ML20138H728

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Staff Exhibit S-147,consisting of Rev 3 to Project Specific QA Procedure PSQP-16.3, Trend Analysis,
ML20138H728
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/13/1985
From: Estella J, Jordan T
HOUSTON LIGHTING & POWER CO.
To:
References
OL-S-147, NUDOCS 8510290134
Download: ML20138H728 (19)


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,f l} f f HOUSTON LIGHTING & POWER COMPANY SOUTH TEXAS PROJECT 000fETEg PROCEDUREY**:UAL USMC

SUMMARY

OF REVISIONS

'83 por n P ROC. No.

TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE PSQP-16.3 SUBJECT TREND ANALYSIS REvlSION REVISION OESCRIPTION NUMBER 0

Complete rewrite. Changes include addition of coding system, trending of Corporate and Operations deficiency documents, criteria for evaluating BEC and ESI trend results.

Format changed to comply with requirements of QAD-5.1.

Procedure number changed, replaces former PSQP-A8. Training required.

Effectivity date: August 1,1983 1

Major rewrite.

Changes include addition of HL&P trending of BEC and ESI deficiency documents, deletion of QS/A trending of HL&P Operations deficiency documents and change of trend report distribution frequency.

Training required (QS/A personnel anly).

Effectivity date:

February 3, 1984 2

Revised to include Project GA Trendino of Operations nenerated deficiencies; expanded list of deficiency documents trended. tdded review of TIRs for reportability.

Incorrerated ICf! PS00-16.3-02.

Traininc required.

(05/A personnel only)

Effectivity date: 07-27 3 Revised to include description of Trend Program Committee and to incorporate ICN PSQP-16.3-03.

No training required.

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3 issued 08/01/83 01/31/84 07/28/88 03/19/85 PREPAREDg,s./ sipg p se. &g/4,,

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REV.No, HOUSTON UGHTING S POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

eacE or 7, reg PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 1

18 QATE ISSUEo SUBJECT TREND ANALYSIS 03/19/85 1.0 PURPOSE This procedure provides instructions for the collection, coding and analysis of deficiencies identified by HL&P, BEC and ESI for trends adverse to quality.

Instructions for documentation, correction, follow-up and reporting of estab-lished/ potential trends is also provided.

2.0 SCOPE This procedure includes the trending of deficiencies identified by the follow-ing organizations during the conduct of procurement, design, construction, and start-up activities for the South Texas Project.

A.

HL&P Project. Support and Operations QA/QC personnel B.

BEC Site and Design Office personnel C.

ESI QA/QC and Construction personnel 3.0 DEFINITIONS 3.1 Trend - A collection of data, grouped by a common denominator, that exhibits the existence of quality related repetitive deficiencies over time.

Repetitive quality related deficiencies include duplication of a significant condition, frequent occurrences of a minor condition or the occurrence of similar deficiencies which may suggest underlying system-atic weaknesses. Deficiencies will be trended over a minimum of one year to ensure that those identified during activities audited on an annual basis are reviewed for repetition.

3.2 Reportable Deficiency - A deficiency in design or construction, which, were it to have remained uncorrected, could have adversely affected the safety of operations of the nuclear power plant at anytime throughout the expected lifetice of the plant, and which represents at least one of the following criteria:

(i)

A significant breakdown in any portion of the Quality Assurance Program conducted in accordance with the requirements of 10CFR50, Appendix B.

(ii)

A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the Safety Analysis Report (SAR) or construction permit.

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STD 59 A H-831 PMcC. No.

R Ev, No.

HOUSTON UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAoE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 2

18 OATE ISSUED SU8 JECT TREND ANALYSIS 03/19/85 (iii)

A significant deficiency in construction of or significant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bcses stated in the Safety Analysis Report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its I

intended safety function.

(iv)

A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of the structure, system or component to meet the criteria and bases stated in the Safety Analysis Report or construction permit or to other-vise establish the adequacy of the structure system or compo-nent to perform its intended safety function.

4.0 REFERENCES

4.1 PSQP-15.2 Stop Work 5.0 RESPONSIBILITY f

The Supervisor, Quality Systems / Administration is responsible for maintaining and i=plementing this procedure.

