ML20134J157
| ML20134J157 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/16/1985 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| NUDOCS 8508290191 | |
| Download: ML20134J157 (6) | |
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RECElVED.
NRC Portland General ElectricCoraxuly
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.l... f,U3 l 3 [N l: l[4 03 Bart D Withers Vce PreeAert 9E6lO'lV file August 16, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects U.S. Nuclear Regulatot; Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368
Dear Mr. Kirsch:
Ouality Assurance Program for Trojan Operations The following responses to your requests for additional information or clarifications of specific changes in Revision 10 to the Nuclear QA Program transmitted by your letter of July 3, 1985 are provided. Also included, as attachments to this letter, are marked-up pages of the Nuclear QA Program which will be formally submitted to you in November 1985 as a part of Revision 11.
Chapter 3.0 Lesign Control NRC Comments a.
Section 3.2.3.
Deletion of the Nuclear Safoty and Regulation Depart-ment's review and concurrence with the Request for Design Change safety and environmental evaluation prior to review by the Plant Review Board is a reduction in the QA program commitments. Additional justification is requested for this deletion in order to evaluate the acceptability of this change.
b.
Section 3.2.4.
Revision 10 does not address the requirement for the appropriate engineering etment's approval of Detailed Construction Packages.
Please provide irification for this omission or if this action is no longer a requirement, justification for the apparent reduction in QA program corr.itments.
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N M BOChiCCOr11Mdly Mr. D. F. Kirsch August 16, 1985 Page 2 l
PGE Responses a.
The Nuclear Safety and Regulation Department (NSRD) will continue to review safety evaluations for RDCs. Revision 10 to the QA Program (Section 3.2.3) allows this review to be conducted after review by the Plant Review Board.
The reviews by NSRD are done as staff work for the Trojan Nuclear Operations Board (TNOB) in accordance with Technical Specifica-tion 6.5.2.7(a).
This Technical Specification states that:
"The TNOB shall review the safety evaluations for 1) changes to procedures, equipment, or systems, and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question."
This Technical Specification, whic: forms the ba. a for ERRD's/TNOB's review of RDCs, allows the review cf afety evaluatiens ta be performed
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after-the-fact, as reflected in F edr 10 to the CA Pr: g ram.
Sirce
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this is allowed by Technical spec.
, and o nr' N323 will still continue
,,a review the safety evaluat,.
this 1 felt to be a reduction en QA Program commitments.
I The QA Program was originally approved by NRC te allow for NSRD/Th a j
review of RDCs as propcsed in Revision 10.
We was changed ir, 1960 to f
reflect that USRD/'IEDB review occurred prior
- ' Nit review as -
l internal PGE i ' i c y.
It has sin' bt" det&
.rM t L a price vLew a the crit) 41 for RDCs ir
< M:uve, r
- al, or v..
conted, and.
efore, the orie review. md nN process l
I' safety evaluats as has been resta A,
b.
The ':quirement for the appre t u engineerint, dmpartment's apprm i
of
= ailed Conc ruction Pa m
-s (DCPc) we inadvertently omitte!
ring of Es teLon 10 to QA Prot Section 3.2.4 will in in Revision 11 (see ie 3-4 of c, ttachment) to more clearly raict-the approval authority DCPs.
t acoval of T. cps by either
- ne lh ter, Nuclear Plant Engin is, or tr Plant Engineering supervL i
r, depend ng upon which poization ptepared the DCP, has
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been a c ngstanding rev irement.
Chapter 15.0 lanconforming h teria v_
-t.s of Component tig,;fe tivo $ction NRC Comme '
Section 11 (Purpose). This section failu =o provide a statement concerning corrective action. A description c the Pu a se as stated in Chapter 16.0 of r
Rev-'lon 3 is needed since Revisior,10 is ir. orporating requit taents for cor ective action.
W A
W Gerierd MCoritieuly Mr. D. F. Kirsch l
August 16, 1985 l
Page 3 PGE Response A statement concerning corrective action will be added to the 3ection 15.1 (Purpose) of Chapter 15.0 (see Page 15-1 of our attachment).
l Chapter 16.0 Nonconforming Activities and Corrective Action NRC Conunent Section 16.2.3 of Revision 9 required corrective actions associated with nonconforming activities to be submitted to the plant General Manager for approval. Revision 10 replaced "the plant General Manager" with "the responsible organization management". Since organizational structures have been subject to change there are no assurances that the proper level of management attention would be provided to resolve plant problems. It is required that you revise Revision 10 to specify the plant General Manager or provide justification for this apparent reduction in QA program commitments.
PCE Response Section 16.2.2 will be revised in Revision 11 (see Page 16-3 of attachment) to more clearly indicato the approval authority for corrective actions for nontmf orming activities. The NCAR form is now used by all Nuclear Division organizations.
Corrective actions which require action by the Plant will be approved by the Plant General Manager or his designee. This approval process is also described in Section 1.2.2.1.4 of the QA Program under the responsibilities of the Plant General Manager and was not changed in Revision 10.
