ML20211K048
| ML20211K048 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/26/1984 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20211J491 | List:
|
| References | |
| FOIA-85-59 CP-QP-16.0, NUDOCS 8606270136 | |
| Download: ML20211K048 (13) | |
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PROCEDURE ISSUE R
QN PAGE TEXAS UMUMES GENERAMNG CO -
NUM8ER DATE
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CP-QP-16.0 12 JAN 2 6 534 1 of 13
,u.7 PREPARED BYr,-
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NONCONFORMANCES
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1.0 REFERENCES
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l 1-A CP-QP-15.0, " Tagging System" J
.L 2.0 GENERAL U
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2.1 PURPOSE AND SCOPE Ig 1
The purpose of this procedure is to establish a method of documenting the identification. resolution, and closecut of nonconfomances as defined in Paragraph 2.2.
It is the responsibility of all site employees to report items of f
nonconfomance to their supenisor or to the 1UGC0 Site QA Supervisor.
The requirements contained herein are applicable to nonconfomances identified for materials, services or items associated with safety-related structures, systems and components not under the jurisdiction of the ASE Code,Section III, Division 1.
NOTE:
When nonconfomances are detected by inspection and testing, they shall be reported in accordance -
with quality procedures / instructions describing the inspection or testing functions.
Where.
specific guidelines ar's not given in quali ty procedure / instructions" the provisions of this l
procedure shall govern.
In Oct.1983, a Building / Matrix Management Organization was established for the completion Df Unit I and Common.
Section 3.1 and 3.3 of this procedure describe the processing of nonconfomances under this system.
Section 3.1 and 3.2 describe the processing of nonconfomances for Unit 2 and areas not under the Matrix organizat?on.
2.2 DEFINITION 2.2.1 Nonconfomance A deficiency in characteristic, docunentation, or procedure
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which renders the quality of an iten unacceptable or in-deteminate.
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g PROCEDURE REVISION ISSUE PAGE NUMBER DATE TEXAS UTILITIES GENERATING CO.
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1 m ES CP-QP-16.0 12 2MD jgg p 4,C,!d l
3.0 PROCEDURE 3.1 NONCONFORMANCE IDENTIFICATION 3.1.1 Field Identification When a nonconfoming condition as defined in Paragraph 2.2.1 is identified, the individual shall inmediately apply a Hold Tag, when practical. (Reference 1-A) and note his name and telephone extension on the tag. He shall return and note on the Hold Tag the appropriate NCR neber when obtained fran the TUGC0 NCR Coordinator.
NOTE:
For electrical activities, the inspector say use his judgement to apply a Hold Tag to a nonconfoming internal component. For example, the inspector my apply a Hold Tag to a broken / damaged teminal strip c
and note on the Hold Tag wording such as " Applied to Teminal Strip Only." On the NCR the statement
, g would be " Applied to Terminal Strip Only - other unrelated activities may proceed."
3.1.2 Reporting Nonconfoming conditions shall be reported on the NCR fom (Attachment 2).
Supporting documentation, e.g., Inspection Reports NDE reports, drawings shall also be attached to the MCR where appropriate.
The location of the nonconfonning condition (structure, rom neber, elevetion and area code)
I and the system /subsyista neber sh'all be recorded on the NCR fom.
NOTE:
The system /subsysten neber is not required for discrepancies relating to conduit, cable trays, protective coatings, cable tray hangers or anchor bolt locations provided that the structure is identified.
3.1.3 Numbering the NCR
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8efore sending the NCR to the Quality Control Supervisor, or l
his designee, the individual reporting the nonconformance shall obtain a neber from the TUGC0 NCR Coordinator. This number shall be 'noted on the NCR and on the Hold Tag per Reference 1-A that is applied to the nonconforming iten/
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coquipment.
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PROCEDURE ISSUEi REVISION NUMBER DATE PAGE TEXAS UTILITIES GENERATING CO.
C' CPSES CP-QP-16.0 12 3 of 13 0 6 1984 The TUGC0 NCR Coordinator shall assign numbers as follows:
e.g.
NCR M
80 00214 l
sequential NCR nimber for that year year Discipline (_ Mechanical, Ton, Civil)
Electrical
_Tnstumentat For NCR's on items / components turned over to TUGCO, the TUGC0 NCR CoonHnator shall add the letter "S" after the NCR neber and forward a copy to TUGC0 Startup for information.
The TUGC0 NCR Coordinator enters the NCR neber and brief description of the nonconfoming condition in the Master NCR Log (Attachment 3).
NOTE:
The TUGC0 ER Coordinator shall periodically h
review the Master NCR Log (at least annually) to ensure accuracy.