6.0 REQUIREMENTS 6.1 Documents Trended 6.1.1 The following deficiency documents shall be reviewed by Quality Systems / Administration (QS/A) personnel for potential adverse trends.

a..

Standard Deficiency Reports (HL&P, BEC and ESI) b.

Audit Deficiency Reports (HL&P Corporate and Operations) c.

Nonconformance Reports (HL&P Project and Operations BEC and ESI) d.

Supplier Deviation Disposition Requests (BEC) - accepted only e.

Deficiency Notices (ESI) f.

Audit Finding Reports (BEC) g.

Quality Surveillance Deficiency Report (BEC) h.

Quality Engineering Report (BEC) - Design Deficiency data only.

i.

Document Deficiency Notices (BEC) e -

STP 59 A (1431 P roc. No.

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HOUSTON UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE oP TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 3

18 OATE ISSUEo SU 5JE CT TREND ANALYSIS 03/19/85 j.

Deficiency Evaluation Form (HL&P) k.

, Deficiency Evaluation Report (BEC) 1.

Maintenance Discrepancy Reports (BEC, ESI)

Corrective Action Reports (HL&P Operation) m.

Surveillance Deficiency Notices (HL&P Operations) n.

6.1.2 Nonconformance Reports trended will include NCRs documenting HL&P, BEC and ESI deficiencies and NCRs issued by HL&P, BEC and ESI documenting subcontractor and off-site supplier defi-ciencies. NCRs documenting deficiencies identified on work previously performed and completed by B&R will not be included in the trend analysis program.

6.2 Coding 6.2.1 Upon initiation / validation, copies of HL&P Project and Operation NCRs and Operations CARS and SDNs will be forwarded to QS/A. QS/A will retain a copy of HL&P initiated SDRs upon transmittal to the responsible organization. Copies of Corporate and Operations ADRs will be forwarded to QS/A upon transmittal of the applicable audit report. Copies of DEFs will be forwarded to QS/A by Project Licensing. Copies of deficiency documer.ta generated by BEC and ESI will also be forwarded to HL&P Q3/A upon initiation / validation in accordance with the controlling procedure.

6.2.2 Upon receipt by HL&P QS/A, a code providing the following information will be entered into the computer data base:

A description of who was 6.2.2.1 Company Organization responsible for performing Discipline / Group the activity which generated the deficiency. Examples of one character ' Company' codes are provided on Attachment 2.

Examples of two character

' Organization' and

' Discipline / Group' codes are provided on Attachments 3 and 4.

respectively.

The activity which generated 6.2.2.2 Activity the deficiency. Examples of two character codes are provided on.

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ST7 50A (1431 PROC. No.

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HOUSTON UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE OF TITL g PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 4

18 I

DATEISSUED SUSJECT TREND ANALYSIS 03/19/85 A description of what was wrong 6.2.2.3 Deficiency Type with the deficient item.

Examples of two character codes are provided in Attachment 6.

The trend codes provided on attachments 2 through 6 ars' examples only. The trend code list will be controlled separately from this procedure. Updates will be made as necessary and the revised code list will be approved by the PQAM prior to use in trend analysis.

6.2.3 The code will be entered into the computer data base inIthe i

following format (Reference Attachment 1):

Company - Organization - Discipline / Group - Activity - Deficiency Type Exa=ple: CAR G-052 The BEC PQPM, Rev. I was issued without HL&P review and approval.

Company Organization Discipline / Group Activity Deficiency Type (Attach. 2)

(Attach. 3)

(Attach. 4)

(Attach. 5)

(Attach. 6) !

2 07 N/A 39 40 If multiple items are identified on the deficiency document, two or more codes may be used to ensure adequate retrieval and comparison capabilities. Multiple codes may also be used for deficier.cy documents identifying single items if one code in t

any or all categories does not adequately describe the condi-tion.

Example: CAR G-085 1.

Records are not stored according to ANSI requirements and access requirements are not enforced.

2.

Procedures are not developed describing filing methods.

l Company Organization Discipline / Group Activity Deficiency Type 2

09 N/A 61 32 30 07 l

The code of "other" should be used only when no other code in a I

particular category applies.

