimaaired, even though the item still may no,t. conform to the original requirement.
2.6 REWO:$
A disposition and the process by wh11h a deficient item is made to conform to a completion, remachining, prior specifsed requirement by reassembling, or other corrective means.
2.7 REJECT A disposition imposed when the deficient item in present condition is unacceptable for intended use.
2.8' OBTAIN VALID DOCUMENTATION A disposition imposed as a result of incorrect or incomplete quality assurance documentation, including existing issued drawings.
2.9 HARDWARE NOT AFFECTED A disposition assigned when a deviation from procedures or programs occurs that in no way alters or deviates from the design or changes any hardware.
2.10 NO DEFICIENCY CARD REQUIRED l
A disposition assigned when it is determined that no deficiency exists or that the identified deficiency should be dispositioned using other administrative controls.
2.11 QC HOLD TAG A tag used to identify non-conforming materials.
??).45
05-17-90 !!!19 T-M pia C0 4045545!14 up?? F04 PROCf DUME NO REvtStoW PQ0E NO VEGP 00150-C 10 3 of 22 2.12 NOTIFICATION Notific ition to appropriate regulatory agencies as described in Procedure 00152-C, " Federal And State Reporting Requirements".
2.13 IMMEDIATE CORRECTION ACTION Actions directed by the Unit Shift Supervisor (USS) to place the plant in a safe condition, comply with license requirements, and return equipment to normal operating conditions.
2.14 DEFICIENCY CARD (DC)
A card, similar to that shown in Figure 1 used to identify deficiencies, r.
2.15 MATERIAL DEFICIENCY CARD (MDC)
A card, similar to that shown in Figure 2, used to identify material deficiencies.
2.16 DEFICIENCY CARD NUMBER A unique number assigned to a yellow Deficiency Card (Figure number))1) (i.e., 1-87-0001 (unit-year-sequential DCs on common systems will use Unit 1 prefix.
2.17 MATERIAL DEFICIENCY CARD NUMBER A unique number assigned to a white deficiency card (Figure 2)
(i.e., M-87-001 (material-year-sequential numser)).
1.18 LONG TERM CORRECTIVE ACTION t
Actions recommended to prevent recurrence.
These actions are determined after root cause determination, i
f es-:Mc neo Ma ric co acasta5na ce?+ Pe5 P,.oCEDURE No LEVs5loN PAGE No 1
),
VEGP 00150-c 10 4 of 22 2.19 CONDITIONAI. RELEASE Allowing an item / component which has been received but has been found unacceptable, to be installed in the plant, but may not be relied upon to perform its intended function.
Consumable materials are.not conditionally released.
i l
2.20 SAFETY-RELATED 2.20.1 ankeleElectricGeneratingPlant Vo structures, systems, components necessary to assures a.
integrity of the reactor coolant pressure
- boundary, l
b, capability to shut down the reactor and maintain it in a safe shutdown condition, or capability to arevent or mitigate the consequences c.
of accidents which could result in off-site expos. ires that exceed the guidelines established in 10CFR 100.
2.20.2 Systems or com class 0, 1, 2,ponents designated as nuclear safety or 3 and listed in FSAR Table 3.2.2-1:
and instrumentation. designated category 1 or 2, as listed in FSAR Table 7.5.2-1: Fire Protection Systems / Components as described in the Fire Protection Program (see 92000-C): Radwaste Systems / Components having Project Classification of XX7, where XX are safety class and seismic class, respectively.
NOTE Procedure 11850-C,
" Safety-Related Equipment Classification" contains the information listed in FSAR Table 3.2.2-1 and FSAR Table 7.5.2-1, 3.0 RESPONSIBILITIES 3.1 GENERAL MANAGER-NUCLEAR PLANT The General Manager-Nuclear Plant has the overall responsibility to implement the deficiency reporting system.
1
'0J886 e-
O!-C-?O 17 t ;0 T-% AG CC 404554t!14 18299 Ki 7
PAoCEDURE No.
AEvlBioN PME No.
VEGP 00150-C 10 5 of 22 i
3.2 PLANT REVIEW BOARD (PRB)
I The PRB:
3.2.1 Reviews deficiencies designated as 3B or 3C for concurrence with the reportability determination and for detection of potential hazards to nucleer safety.
PRB recommendations regarding corrective actions will be forwarded to appropriate individuals.
3.2.2 Reviews the rco: cause and corrective actions taken for reportable items.
This review is performed as part of the PRD review of reportatio items.
I 3.3 UNIT SUPERVISOR (USS)/0PERATIONS The USS:
3 i
3. 3. '.
Evaluates Jeficiency Cards for immediate reportability.
The Shift Superintendent (SS)'will make required l
notification to regulatory agencies.
3.3.2
-Evaluates affect on plant operation and initiates compensatory action as required.
3.3.3 Assign 8 sequential numbers to Deficiency Cards.
3.3.4 Maintains a number assignment log for Deficiency Cards to include number assigned, date number una assigned, and Deficiency Card topic.
3.4 MANAGER ENGINEERING SUPPORT The Manager Engineering Support (MES) ensures Design Change Requests (DCRs) or Request for Engineering Review (RER), required as the result of corrective action for a deficiency, are initiated.
3.5 MANAGER TECHNICAL SUPPORT The Manager Technical Support (MTS) ensures:
3.5.t Deficiency Card tracking is maintained.