3.2 PROCESSING NONCONFORMANCE REPORTS FOR UNIT 2 AND AREAS NOT UNDER THE MATRIX ORGANIZATION 3.2.1 Draft NCR The inspector will sign and forward the draft NCR to the Discipline QC Supervisor or desdgnee.
When individuals assigned to departments other than QA/QC are reporting a nonconfomting condition, they shall forward the draft Nonconfomance Report to the TUGC0 NCR Coordinator for processing in accordance with this procedure.
3.2.2 Pre-Issuance Review and Preparation The reported nonconfomance shall be evaluated by the Discipline Quality Control Supervisor or his designee for clarity, accuracy, validity. specificity and legibility.
3.2.2.1 NCR's may be voided at any time if it is determined.that i
nonconforming conditions do not exist, the _nonconformance was previously reported on another NCR or other simila'r conditions exist.
In the event that an NCR is' determined
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to be invalid, ' Void" shall be entered in bold letters in the disposition block with the reason and justification Penn sees a
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. PROCEDURE REVISION ISSUE NUMBER DATE PAGE TEXAS UTIUTIES GENERATING CO.
C CPSES CP-QP-16.0 12 JAN 2 6 Iggo 4 of 13 for voiding the NCR. Any pertinent supporting documentation shall be attached to the NCR and referenced in the reason /
justification statenent s.
Voiding of NCR's shall be approved by the QA/QC Supervisor or his designee by placing his signature and the date under 'the reason /
justification statement.
The original voided ER will be forwarded to the TUGC0 NCR Coordinator.
3.2.2.2 If the NCR is determined to be valid, the Discipline QC Supervisor signs and forwards the draft NCR to the TUGC0 NCR Coordinator.
3.2.3 NCR Issue The TUGC0 NCR Coordinator enters.the date issued in the NCR Log, maintains the original and forwards a copy of the NCR to an " Action Addressee".
(The
" Action Adressee" nomally is the responsible Q^
Engineering Supervisor who evaluates and dispostitions the reported nonconfonnances.)
3.2.4 Disoosition 3.2.4.1 Final Disposition (Rework, Repair, Scrap, Use-as-1s)
The
" Action Addressee".shall evaluate each reported nonconforming condition and detemine an appropriate disposition to correct and/or resolve the nonconfomance.
The disposition shall be clearlf and concisely reconfed in the " Disposition" space on each NCR according to the following:
a.
The. respective disposition block (s) shall be checked (i.e., Rework, Repair Use-As-Is and/or Scrap).
I b.
Rework Dispositions shall specify the rework actions required to correct the nonconforming conditions and bring the affected items into compliance with the specified requirements.
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c.
Repair Dispositions shall specify the repair -actions required to bring the nonconforming characteristic (s) to a condition such that the capability of the affected iten to function reliably and safely is unimpaired.
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even though the item still say not confom to specified requirements.
Aepair dispositions shall also include appropriate. Engineering technical. justification for l
acceptance of the item with characteristics that do l
not comply with specified design requirements.
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PROCEDURE REVISION ISSUE NUMBER DATE PAGE
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CPSES CP-QP-16.0 12 JAN ? 6 1984 5 of 13 d.
Use-As-Is Dispositions shall include sufficient Engineering technical justification to establish that the nonconfoming characteristic will result in no adverse conditions and that the affected item will continue to meet all Engineering functional requirments,
. including performance, maintainability, fit and safety.
e.
Scrap Dispositions shall be made when it is detemined that an item is unsuitable for its intended purpose and cannot be feasibly or econmically reworked or
._..repai red.
3.2.4.2 Temporary Waiver For those nonconforming items which Construiction/ Engineering desires to continue to process on a " risk removal" basis, authorization shall be requested in the NCR disposition. In i
order to receive this authorization to continue the process, the following conditions umst be ' satisfied:
1 a.
The ER disposition shall include sufficient infoma-tion and direction for accomplishing the wort. Detail shall be provided to pemit adequate evaluation of potential impact to affected parties (i.e., construction.
l engineering, QA/QC, records, start-up and operations);
b.
Engineer Review / Approval shall be by the Engineering Group Supervisor or above; c.
Quality Assurance Review / Approval shall be by the Discipline QA/QC Supervisors or above.
After approval of the disposition a Blue Teporary Waiver Tag, per Reference 1-A, shall be affixed to the item. The ER neber shall be noted on the Temporary Waiver Tag.
3.2.5 Quality Assurance Review The NCR disposition shall be reviewed by the Discipline Quality Engineer for adequacy and conformance to applicable speci fications, code requi rements and current drawing /
design change.