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' STP 59 A O-83)

HOUSTON UGHTING & POWER COMPANY PROC. No.

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SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

TITLC PAGE oF PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 5

18 SU8 JECT OATE ISSUEo TREND ANALYSIS 03/19/85 6.2.4 The trend codes and other pertinent information related to each deficiency document, i.e., document number, description, issue date, etc., will be entered into the HL&P Trend Analysis computer program.

6.3 Analysis 6.3.1 The analysis of deficiency documents is segregated into four groups.

6.3.1.1 Hardware Deficiencies: Those deficiencies concerning actual hardware problems involving Project and Operations Activities. The deficiency documents falling into this category include HL&P, BEC and ESI NCRs and ESI DNs.

6.3.1.2 System Deficiencies: Those deficiencies involving programmatic and non-hardware problems occurring during Project and Operations activities. Deficiency documents trended include HL&P, BEC and ESI SDRs; HL&P Corporate ADRs; HL&P DEFs; BEC DERs; HL&P Operations ADRs and SDNs; and BEC and ESI MDs.

6.3.1.3 Supplier Deficiencies: Those deficiencies issued against supplier activities. The deficiency documents trended in this category include BEC SDDRs; BEC AFRs; BEC DDNs; BEC QSDRs; and HL&P, BEC and ESI NCKs issued against suppliers.

6.3.1.4 Engineering Design Changes: Those deficiencies not identified by BEC Engineering in the course of design development that ultimately result in a design change document to achieve a satisfactory design. The coded, sorted data is submitted to HL&P QS/A by BEC Engineering via the Quality Engineering Report for analysis. Design change documents trended include Drawing Change Notices, Specification Change Notices, Field Change Requests, Specification Revisions and Drawing Revisions.

6.3.2 Each month the deficiency documents in the categories described above will be sorted by one or any combination of code categories as deemed appropriate for the current reporting period and the previous eleven months. The data will be normalized against indices deemed appropriate for the activity or commodity, i.e., manhours, quantity installed, inspection hours. Graphical summaries of the performance for selected code categories over time will be prepared in each area.

ST9 59A (1.c31 PnCC. N3, rey, No, HOUSTON LIGHTIN3 0 POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PS P-6.3 3

TITLE PAGE oF PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 6

18 SUBJECT DATE ISSUED TREND ANALYSIS 03/19/85 6.3.3 A preliminary evaluation of the graphical data vill be made in a joint meeting held by HL&P and BEC QA.

Those areas in which immediate corrective action or further review is felt necessary will be extracted.

No further action will be taken in those areas where no potential trends appear to be developing.

6.3.4 Those areas where further review is felt warranted will be referred to the Trend Program Committee. The Trend Program Co=mittee is composed of HL&P and BEC personnel representing QA and Construction supplemented by additional discipline personnel when further expertise in an area under evaluation is necessary. The Trend Program Committee will review each area to determine whether sufficient evidence is available to indicate that a trend adverse to quality is developing or has developed. An action plan will be drafted by the committee for those areas where a trend has developed or may be developing and a TIR will be issued by QS/A in accordance with paragraph 6.4.

6.4 Trend Documentation 6.4.1 A TIR will be issued by QS/A to BEC or ESI via the BEC PQAM, or appropriate HL&P or vendor management personnel responsible for the specific deficiency (s) when deemed necessary by the Trend Program Committee. The information centained in Section 1 of the TIR will be documented by the initiator. This will include an evaluation for reportability in accordance with 10CFR50.55(e) utilizing the guidelines contained in definition 3.2.

If the TIR appears to be reportable per 10CFR50.55(e), a Deficiency Evaluation Form (DEF) will be initiated in accordance with PLP-02. The Supervisor, QS/A will review and approve the TIR prior to issuance.

After approval, QS/A will assign a sequential number to and log the TIR. The TIR will be issued to the responsible party via a cover letter prepared by QS/A and signed by the Project QA Manager (PQAM). A response date of no more than 20 working days from the date on the cover letter will be assigned.

~~

Written response extension requests nay be granted by the PQAM if good cause has been demonstrated.