3.5.2 Deficiency Cards are reviewed to determine significance and reportability.
3.5.3 Responsibility for disposition of Deficiency Cards is assigned.
Oi-I,7-iQ k ? t il T-% 0 W f.O 4CC".'#. ? id UDi'It Ec7 l
c o
P Acc tDVQtt NO Rt tflOON PAQt No VEGP 00150-C 10 6 of ?.?
3.5.4 A complete Event Investigation is recommended, if appropriate.
1 3.5.5 DCs and corrective actions are tracked to closure.
3.5.6 Deficiency Cards are trended.
3.5.7 Completed DCs and applicable documentation are forwarded to Document Control.
4 3.5.8 A Licensee Event Report or other report is initiated, I
if required per 00152-C.
3.5.9 Conditions identified through Deficiency Cards, trending of Deficiency Cards or other methods identifying si3nificant conditions adverse to quality, the cause of tas condition, and corrective action taken is reported to plant management.
3.5.10 Material deficiencies are controlled to prevent inadvertent use of the material in the ptant.
3.5.11 QC Hold Tags are used to identify material deficiencies in the warehouse.
3.5.12 Sequential numbers are assigned to Material Deficiency 1
- Cards, i
3.5.13 A log is maintained for Material Deficiency Cards to include number assigned, date number wac assigned, and Material Deficiancy Card topic.
3.5.14 Material Deficiency Cards are sent to Document Control I
after closure.
3.6 MANAGER PLANT ADMINISTRATION I
The Manager Plant Administration ensures l
3.6.1 The Materials Group provides the disposition for I
craterial deficiencies including the required ccrrective actions.
3.6.2 The Supervisor Materials approves material deficiencies I
dispositioned "use-as-is" or " repair".
3.6.3 The Materials Engineering Group Supervisor approves all i
other dispositions for material deficiencies.
A L
M
+
0$-1MO 12:22 T-CA hp CO C4'54'J31411039 F03
'IMoCLOVAt No REvisiotJ-Pagt No VEOP 00150-C 10 7 of 22 i
3.7 DEPARTMENT MANAGER 3 Department managers are responsible fors 3.7.1 Dispositioning assigned deficiencies.
3.7.2 Ensuring the root cause is determined for assigned deficiencies and the required corrective actions are identified and implemented as assigned.
.x 4.0 INSTRUCTIONS FOR INITIATION OF A DEFICIENCY CARD 4.1 Plant personnel are required to initiate a Deficiency Card (Figure 1) when a deficiency is identified, with the exceptions noted in 4.2.
4.2 Deficiency Cards are required to be generattd for safety-related equipment, conditions, or activities that do not conform with specified requirements of design documents, procedures, and/or regulatory commitments except as delineated in 4.2.1 through 4.2.4.
DC's are also required for all conditions determined to be rep'ortable in accordance with Procedure 00152-C, Federal And State Reporting Requirements".
The. following are conditions where deficiency cards are NOT required.
4.2.1 For-installed equipment malfunctions or failures requiring " Maintenance", Procedure 00350-C, " Work Request Program" and appropriate Outage and Planning Department procedures are to be used to document, perform and trend corrective maintenance actions and to assess operability and reportability.
4.2.2 For Security-related deficiencies, other than events requiring a 30-day written report (Licensee Event Rapostl Security Denartmunt-procedures are to be used I
i to document and trend security deficiencies and their resolution.
4.2.3 For fire protection related deficiencies, other than those_ requiring a 30 day written report (Licensee Event Report), the appropriate Operations Department Fire Protection procedure is to be used to document and trend fire protection deficiencies and resolution, l
-]
es-n 30 r;e.t t-sea n c co ac. cama uen res AoptDu-t No 4tv@oN PAor, so VEGP 00150-C 10 8 of 22 4.2.4 Administrative deficiencies that are documented and resolved through departmental processes, do not require Deficiency Cards, as defined by this procedure.
The departmental process should trend the deficiencies if appropriate, and take corrective action.
If -
sinnificant trends develop, as determined by,t.he applicable department manager, a Deficiency Card should be initiated in accordance with this procedure.
Examples of these administrative deficiencies include overdue whole body counts, overdue training, emergency preparedness audit findings, document control audit findings, etc.
4.3 Deficiency Cards are required when the following conditions are identified on safety-related components:
4.3.1 Significant discrepancies between design documents and installed equipment.
4.3.2 Identification of significant design errors.
4.3.3 Noncompliance with a specification of the VEGP Technical Specifications (e.g., when the requirements of the LCO and associated action requirements are not met within the specified time).
4.3.4 Significant failure of, or damage to, a safety-related item which keeps the system from performing its intended function.
4.3.5 Deficiencies involving safety-related components which are to be dispositioned "Use-as-is or Repair".
4.3.5 other conditions involving safety-related components which require Engineering Support or other technical assistance to determine if the component is deficient.
4.3.7 Failure to satisfactorily pass a final QC inspection or other significant problem identified by QC
-4.3.8 Any radiological deficiency as follows:
4.3.8.1 An' individual exen Js an authorized administrative limit as specified in 00920-C, " Radiation Exposure Limits",
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_c.s m t : u u m r 1 c PacCC Duf4C fvC
- 1vi$iOH PA'ak No VEcP 00150-c 10 9 of 22 4.3.8.2 A known high radiation area is found improperly posted, or a high radiation area having general area dose rates greater than 1000 millirem per hour in found without proper locks or barricades in place, 4.3.8.3 An entry is made to any costed high radiation area without an RWP and/or without proper monitortig as described in 00930-C, " Radiation And Contamination Control".