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CPSES Cp-Qp-16.0 12 M26 @
6 of 13 If the review is satisfactory the TUGC0 NCR Coordinator will have the disposition entered on the original, obtain the required signatures, and enter the date on the NCR log.
If the disposition is not satisfactory, the Quality Engineer shall resolve all comments with the Engineer who dispositioned the NCR.
Based on his review, the QE may recommend voiding in accordance with Section 3.2.2.1.
((pon Quality Engineering approval of the disposition, and prior to beginning any rework / repair, QC shall remove the red hold tag and blue waiver tag (if applicable).
3.2.6 Revision of Nonconfonnance Reports When changes are required to the nonconfonning condition or disposition, the NCR shall be revised.
This revision shall be denoted on the NCR nimber and the reason (s) for h
revision included in the comments section.
The necessary approvals shall be obtained in accordance with this l
procedure for the portion affected by r'evision.
3.2.7 Implementation of the Disposition NCR's dispositioned " Rework", " Repair" or " Scrap" shall be sent by the TUGC0 NCR Coordinator to the appropriate department responsible ' for scheduling / coordinating work activities for iraplementation of t,he disposition.
NCR disposition "Use As Is" sha'11 be sent to the Non-ASME QA/QC Supervisor for approval.
For iiCR's dispositioned as " Rework", " Repair", or " Scrap" and identified with an "S"
after the NCR number, an l
infonnation copy will also be sent to TUGC0 Startup.
3.2.8 verification / Closure The Discipline QC Supervi sor shall ensure that. the NCR disposition work items are verified and/or witnessed _by QC.
QC shall doc ment their inspections (vi a, inspection reports, checklists, travelers, etc. as required).
These-docuents shall be either attached to or referenced on the NCR as appropriate, (j-
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CPSES CP-QP-16.0 12 7 '# 13 JAN ? 61994 The QA/QC Supervisors, or their designee, shall close the NCR by signing the " Verification" block of the original.
The closed NCR will then be transmitted by the NCR Coordinator to the Pemanent Plant Records Vault and' the date entered in the NCR log.
3.3 PROCESSING NONCONFORMANCE REPORTS FOR UNIT 1 AND COMMON (SEE ATTACHENT 1 FOR NCR FLOW) 3.3.1 Draft E R Following completion of activities specified in Section 3.1, the inspector will sign and forward the draft 'NCR to the Building QC Supervisor or designee.
When individuals assigned to departments other than QA/QC are reporting a nonconfuming condition, they shall fomard the draft Nonconformance Report to the Building ER Coordinator for processing in accordance with this procedure.
3.3.2 Pre-Issuance Review and Preoaration The reported nonconfomance shall be evaluated by the Building Quality Control Supervisor or his designee for
.clari ty, accuracy, validi ty, specificity and legibili ty.
l 3.3.2.1 ER's may be voided by the Building QC Supervisor if 1t 1s detemined that nonconfominfi conditions do not exist, l
the nonconformance was previous'y reported on another NCR or other similar. conditions exitst In the event that an NCR is detensined to be invalid,'" Void" shall be entered in
. bold letters in ' the disposition block with the reason and justification for voiding the ER. Any pertinent supporting documentation shall be attached to the ER and referenced in the reason / justification statements..The original voided ER with supporting douanentation shall be filed in the PPRV and a copy forwarded to the TUGC0 ER Coordinator.
3.3.2.2 If the NCR is detemined to be valid, the Building QC Supervisor signs and forwards the draft NCR to the Building NCR Coordinator.
The Building NCR Coordinator' sends a duplicate copy to the TUGC0 ER Coordinator -for Teduntant filing.
l 3.3.3 NCR Issue L
The Building NCR Coordinator enters the date issued in the Suilding ER Log and forwards the original ER to an " Action i
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(. r PROCEDURE REVISION ISSUE NUMBER DATE PAGE F.
TEXAS UTILITIES GENERATING CO.
CPSES cp'-QP-16.0 12 8 of 13
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Addressee".
(The Building NCR Log will be similar to the Master Log maintained by the TUGC0 NCR Coordinator.)
(The
" Action Adressee" normally is the responsible Construction / Engineering Building Supervisor who evaluates and dispositions the reported nonconfomances.)
3.3.4 Disoosition 3.3.4.1 Final Disposition (Rework, Repair, Scrap, Use-as-is) repoked The
" Action Addressee" shall evaluate each nonconforming condition and determine an appropriate disposition to correct and/or resolve the nonconformance.
