ML20138B178

Forwards Rev 11 to QA Program.Rev Includes Statement That Nuclear Safety & Regulation Dept Reviews Safety Evaluations as Nuclear Operations Board Staff Function

ML20138B178
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	09/16/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8510150192
Download: ML20138B178 (4)

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- mm NRC amm NMM U35 SEP I9 p;4 g g Bad D. Wahers Vcc Presdert ES!Of.T tEr September 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 Regulatory Conunission, Region V 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Kirsch:

Ouality Assurance (OA) Program for Trojan Operat. ions Based on September 10 and 13 discussions between Mr. Dodds and Mr. Wagner of Region V and members of PGE's staff, clarification was agreed to concerning Revision 10 to the Nuclear QA Program, with specific reference to your letter of July 3 and my letter of August 16, 1985.

With regard to Section 3.2.3 of Revision 10 of the QA Program, it is stated that: "the Trojan Nuclear Operations Board (TNOB) reviews all safety evaluations of changes to the facility completed under the provisions of 10 CFR 50.59". Under both Revision 9 and 10, this review was and still is performed by the Nuclear Safety and Regulation Department (NSRD) as a TNOB staff function. While nevision 10 did delete the statement that NSRD reviews design change safety evaluations, this review was always one and the same as the TNOB review performed by NSRD. The only effect of the change _in Revi-sion 10 was to change the timing of NSRD's review such that it now occurs after Plant Review Board approval of design changes. In order to permanently clarify this matter, Revision 11 of the QA Program will include the statement that NSRD reviews safety evaluations as a TNOB str.ff function (see attached mark-up).

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N Genier-d ElectricCosty)Emiy Mr. D. F. Kirsch, Acting Director September 16, 1985 Page 2 With regard to Section 15.1 of Revision 10 of the QA Program, the purpose of this chapter will be restated in Revision 11 to clearly state that the chapter describes corrective actions for nonconforming material, parts, or components (see attached mark-up).

Sincerely,

$f ^e:- hr Bart D. Withere Vice President Nuclear Attachment c: Mr. Lynn Frank, Director State of Oregon Department of Energy

Attachment A engineer under the cognizance of Nuclear Plant Engineering) as assigned by the plant General Manager.

The evaluations for RDCs determine if the change affects performance of quality-related structures, systems, or components; provide the basis for a determination of the impact on plant safety or the environment; and determine whether the proposed change involves an unreviewed safety question or an environmental impact.

After the preliminary design, safety evaluation, and ALARA review are com-pleted and documented on the RDC, it is approved by the Manager, Nuclear Plant Engineering or Plant Engineering Supervisor as assigned by the plant General Manager. A copy of an environmental-related RDC is sent to the General Manager of Environmental & Analytical Servi".es for review. This

' review is not part of the RDC approval sequence. A preliminary design change which involves security equipment or physical barriers is sent to the Director of Corporate Security for concurrence. When this concurrence 1 has been received, the RDC is reviewed by the Plant Review Board and for-warded with a written recommendation for approval or disapproval to the

plant General Manager. The Trojan Nuclear Operations Board reviews all safety evaluations of changes to the facility completed under the provi-sions of 10 CFR 50.59; these reviews are performed by the Nuclear Safety and Regulation Department as a staff function '

for the TNOB. Design changes which involve a change to the license, '

l- technical specifications, or unreviewed' safety questions are reviewed by the TN08 and forwarded as License Change Applications to the NRC for review and approval prior to installation. -

a 3.2.4 Detailed Construction Packanes I . Detailed design for an RDC is perfonned by completing a Detailed Construc-tion Package (DCP).. This includes preparation of specifications, engineer-

[ ing instructions, list of materials, drawings, calculations, and installa-tion procedures necessary to accomplish the RDC work,

) The DCP 'is completed by Trajan . Technical Services, Nuclear Plant Engineer-

! ing, or a consulting engineer under the cogniza'ne of Nuclear Plant Engi-

$ neering. The DCPs contain the appropriate quality requirements, including l 3-3 r

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'15.0 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS AND CORRECTIVE ACTION 15.1 PURPOSE This chapter describes-measures for documentation and control of non-conforming quality-related items to prevent their inadvertent use er I- installation'in the Trojan Nuclear Plant. This chapter also

-describes the actions which assure that.such nonconforming items are evaluated and corrected and for.those significant it i conditions adverse to quality, corrective action is taken to preclude recurrence.

l 15.2 NONCONFORMING MATERIAL CONTROL PROGRAM ,

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15.2.1 General i 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) govegns 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 the nonconforming condition is satisfactorily evaluated by responsible engineering supervision and the 'Shif t Suoervisor 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 4

nonconformance is resolved.

When feasible,' nonconforming items are clearly identified with Quality Control. Hold Tags and segregated to indicate their unacceptable status until the noncon'ormance is properly dispositioned. To preclude opera--

tion with insta11ed' nonconforming items which could have an adverse effect on plant safety, those' items are also tagged in accordance with Section 14.2.2 of this QA Program by the plant operator under the .

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