4.3.8.4 VEGP licensed radioactive material is lost, stolen, or discovered unattended outside of an established RCA or radioactive material storage area.
NOTE Report requirements for on-site sources licensed to a vendor, radiographer, or other contractor are decided on a case-by-case basis by Manager HP/ Chemistry.
4.3.8.5 Radioactive contamination exceeding station limits for uncontrolled release is discovered outside of an RCA.
4.3.8.6 An individua. receives expcsure to airborne radioactivity exceeding 40 MPC-hours in any seven consecutive days.
4.3.8.7 An individual is contaminated and sustains an injury necessitating on-site first-aid actions only.
4.3.8.8 Work is stopped and personnel are evacuated because of an unexpected deterioration of radiological conditions in the immediate work area.
4.3.8.9 An individual's work actions result in repeated radiological deficiencies.
4.3.9 Deficiencies in computer codes / program classified as basic components.
NOTE Individuals identifying deficiencies may consult with their supervisor or the Technical Support Department for assistance in determining whether the condition requires a Deficiency Card, t
Y }.4 h
.. ~
i P. OCEDVat No 5t t VilloN PAGt No, VEGP-00150-C 10 10 of 22 4.4 COMPLETION AND PROCESSING OF DEFICIENCY CARDS i
The individual identifyi the deficiency should completeBlock1oftheD!ficiencyCardanddeliverthe l
Deficiency Card to the Unit Shift Supervisor (USS).
I h0TE J
Completion of the Deficiency Card and autmittal to the Control Room s
should be completed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after determining that a deficiency exists.
Do not use the mail to forward Deficiency Cards to the Unit Shift Supervisor.
I 4.5 The originator sho nelude sufficient information to a
clearly identify thw weficient condition.
Additional sheets should bt attached, if needed.
++
4.6 The USS may require the initiator to provide additional I
information for any DC that does not contain sufficient information to evaluate the deficiency.
i 4.7 After receiving the Deficiency Card the Unit Shift-(
Supervisor will assign the card a Deficiency Card Humber.
This number will be of the form N-W-XXXX where N is the applicable unit, YY is the last two digits of the current year and XXXX is a sequential number beginning with 0001 far each new year.
4.8 The USS will review the Deficiency-Card to determine if I
i conditions.y action is required to maintain safe plant compensator This review ehould include consideration for placemene of Clearance, Caution tags and/or Information tags.
The-Unit Shift Supervisor should I
r request technical assistance from applicable plant technical staff to assist-in evaluating specific
-components that may be deficient and the effect that equipment has on plant operations.
(These items include, but are not limited to containment isolation valves and snubbers.)
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VEGP 00150-C 10 11 of 22 4.9 The USS will review the Deficiency Card to determine I
the need for immediate reporting in accordance with Procedure 00152-C, " Federal And State Reporting Requirements".
If technical assistance is needed to determine reportability, assistance should be requested from appropriate plant staff.
NOTES a.
All Immediate Corrective Actions taken by the Unit Shift Supervisor I
should be noted on the Deficiency Card.
This includes Work Request Tags (WRT) initiated per Procedure 00350-0 and Limiting Conditions for Operation (LCO) initiated per Procedure 11875-C, "LCO Status Sheet".
-b.
The Unit Shift Supervisor review **
I should be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after submittal.
4.10 After completing the reviews required in Steps 4.8 and 4.9 the USS should complete Block 2 on the Deficiency l
Card and forward the Deficiency Card to the Technical Support Department.
4.11 The Technical Support Department will process the Deficiency Card in accordance with Procedure 80014-C,
" Handling Of Deficiency Cards".
4.12 The Technical Support Department will review each Deficiency Card for reportability in accordance with Procedure 00152-C.
The Technical Support Department review is independent of the USS review.
The Technical Support Department will receive concurrence from HP on determination of significance for deficiencies relating to radiological. conditions.
i 4.13 If the Technical Support Department review determines the deficient condition does not recuire a Deficiency l
Card or the item should be processec, using a different control program (i.e., 00350-C, " Work Request Program":
90018-C, Incident Report Review", 92040-C, " Fire Protection LCO Program") the Technical Support Department reviewer will perform the following:
A n
9 Ot s : :. 1 ;) :- % i ; *,; CJP Jt:;4 n M L1:
~
P.,0CE0unE No LE vi5'c N
& AGE No
[
VE)P 00150-C 10 12 of 22 4.13.1 Check Block 3A of the Deficiency Card and provide an explanation of why a deficiency card is not required.
i 4.13.2 Sign and date the Reviewer section of Block 3 on the Deliciency Card.
4.13.3 Denote the responsible departmer.t based on clie item identified 4.13.4 "N/A" the disposition section (Block 4) of the Deficiency Card and forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.13.5 Forward the original DC to the MTS for concurrence and signature in Block 4 4.13.6 Forward a coay of the Deficiency Card to the appropriate Jepartment Manager for further action.