6.4.2 The responsible party will conduct an investigation to determine whether a trend exists and document the results in l

Section 2 of the TIR.

If no trend was identified, the TIR will be signed and returned to QS/A.

If a trend was identified.

Section 3 will be completed, the TIR will be signed and returned to QS/A.

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STP 59A (18B PnoC. No.

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PAGE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 7

18 DATE l5 SUED SUBJECT TREND ANALYSIS 03/19/85 6.4.3 The initiator will review the investigation results for adequacy and verify implementation of corrective action / recurrence control, if applicable. The results will be documented in Section 4 of the TIR.

6.4.4 The TIR will be signed by the initiator and approved by the Supervisor, QS/A upon satisf actory verification of the correc-tive action / recurrence control. The TIR will be forwarded to the HL&P Project QA Manager (PQAM) for final closure approval.

If no trend was identified, the TIR will be closed after a review for adequacy of the investigation results.

6.4.5 A letter, prepared by QS/A and signed by the HL&P PQAM, will be sent to the responsible organization notifying them of closure of the TIR.

If the TIR involved offsite suppliers, as described in paragraph 6.5.2, the closure letter will be prepared by QS/A and signed by the Manager, QA.

6.4.6 Unsatisfactory responses, evidence that an inadequate investigation was conducted by the responsible organization to determine whether a trend exists, or failure to implement corrective action / recurrence control shall be handled at the discretion of the Supervisor, QS/A and may be directed to a higher level of management.

6.4.7 TIRs will be monitored on a quarterly basis for recurrence.

Repetition of a previously identified and confirmed trend may be handled in accordance with PSQP-15.2 or directed to an appropriate level of management for resolution.

6.5 Operations and Corporate TIRs 6.5.1 Potential trends identified as a result of a review of Operations NCRs, CARS, ADRs and SDNs involving onsite organizations will be documented on a TIR by QS/A and forwarded to the responsible organization via a cover letter signed by the Operations OA Manager. Review of investigation results, implementation verification and closure will be handled by

~~

Operations OA personnel in accordance with paragraphs 6.4.3 and 6.4.4.

Responsibilities assigned in these paragraphs to the initiator, Supervisor QS/A, and PQAM will be performed by Operations QA Specialists / Engineers, the Supervisor Operations QA and the Operations QA Manager, respectively. After closure.

l the original TIR will be forwarded to QS/A for filing.

9

STP 59 A f143)

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HOUSTON UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE oF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 8

18 SUBJECT OATEISSUED TREND ANALYSIS 03/19/85 6.5.2 Potential trends identified as a result of a review of Corporate and Operations ADRs issued to offsite suppliers will be documented on a TIR by QS/A and issued to the appropriate subcontractor management personnel via a cover letter signed by the Manager, QA. Review of investigation results and implemen-tation verification of TIRs involving Corporate ADRs will be handled by QS/A with assistance from Corporate QA personnel as requested by the Supervisor, QS/A, Closure of the TIR will be in accordance with paragraph 6.4.4 Review of investigation results, implementation verification and closure of TIRs involving Operations ADRs will be handled by Operations personnel as described in paragraph 6.5.1.

6.5.3 TIRs involving a combination of Project, Operations and/or Corporate deficiency documents will be handled by QS/A per-sonnel in accordance with paragraphs 6.4.1 through 6.4.5.

6.6 Reporting 6.6.1 A sum =ary of trends identified in the current reporting period and actions taken on open, previously identified trends will be included in the QA Monthly Report. A formal Trend Report will be prepared by QS/A and issued on a quarterly basis.

Distribution will include at a minimum:

a)

HL&P Group Vice President. Nuclear b)

HL&P Manager, Quality Assurance c)

HL&P Project QA Manager d)

HL&P Operations QA Manager e)

HL&P Support QA Manager f)

BEC Project QA Manager g)

ESI Quality Program Site Manager 7.0 DOCUMENTATION The following documents are considered Quality Assurance records and shall be transmitted to STP RMS by the Supervisor, Quality Systems / Administration.

7.1 Records 7.1.1 Quarterly Trend Analysis Reports 7.1.2 Trend Investigation Requests (TIR) and related documentation

STD 59 A (103 DRoC. N O.