Those corrective actions which require actions by offsite support organizations will be approved by the cognizant Manager.
Sincerely, for Bart D. Withers Vice President Nuclear Attachment c:
Mr. Lynn Frank, Director State of Oregon Department of Energy
l 1
appropriate witness and inspection hold points, for the work to be accomplished.
11 Design verification is performed during final review of the DCP..and--prtor--
--te-the-eppeova by th==;;x t-of-the-preparing-opganintica Design verification is performed by individuals other than those who performed the original design. The individuals performing the verification do not l
have immediate supervisory responsibilities, or have specified the design approach, or have ruled out certain design considerations, or have established the design inputs. Cursory reviews do not satisfy the design verification requirements.
Design verification for design changes is accomplished by any one or more of the processes of design reviews, alternate calculations, or testing.
Design reviews for quality-related items can be completed by the Nuclear Safety & Regulation Department as requested by Trojan Technical Services or Nuclear Plant Engineering.
O Additionally, desiga reviews can be completed by Trojan Technical Services for Nuclear Plant Engineering prepared DCPs, by Nuclear Plant Engineering for Trojan Technical Services prepared DCPs, by either PGE engineering organization for consulting engineer prepared DCPs, or by individuals within the same group who are independent of the design originator.
Reviews of the environmental impact analysis of RDCs and DCPs will be per-formed by the Environmental & Analytical Services Department as requested j
by Trojan Technical Services or Nuclear Plant Engineering.
1 DCPs are approved by the Manager, Nuclear Plant Engineer or Plant yy Engineering Supervisor as assigned by the plant General Manager.
All approved DCPs are reviewed by the Trojan Plant Engineering Supervisor l
or his PRB alternate, for the plant General Manager, prior to implementa-f tion. This final review assures that an approved RDC exists and that the DCP conforms to the approved preliminary design and safety evaluation.
DCPs are then approved for implementation by the TPE Supervisor acting for the plant General Manager. Installation of the modification or design change is performed by Plant Maintenance, the Plant Modifications Depart-ment, or a contractor. Nuclear Plant Enginaering conducts a post-installation review to verify conformances to the details of the DCP.
3-4 Revision 10
i 10l 15.0 NONCONFORMING MATERIAL., PARTS, OR COMPONENTS AND CORRECTIVE ACTION 15.1 PURPOSE This chapter describes measures for documentation and control of non-confor71ng quality-related items to prevent their inadvertent use or j
installation in the Trojan Nuclear Plant.
Ultimate disposition measures 1
i{q and approval of corrective actions are described.
10l 15.2 NONCONFORMING MATERIAL CONTROL PROGRAM 15.2.1 General Material, parts, and components that deviate from approved specifica-tions, codes, drawings, or other applicable documents are considered as nonconforming.
A Nuclear Division Procedure (NDP) governs the identification, control, and disposition of nonconforming items identified during operation which are not reworked by the MR process, and serves as a basis for notifica-tion of responsible organizations.
A nonconforming item may be installed or remain in service provided that 10 the nonconforming condition is satisfactorily evaluated by responsible engineering supervision and the Shift Supervisor and is determined to have no adverse effect on the safe operation of the plant. Nonconforming items are not relied upon to fulfill their intended functions until the nonconformance is resolved.
When feasible, nonconforming items are clearly identified with Quality Control Hold Tags and segregated to indicate their unacceptable status until the nonconformance is properly dispositioned. To preclude opera-tion with installed nonconforming items which could have an adverse effect on plant safety, those items are also tagged in accordance with 11)
Section 14.h.2 of this QA Program by the plant operator under the 15-1 Revision 10
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..--,o-t The Trojan QA staff or the HQA0 evaluates the NCAR for validity and will forward valid NCARs to the responsible supervisor or manager for correc-tive action and a determination of the root cause of the nonconforming activity. NCARs determined to be invalid during the QA evaluation will be returned to the originator with an explana: ion regarding the determination.
The responsible supervisor or manager evaluates the nonconforming activity to determine if a significant condition adverse to quality exists or if it is potentially reportable. Nonconforming activities determined to be significant conditions adverse to quality require corrective actions to be taken to preclude repetition. For nonconforming activities that are significant conditions adverse to quality, a response is required in less than 30 days, otherwise, a response shall be due 30 calendar days from the date the NCAR is distributed.
10 The responsible supervisor or manager documents proposed corrective actions which include an identification of the root cause on the NCAR and
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Following approval of the corrective action, the NCAR is transmitted to the appropriate QA organization for evaluation of the proposed corrective action to determine if the action is adequate to close the NCAR.
(Unacceptable corrective action is documented and resubmitted to the responsible organization managenent for additional corrective action.)
Inappropriate or incomplete corrective action may result in suspension of the associated operation or activity.
If corrective action cannot be completed as scheduled, the responsible supervisor or manager is required to provide the appropriate QA organiza-tion with a new completion date for corrective action.
The QA organizations verify implementatior, of the corrective action through reviews, audits, or surveillances.
16-3 Revision 10 3
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