4.13.7 Forward the original Deficiency Card to Document Control for storage as a permanent record in accordance with 00100-C, " Quality Assurance Records Adminis t ra tion".
4.14 If the Technical Support Department review determines the identified deficiency is reportable, requiring a NRC written report, the Technical Support Department reviewer will perform the following:
4.14.1 Check Block 3B in the Deficiency Card and provide an explanation on why it is reportable.
4.14.2 Sign and date the Reviewer section of Block 3 on the Deficiency Card.
4.14.3 Denote the Technical Support Department as the responsible department for dispositioning the deficiency.
4.14.4 Forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
I 4,14.5 Forward a copy of the DC to the PRB for concurrence with the reportability determination and for review of potential hazards to nuclear safety.
4.14.6 If an evaluation has been initiated per Procedure 00057-C, " Event Investigation", then attach a copy of the Root Cause Determination Worksheets from the completed Event Report.
0"-2.MQ 12: 26 T-CA R F CO 4045t4S?14 #0'.4 F13 PROCEDURE so.
REvlSION PAGEP9 VEGP 00150-C 10 12 of 22 4.13.1 Check Block 3A of the Deficiency Card and provide an explanation of why a deficiency card is not required.
I
<2 Si n and date the Reviewer section of Block 3 on the De iciency Card.
4.1J.3 Dencte the responsible department based on tiie item identified "N/A" the disposition section (Block 4)
.f the e
I Deficiency Card and forward the DC to th4 NSAC l
Supervivo'r for concurrence and signature in Bloch 3.
Forward the original DC to the MTS for concurrence and s
signature in Block 4.
]
4..
.c Forward t. copy of the Deficiency Card to the 5
appropriate Departtent Manager for further action.
Y 4.13.7 Forward the original Deficiency Card to Document Control for storage as a permanent record in accordance with 00100-C, " Quality Assurance Records Administration".
4.14 If the Technical Support Department review determines the identified deficiency is reportable, requiring a WRC written report, the Technical Support Department reviewer uf.11 perform the following:
i 4.14.1 Check Block 3B in the ieficiency Card and provide an explanation on why it is reportablo.
4.14.2 Sign and date the Reviewer section of Block 3 on the Deficiency Card.
4.14.3 Denote the Technical Support Department as the responsible department for dispositioning the deficiency.
4.16.4 Forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.14.5 Forward a copy of the DC to the PRB for concurrence with the raporte.bility determination and for review of potential hazards to nuclear safety.
4 L4.6 If an evaluation has been initiated per Procedure n0057-C, " Event Investigation", then attach a copy of the Root Cause Determination Worksheets from the completed Event Report.
m J
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,3g a m T-c+ na cc aoats z w na?? n a j
i.EvisioN FAGE No 0
m: rn-C 10 13 of 22 cicncy Carf n s
'icncy' card u w -
investigation is to be oerformed per Procedurr m <
ta 7-C, then perform an investigation and complete a case and Corrective Act16n (RCCAi evaluation in section cf 3.; ' - '
Manen with Procedure 000$8-C, " Root Cause mination".
l;rtmnt*0LiL '
~
re a 1.icensee Event Report (LER) in acedr" dance Procedure 81030-C, " Preparation And Processin on (B!cek -
' Licensee Eve'..t Reports And Special Reports" g Of if
~'-
tho DC :: :r i
- ared, cnd sinntre the LER number or other special report number in 4
tha MTS fr =^r ~
- S 3B, if applicable.
>4n the signature of the Manager rechnical Support
^1 enc Ct:n ~
luck 4 to close the Deficiency Card.
~
$ger*yfor i=
n *.
>3rd the original Deficiency Card to Document
,nney Cart * %=a "al for storage as a permanent record in accordance 90100-C, "Ouality Assurance Records
$rmanentre:::/
. wi rcnce Ft r-c-
,istration".
Technical Support Department will enter completed 3ctive actions that require tracking and correctiva ans awaiting implementation and/or require long n
rn u - um Npartmen:
Ghnical Sur r a r -
tracking in the Open Item / Commitment Tracking a rcport.42 n r t a in accordance with Procedurc 00409-C, "Open
, 311cuine JCotnitment Tracking".
gicncy Ccn er~.
'he Technical Support Department review determines 9 portable identified deficiency is not reportable end does require a written report, the DC will be processed v
soctior n i c_
follows:
De Technical Support Department reviewer will check
, t Der c rrrr. a -
lock 3C, include an explanation as to why the DC is I
dispor r = m -
wt reportable and assign a responsible department to 1.iisposition the Deficiency Card and forward tne DC to the NSAC Supervisor for concurrence and signature in Fiperva r t- ~:-
Block 3.
The Technical Support Department will forward the 3
0"iginal DC to the responsible department and a copy to 9 the FF2.:r - um xmins n m
the Plant Review Board for their concurrence with the Dr safe--
reportability determination and review of potential hacards to nuclear safety, inititre w Son", rbu m Dn WO ri:!iir:0 - '
'C)u$
05 U-90 12:26 T-GA Pt!P CO 4045545214 #0M P12 P.;oCEDUAE No.
REV.34oN PAGE No VEGP 00150-C 10 12 of 22 4.13.1 Check Block 3A of the Deficiency Card and provide an explanation of why a deficiency card is not required.
l 4.13,2 Sign and date the Reviewer section of Block 3 on the Deficiency Card.