QEV.NO.

HOUSTGN UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

TITLE PAGE oF PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 9

18 SU BJE CT DATEISSUED TREND ANALYSIS 03/19/85 7.2 Working Documents 7.2.1 None f

7.3 Attachments 7.3.1 - Code Format 7.3.2 - Company Codes 7.3.3 - Organization Codes 7.3.4 - Discipline / Group Codes 7.3.5 - Activity Codes 7.3.6 - Deficiency Type Codes

.y 7.3.7 - Trend Investigation Request (TIR) ee

.n

  • STD 59 A (9 831 Proc. NO.

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HOUSTON LIGHTING & POWER COMf'ANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 10 18 D ATE ISSUED SU 8JE cT TREND ANALYSIS 03/19/85 ATTACHMENT 1 CODE FORMAT A

B C

D E

A.

Co pany:

Company responsible for the deficiency.

B.

Organization:

Organization within the company responsible for the deficiency.

C.

Discipline / Group:

Discipline within the organization. More than one may be be used, i.e., QC-Site-Electrical. This code is optional.

D.

Activity:

Activity which generated the deficiency.

E.

Deficiency Type:

A brief description of what the deficiency was.

e e

STD Q9 A (1-83)

DRoC.NO.

R E tf. No.

HOUSTON LIGHTING & POWEQ COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

TITLE PAGE OF PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 11 18 SUBJECT DATEISSUED TREND ANALYSIS 03/19/85 ATTACHMENT 2 COMPANY 1.

Houston Lighting and Power 2.

Bechtel 3.

Ebasco 4.

Westinghouse 5.

B&R 6.

Vendor 9

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STD 59 A f183)

DCOC. N o.

CEU. No.

HOUSTON UGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 12 18 SU8 JECT DATE ISSUED TREND ANALYSIS 03/19/85 ATTACHMENT 3 ORGANIZATION 01 Construction 21.

Special Metal Division (W SMD) 02 Engineering 22.

Other 03 Licensing 23 Material Control 04 Procurement 24 Warehousing 05 Project Management 25 Management Services 06 Project Ad=inistration 26 Chemical Operations & Analysis 07 QA 27 Maintenance 08 QC 28 Reactor Operations 09 RMS 29 Technical Support 10 Startup 30 Health and Safety 11 PSQD 31 Stores 12 Nuclear Fuels 32 Nuclear Purchasing 13 Operations '

14 Project Services 15 Contracts 16 Field Engineering 17 Nuclear Fuels Division (W NFD) 18 Electro Mechanical Division (W EMD) 19 Nuclear Services Division (W NSD) 20 Water Reactor Division (W WRD)

O

ST9 SOA (1-831 Pr.0c. No.

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HOUSTON LIGHTING & POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 13 18 OATEISSUEo SUBJECT TREND ANALYSIS 03/19/85 ATTACHMENT 4 DISCIPLINE / AREA 01 Electrical 02 Civil 03 Mechanical 04 Site 05 Design Office 06 Corporate 07 Systems 08 Nuclear 09 Plant Design 10 Pipe Stress and Support Group (PSSG) 11 k'elding 12 HVAC 13 Other 14 Piping 15 Pipe Supports 16 Instrumentation '

17 Chemic,al Operations 18 Chemical Analysis 19 Reactor Operations 20 Maintenance Support

STd 59 A (1431 PROC NO-KEV. No-HOUSTON UGHTING A POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

PAGE oP TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 14 18 DATE ISSUED SUBJECT TREND ANALYSIS 03/19/85 1

ATTACHMENT 5 ACTIVITY 01 Concrete 23 Instrumentation 02 Rebar 12 4 NSSS 03 Structural Steel 25 HVAC 04 Embeds 26 Receiving 05 Coatings 27 Calibration 06 Expansion Anchors 28 Storage and Maintenance 07 Grouting 29 Housekeeping 08 Cadwelding 30 Rigging 09 Soils 31 Audits 10 Anchor Bolts 32 Surveillances 11 Electrical Equipment 33 Trending 12 Electrical Terminations 34 Penetrations 13 Electrical Conduit 35 Shipping 14 Electrical Cable Trays 36 Manufacturing / Fabrication 15 Electrical Cable Pull 37 Document Control 16 Electrical Cable 38 Design Review 17 Code Stamping 39 Procedure Review 18 Piping 40 Training / Certification 19 Welding 41 Inspection 20 NDE 42 Effectiveness Inspections 21 Supports 43 Geotechnical Monitoring 22 Mechanical Equipment 44 Procedure Control

  • STp 59 A (1-831 P Roc. No.