4.13.3 Denote the responsible department based on th'e item identified 4.13.4 "N/A" the disposition section (Block 4) of the Deficiency Card and forwerd the DC to the NSAC Superviso'r for concurrence and signature in Block 3.
4.13.5 Forward the original DC to the MTS for concurrence and signature in Block 4.
4.13.6 Forward a coay of the Deficiency Card to the appropriate ?epartment Manager for further action.
4.13.7 Forward the original Deficiency Card to Document Control for storage as a permanent recoid in accordance with 00100-C, " Quality Assurance Records Adminis t ration".
4.14 If the Technica' Support Department review determines the identified eeficiency is reportable, requiring a NRC written report,.the Technical Support Department reviewer will perform the following:
4.14.1 Check Block 3P in the Deficiency Card and provide an explanation on why it is reportable.
4.14.2 Sign and da*3 the Reviewer section of Block 3 on the Deficiency Card.
4.14.3 Denote the Technical Support Department as the responsible department for dispositioning the deficiency, a
4.14.4 Forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.14.5 Forward a copy of the DC to the PRB for concurrence with the reportability determination and for review of potential hazards to nuclear safety.
4.14.6 If an evaluation has been initiated per Procedure 00057-C, " Event Investigation", then attach a copy of the Root Cause Determination Worksheets from the completed Event Report.
1
.1 05-12-90 13:20 T-% fur CO 4045545314 MOP? F14 pro 6EDUQE No-CEvi$loN PAGE No VEGP 00150-C 10 13 o f 22 4.14.7 If no investigation is to be performed per Procedure 00057-C, then perforn an investigation and complete a Root Case and Corrective Action (RCCA) evaluation in accordance with Procedure 00058-C, " Root Cause Determination".
4.14.8 Pretare a Licensee Event Report (LER) in acedr' dance with Procedure 81030-C, " Preparation And Processing Of Draft Licensee Event Reports And Special Reports" if required.
4.14.9 Denote the LER number or other special report number in Block 3B, if applicable.
4.14.10 Obtain the signature of the Manager Technical Support in Block 4 to close the Deficiency Card.
4.14.11 Forward the original Deficiency Card to Document Control for storage as a permanent record in accordance with 00100-C, " Quality Assurance Records e+
i Administration".
4.14.12 The Technical Support Department will enter completed corrective actions that require tracking and corrective actions awaiting implementation and/or require long term tracking in the Open Item / Commitment Tracking system in accordance with Procedure 00409-C, "Open Item / Commitment Tracking".
4.15 If the Technical Support Department review determines the identified deficiency is not reportable and does not require a written report, the DC will be processed j
as follows:
4.15.1 The Technical Support Department reviewer will check Block 3C, include an explanation as to why the DC is I
not reportable and assign a responsible department to disposition the Deficiency Card and forward the DC to the NSAC Supervisor for concurrence and signature in Block 3.
4.15.2 The Technical Su1 port Department will forward the original DC to the responsible department and a copy to the Plant Review Board for their concurrence with the reportability determination and review of potential hatards to nuclear safety.
i 1
05-Z M O 12:2 T +4 F# CO 4045545;14 40 N R15 1
? PAGE No REW51oN
- ~ PROCEDURE No.
14 of 22 10 VEGp 00150-C The responsible department assigned the DC will perforn 4.15.3 the following within 30 days.
Complete Block 4 of the DC with an appropriateExamples o 4.15.3.1 disposition.
Obtain Valid Use-As-Is, Repair, Rework, Rej ect, Hardware Not Affected, or No-Defici Documentation, Refer to Sections 2.4 to 2.10 for Card Required.
definitions of these dispositions.
l If dispositioned "No deficiency Card Required" 4.15.3.2 Provide justification in Block 4 and return DC to for review and the Technical Support DepartmentSteps 4.15.3.3 through 4.15 a.
concurrence.
be omitted, If the Technical Support Department concurs w b.
snd date Block 3.
NSAC Supervisor will re-sigtThe DC may then be ?rocesse Steps 4.13.5 through 4.13.7.
If the Technical Support Department does not concur with the disposition, the MTS and the c.
responsible department manager will resolve any impasse.
Determine the root cause and corrective acticas (RCCA)
Cause in accordance with Procedure 00058-C, "RootThe corrective ac 4.15.3.3 Determination".
actions to resolve the deficiency and actions to prevent recurrence, and milestone dates for completion of the actions.
Ensure corrective actions assigned to another department have the receiving department's concurrence.
4.15.3.4 (Corrective actions are tracked against the der?rtment assigned to complete the action.)
Return the dispositioned DC'and the completed RCCA s
4.15.3.5 worksheet(s) tracking.
i i
=
05-U-90 13:29 T-G4 PtR CO 4045545314 #0?9 P16 MOCEoVRE No.
REvlStoN -
. PAGE No VEGP_
00150-C 10 15 of 22 4.15.4 The-rechnical Support Department will enter completed corrective actions that require tracking and corrective actions awaiting implementation and/or require long term tracking in the Open Item / Commitment-Tracking system in accordance with Procedure 00409-C, "Open Item / Commitment Tracking".
4.15.5 The Technical Support Department will close out the DC and forward the original and any supporting documentation to Document Control for storage as a permanent record in accordance with 00100-C, " Quality Aseurance Records Administration".
4.15.6 The Technical Support Department will provide management with a periodic status of open DCs.
5.0 MATERIAL DEFICIENCY CARD INITIATION When material deficiencies are identified,'n'he 5.1 t
individual will initiate a Material Deficie cy Card (Figure 2). The individual identifying the material deficiency should complete Blocks 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, and 14 and forward the Material Deficiency Card to Quality Control receipt inspection personnel.
5.2 Quality Control (QC) will assign the card a Material Deficiency Card Number.
This number will be of the fcrm M-YY'-XXXX where M denotes Material Deficiency, YY is the last two digits of the current year and XXXX is a sequential number beginning with 0001 for each new
- year, 5.3 After receiving a Material Deficiency Card QC will ensure Hold Tags are attached to the deficient I
material / components identified and complete Block 15 of the Material Deficiency Card.
5.4 QC ensures the deficient material / components are uniquely tagged or segregated from acceptable marerial to prevent inadvertent use in the plant.
5.5 QC will forward the Material Deficiency Card (MDC) to the Materials Engineering Group (MEG) for l
dispositioning.
l L-sac 4
05-IG-90 13:29 T-CG F1P to 40455-15314 #0M n17 PRocEDUAE do REvlSioN OAGE Mo.
g o
VEGP 001500C 10 16 of 22 5.6 MEG will disposition the Material Card.
The I
disposition will identify corrective actions and implementing documents for completion of corrective action (i.e.. MWO numbers, RERs, etc.).
Dispositioning of Material deficiencies will be in accordance witu Procedure 70546-C, " Evaluation And Disposition Of Material Deficiency Cards".
5.7 Material deficiencies dispositioned as "use-as-is" or
" repair" require approval by the Suaervisor Materials.
1 Material deficiency dispositions other than "use-as-is" or " repair" require approval by the MEG Supervisor.
l 5.8 MEG will forward the MDJ to Technical Support I
Department.
Corrective action. may be performed i
concurrently with the Technical Support Department review.
5.9 The Technical Support Department will determine if the material deficiency" Federal And State Reportingis reportable Procedure 00152-C, Requirements".
5.10 Material Deficiencies determined reportable will be evaluated by MEG in accordance with 00058 C. " Root 1
Cause Determination".
Completed Root Cause Determination worksheets will be attached to the Material Deficiency Card.
5.10.1 The MEG will be responsible for ensuring completion of l
all corrective action.
5.10.2 Upon completion of corrective action, the MEG will l-forward the Material Deficiency Card to QC for closure and hold tag removal.
l 5.10.3 For MDC's dispositioned "Use As Is" or Repair", a copy of the MDC and associated paperwork are to be made part of the Quality Assurance documentation associated with the item.
5.10.4 MDCs will be forwarded to Document Control upon closure for storage as a permanent record in accordance with 00100-C, Quality Assurance Records Administration".
NOTE Use of conditionally released materials will be in accordance with Procedure 00853-C. " Material Identification, Control And Issue".
=-
.. - ~ - -
- +-
05-2 M O 13:2? T-GA FUR to 404S545;14 cc M R15 PRoCE0VZE No.
MEvlSlord FAGE t.L.
VEGP 00150-C 10 14 of 22 4.15.3 1me responsible department assigned the DC will perforn the following within 30 days,
'4.15.3.1 Complete Block 4 of the DC with an appropriate disposition.
Examples of dispositions include:
Use-As-Is, Repair, Rework, Rej ect, Obtain Valid Documentttion, Hardware Not Affected, or No-Deficiency Card Required.
Refer to Sections 2.4 to 2.10 for definitions of these dispositions.
4,15.3.2 If dispositioned "No deficiency Card Required" a.
Provide justification in Block 4 and return DC to the Technical Support Departmect for review and concurrence.
Steps 4.15.3.3 through 4.15.3.5 may be omitted, b.
If the Technical Support Department concurs with the disposition, Block 3A will be checked and the 1
NSAC Supervisor will re-sign and date Elock 3.
The DC may then be atocessed in accordance with Steps 4.1.1.5 through 4.13.7.
c.
If the Technical Support Department does not concur with tha disposition, the MTS and the responsible department manager will resolve any impasse.
4.15.3.3 Determine the root cause and corrective actions (RCCA) in accordance with Procedure 00058-0, " Root Cause Determination".
The corrective ac: ions should include actions to resolve the deficiency a.nd actions to prevent recurrence, and milestone dates for completion of the actions.
4.15.3.4 Ensure corrective actions assigned to another department have the receiving department's concurrence.
(Corrective actions are tracked against the department arsigned to complete the action.)
4.15.3.5 Return the di'spositioned DC'and'the' completed RCCA worksheet(s) to the Technical Support Department for
- tracking, i
l
M i M AA A A N cc acc un u noie PM
- PAocEDUQE No.
~
PE vr$foN PAGE No VEGP 00150-C 10 15 of 22 l
t-4.15.4 The Technical Support Department will enter completed corrective actions that reqcire tracking and corrective actions awaiting implementation and/or require long term tracking in the Open Item /Comitment Tracking Item / Commitment Tracking". system in accordance with Proced 4.15.5 The Technical Support Department will close out and forward the original and any supporting the DC documentation to Document Control for storage as a pe manent Assurance Records Administration". record in accordance with 00 4.15.6 The Technical Support Department will provide management with a periodic status of open DCs.