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PAGE oF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 15 18 QATE143UED SV 8J E CT TREND ANALYSIS 03/19/85 ATTACHMENT 5 (Cont.)

ACTIVITY 45 Nonconformance Control 59 Corrective Action 46 Fire Protection (O

Temporary Attachments 47 Design Document Control 61 Records Control 48 Records Review 62 Other 49 Seismic 63 Calculations 50 Installation / Erection 64 QSDRs 51 Procurement Document 65 AFRs Control 52 Evaluation / Selection 66 Maintenance of Suppliers 53 Supplier Cor. trol 67 Start-up Testing:

Electrical 54 SDDRs 68 Start-up Testing: Mechanical 55 organization / Responsibility 69 Start-up Testing:

I&C 56 Control of Purchased 70 Inservice Inspection Material / Equipment / Services 57 Material Control 71 Emergency Plan 58 Testing 72 Radwaste

STP 59 A (1831

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TITLE

' AGE OF PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 16 18 SUSJECT O ATE ISSUED TREND ANALYSIS 03/19/85 ATTACHMENT 6 DEFICIENCY TYPE 01 Preplacement 23 Codes and Standards 02 Placement 24 Specification 03 Postplacement 25 Incorrect Quantity 04 Damage 26 Identification 05 Documentation 27 Frequency 06 Test out of spec 28 Manufacturers Requirements 07 Procedural 29 Zone Violation 08 Mislocated 30 Access Control 09 Missing 31 Traceability 10 Alignment 32 Improper Storage 11 Bolt up 33 Tagging 12 k* eld defects 34 Segregation 13 Surface Preparation 35 Qualifications 14 Application 36 Unauthorized Release 15 Post application 37 Drawing 16 Testing 38 Incorporation 17 Splice preparation 39 Improper Inspection 18 Hold points missed 40 Improper Review / Approval 19 Configuration 41 Training 20 Instrument Set Points 42 Improper process 21 Mechanical Set Points 43 Improper rigging 22 QA Program 44 Handling

HP 59 A H 831 PrioC. NO.

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HOUSTON UGHTING O POWER COMPANY SOUTH TEXAS PROJECT PROCEDURE MANUAL PSQP.16.3 3

PAGE oF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 17 18 SU8JEc7 OATEISSUED TREND ANALYSIS 03/19/85 ATTACHMENT 6 (Cont.)

DEFICIENCY TYPE 45 Timeliness 65 Corrosion 46 Drafting Deficiency 66 Improper Maintenance 47 Quality Surveillance Plan Violation 67 Contamination 48 Design Error 68 Tech Spec Violation 49 Improper Audit 50 Improper Specification of Quality Requirement 51 Other 52 Material Acceptance 53 Material Change 54 Technical Change 55 Corrective Action Acceptance 56 Cleanliness 57 Incorrect / Inadequate Distribution 58 Incorrect / Inadequate Status 59 Dimensions out of Tolerance 60 Fabrication Errors 61 Minimym Wall violations 62 Base Material Defects 1

63 Fabrication / Installation I

without approved documents 64 Interference t

STP h A (1-83)

PRCC. NO.

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HOUSTON LIGHTIN3 O POWER COMPANY SobTH TEXAS PROJECT PROCEDURE MANUAL PSQP-16.3 3

i PAGE OF TITLE PROJECT SPECIFIC QUALITY ASSURANCE PROCEDURE 18 18 OATEISSUEO SUBJECT TREND ANALYSIS 03/19/85 ATTACICfENT 7 TREND INVESTIGATION REQUEST woustoas uoMTiNG a powEn souTM TE x As PmOJECT ELECTaic GENER AYtNG STAT 60*e TREND INVESTIGATION REQUEST

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