5.0 MATERIAL DEFICIENCY _ CARD INITIATION 5.1 Vnen material deficiencies are identified, che Card (Figure 2). individual will initiate a Material Deficie,n,cy The individual identifying the material deficiency should complete Blocks 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, and 14 and forward the Material Deficiency Card to Quality Control recaipt inspection personnel 5.2 Deficiency Card Number. Quality control (QC) will assign the card This number will be of the fom M-YY-XXXX where M denotes Material Deficiency, YY is the last two digits of the current year and XXXX is a sequential number beginning with 0001 for each new year.
5.3 After receiving a Material Deficiency Card QC will ensure Hold Tags are attached to the deficient meterial/ components identified and complete Block 15 of I
the Material Deficiency Card.
5.4 QC ensures the deficient tmerial/ components are uniquely tagged or segregated from acceprrable= material to prevent inadvertent use in the plant.
5.5 QC reill forward the Material Deficiency Card (MDC) thr, M.aterials En to dispositioning. gineering Group (MEG) for l
1
- ~ - - - - - - - - - - - - - - -
05-23-90 13:1? T-Ce P! F CO 4045545314 tQ?9 Pl?
g PROcEDUKE NO.
AEylSioN PAgg NQ, VEGP 00150-C 10 16 of 22 5.6 MEG will disposition the Material Card.
The I
disposition will identify corrective actions and t
implementing documents for completion of corrective action (i.e., MWO numbers, RERs, etc.).
Dispositioning of Material deficiencies will be in accordance with Procedure 70546-C, " Evaluation And Disposition Of Material Deficiency Cards".
5,7 Material deficiencies dispositioned as "use-as-is" or
" repair" require approval by the Su>ervisor Materials.
I Material deficiency dispositions otier than "use-as-is" or " repair" require approval by the MEG Supervisor.
l 5.8 MEG will forward the MDC to Technical Support i
Department.
Corrective actions may be performed concurrently with the Technical Support Department review.
5.9 The Technical Support Department will determine if the material deficiency" Federal And State Reporting is reportable in accor44nce with Procedure 00152-C, Requirements".
5.10 Material Deficiencies determined reportable will be evaluated by MEG in accordance with 00058-C, " Root 1
Cause Determination".
Completed Root Cause Determination worksheets will be attached to the Material Deficier.2y Card.
5.10.1 The MEG will be responsible for ensuring conpletion of I
all corrective action.
5.10.2 Upon completion of corrective action, the MEG will l
forward the Material Deficiency Card to QC for closure and hold tag removal.
l 5.10.3 For MDC's dispositioned "Use As Is" or Repair", a copy of the MDC and associated paperwork are to be made part of the Quality Assurance documentation associated with the item.
5.10.4 MDCs will be forwarded to Document Control upon closure for stora record in accordance with 00100-C, ge as a permanentQuality Assurance Records Administration".
NOTE Use of conditionally released materials will be in accordance with Procedure 00853-C, " Material Identification, Control And Issue",
wo
05-Z?-90 12:!O T-G4 PiR CO 4045545!14 u?M F19 PAoCEDUAE No A E VIStoN P AGE NQ.
VEGP 00150-C 10 17 of 22 6.0 DUPLICATE DEFICIENCY _ CARDS When a deficiency ard is found to be a duplicate of a previously identif ed deficiency, the deficiency card will be stamped or Parked " DUPLICATE", and closed out bv Technical Support.
Technical Support will forward the " duplicate" DC to Document Control for st6 rage.
7.0 TRENDING 7.1 All DCs should be trended to identify recurring deficiencies which night indicace procedural or programmatic breakdowns that could adversely affect the quality of the plant and associated equipment.
A trend is identified unen a repetitive occurrence or a sustained increasing frequency of occurrence is observed and is not explainable as an occasional or isolated procedural or programmatic inadequacy.
99 7.2 A quarterly trend report should be prepared by the Technical Support Department and distributed to Department Managers and the General Manager-Nuclear Plant.
A copy of the trend report will also be forwarded to the Supervisor Safety Audit Engineering l
Review.
7.3 Department managers should perform root cause determination in accordance with Procedure 00058-C,
" Root Cause Determination" and take appropriate corrective actions as necessary for trends identified within their departments area of responsibility.
7.4 Material Deficiency Cards (MDCs) will be trended by the Supervisor Materials.
l i
8.0 RECORDS Deficiency Cards and supporting documentation shall be handled and maintained in accordance with Procedure 00100-C, " Quality Assurance Records Administration".
4
v -
05-27-90 12120 T-G4 dim CO :045545214 409 P19 WoCEDUCE NO.
HEVI$loN Pact go.
-+
VEGP 00150-C 10 18 of 22
9.0 REFERENCES
9.1 ANSI N18.7 - 1976 9.2 ANSI N45.2 - 1977 9.3 Title 10CFR50 Appendix B, Criteria XV and XVI-9.4 Title 10CFR50.59, Changes, Tests & Experiments 9.5 Title 10CFR21, Reporting of Defects end Noncompliances 9.6
- itle 10CFR50.72, Icmediate Notification Requirements for Operating Nuclear Power Reactore 9.7 Title 10CFR50.73, License Event Report System 9.8 Title 10CFR50.45 (X), Conditions of Licenses 9.9 Title 10CFR50.55 (e) 9.10 Regulatory Guide 1.33, Quality Assurance Program Requirements 9.12 Regulatory Guide 1.38, Qua'lity Assurance Requirements Packinfo,rWater-CooledNuclearPowerPlantsiShipping. Receiving, Stor Items 9.13 Regulatory Guide 1.~123, Quality Assurance Requirements for Control of Procurement of Items and Services for.
Nuclear Power Plants.
9.14 PROCEDURES 9.14.1 00057-C,
" Event Investigations" 9.14.2 00058-C,
" Root Cause Determinatiot" 9.14.3 00100-C,
" Quality Assurance Records Administration" 9.14.4 0015Z-C,
" Federal And Stare Reporting Requiremettes" 9.14.5 00350-C,
" Work Request Program" 9.14.6 00400-C,
" Plant Design Control" 9.'.4.7 00409-C, "Open item / Commitment Tracking" 9.14.8 00853-C,
" Material Identification, Control, and Issue" wo
o 05-23-90 13:31 T-% P!JR CO 4045545214 4099 FIO
)
P<4Ct!DW E No-REVISloN PAGE NO.
VEGP 00150-C 10 19 of 22 9.14.9 00920-C,
" Radiation Exposure Limits" 4
9.14.10 00930-C,
" Radiation And Contamination Control" 9.14.11 11875-C, "LCC Status Sheet" 9.14.12 20100-C, "ASME Section XI Repair / Replacement ~ Program" 9.14.13 50011-C,
" Engineering Evaluation And Disposition Of Deficiency Reports
9.14.14 70546-C,
" Evaluation And Disposition Of Material-Deficiency Cards" 9.14.15 80014-C,
" Handling Of Deficiency Cards" 9.14.16 81030-C,
" Preparation And Proce sing Of Draft Licensee Event Reports And Special Reports" 9.14.17 90018-C,
" Incident Report Review" 9.14.18 92040-C,
" Fire Protection LCO Program" l
i END OF PROCEDURE TEXT l-
- E
o c3-23.s2 cc T-s n;oc :o acassar: u ma+9 : 1 4
FROCEDURE NO.
REVISIOt4
- PI'GEt40 I
~
VEGP 00150.c 10 2ti of 22 DEF)CIENCY CARD CMD#
WT11) WT 1 ( ) COlaf0NI )
1:
DEm W 07r4NC/
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~ 05-2;-90 1;t 22 T-G4 PtR CO 10.:55-15314 n05 P22
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PnOCEDU7,E NO.
REVISION PAGE NO.
VEGP-00150-C 10-21 of 22
^4_
k T9900 CAL SUPPORT AfVEW NBAC EVALUATOe8EVEW f0GCE APPROPRdit box) 0415 IWCEPrGD A
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,p-05-2!-90 13:32 T-GA Pbi CO '4045545314 t:N3 F23 1
e j*
'
- haocgDUAE NO.
REV;SION
? # AGE NO VEGP' 00150-C 10 22 Of 22 MATERIAL DEFICIENCY CARD 1.
MATERIAL DC NO. M-2.
P.O. NO.
3.
P.O. ITEM NC.
4 NO. OF ITEMS 5.
M.I.R. NO.
6.
PROCUREMENT LEVEL 7.
SAFETY CLASS 8.
ITEl' DESCRIPTION 9.
ITEM LOCATION 10,-
VENDOR / SUPPLIER LOCATION _
11.
DEFICIENCY i
12.
CAUSE (IF KNOWN) 13.
.0THER INFORMATION 14.
ORIGINATOR (PRINT)
DATE 15.
QC HOLD TAG (QTY)
QC INSPECTOR _
16.
DISPOSITION:
i 17.
APPROVAL:
USE-AS-IS/ REPAIR (SUPV HATERIALS)
DATE OTHER(MEG SUPV)
DATE 18.
REPORT REQ'D:YES No i
19.
TECH. SUPPORT REVIEW BY:
DAIE i
20.
QC CLOSURE:
DATE FIGURE 2 (WHITE)
(EXAMPLE)
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DG 18 TROUBLESHOOTING PLAN
,JW 4emperature switches prior to each start.
itor'P-3 operation for each start.
op.each JW temperature switch during start, itor JB temperature during each run and record.
)y problems stop and have meeting.
( Perform 3 local emergency starts with "old" switches installed Calibratelew P-3 to lower setpoint (in I & C Shop)
Perform 1 (or more) normal starts with existing P-3 Install new P-3 with lower setpoint Perform 3 normal starts with new P-3 Perform Operations surveillance 4
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g DG 18 TROUBLESHOOTING PLAN p-Vent JW temperature switches prior to each start.
Monitor P-3 operation for each start.
. Snoop each JW temperature switch during start.
Monitor JW temperatute during each run and record.
-Any problems stop and have meeting.
1.
Perform 3 local emergency starts with "old" switches installed-
- 2. - Calibrate new P-3 to lower setpoint (in I & C Shop) 3.
Perform 1 (or more) normal starts with existing P-3 4.- Install new P-3 with lower setpoint 5.
Perfom 3 normal starts with new P-3
- 6. -Perform Operations surveillance 073rcoT C/2+/7s
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