The disposition shall be clearly and concisely recorded in the " Disposition" space on each NCR according to the a
following:
The respective disposition block (s') shall be checked a.
,Q (i.ei, Rework, Repair Use-As-Is and/or Scrap).
b.
Rework Dispositions shall specify the rework actions '
required to correct the nonconforming conditions and bring the affected itens into compliance with the specified requirements.
c.
Repair Dispositions shall specify the repair actions required to bring the nonconforming characteristic (s) to a condition such that the capability of the affected item to function reliably.Wnd safely is unimpaired, even though the itan still nay not confom to specified requirements.
Repair dispositions shall also include appropriate Engineering technical justification for acceptance of the iten with characteristics that do not comply with specified design requirements.
d.
Use-As-Is Dispositions shall include sufficient Engineering technical justification to establish that the nonconfoming characteristic will result. in no adverse conditions and that the affected iten will continue to meet all Engineering functional requir'emer,ts, including perfomance, maintainability, fit and safety.
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CPSES CP-QP-16.0 12 JM 2 6 ga 9 of 13 e.
Scrap Dispositions shall be mde when it is detemined that an item is unsuitable for its intended purpose and cannot be feasibly or economically reworked or repaired.
3.3.4.2 Temporary Waiver
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For those nonconfoming items which Construction / Engineering desires to continue to process on a " risk removal" basis, authorization shall be requested in the NCR disposition.
In order to receive this. authorization to continue the process, the following conditions must be satisfied:
a.
The NCR disposition shall include sufficient informa-tion and direction for accomplishing the work. Detail shall be provided to permit adequate evaluation of potential impact to affected parties (i.e., construction, engineering, QA/QC, records, start-up and operations);
b.
Engineer Review / Approval shall be by the Building Group Supervisor or above; c.
Quality Assurance Review / Approval shall be by the Building QA/QC Supervisors or above.
After approval of the dispositinn a Blue Temporary Waiver Tag, per Reference 1-A, shall be affixed to the item. The NCR number shall be noted on the Temporary Waiver Tag.
3.3.5 Quality Assurance Review The NCR disliosition shall be reviewed by Quality Assurance for adequacy and conformance to applicable specifications, code requirements and current drawing / design change.
Disposition for scrap, rework, and standard repairs are l
approved by the Building QC Supervisor.
Dispositions for use-as-i s and non-standard repairs shall be approved by the Non-ASME QE Supervisor.
If review is satisfactory the Building NCR. Coordinator shall enter the date on the NCR log.
If the disposition is not satisfactory, the Building QC Supervisor or Non-ASME QE Supervisor, as appropriate, shall resolve all comments with the Engineer who dispositioned the NCR.
The Building NCR Coordinator. sends a duplicate dispositioned copy to the
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g.c 66 PROCEDURE REVISION ISSUE NUMBER DATE PAGE TEXAS UTILITIES GENERATING CO.
CPSES Cp-QP-16.0 12 l
JAN ? 61984 10 of 13 Upon Quality Assurance approval of the disposition, and prior to beginning any rework / repair, QC shall remove the red hold tag and blue waiver tag (if applicable).
3.3.6 Revision of Nonconfomance Reports When changes are required to the nonconforming condition or disposition, the NCR shall be revised.
This revision shall be denoted on the NCR ntsnber and the reason (s) for revision included in the connents section.
The necessary l
approvals shall be obtained in accordance with this
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t procedure for the portion affected by revision.
3.3.7 Implementation of the Disposition NCR's dispositioned " Rework", " Repair" or " Scrap" shall be sent by the Building ER Coordinator to the appropriate building department responsible for scheduling / coordinating work activities for implementation of the di sposition.
For NCR's dispositioned as " Rework", " Repair", or " Scrap" and identified with an "S"
after the NCR msnbe r, an j
information copy will also be sent to TUGC0 Startup.
3.3.8 Verification / Closure The QC Building Supervisor shall ensure that the ER disposition work itens are verified and/or witnessed by QC.
QC shall doctament their inspections (vi a.
inspection reports, checklists, travelers. etc. as required).
These docisments shall be either attached to or referenced on the ER as appropriate.
The QE or QC Supervisors, as appropriate, or their designees.
shall close the ER by signing the " Verification" block of the original.
Copies of closed NCR's will be distributed by the cognizant Building NCR Coordinator as follows:
The original will be sent to the appropriate building a.
Paper Flow Group who will transmit to the. Permanent Plant Records Vault (PPRV).
b.
A copy of the closed ER will be sent to the.TUGQ)
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ER Coordinator for Master Log. updating and duplicate filing.
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UNIT 1 AND CD19e0N IICR FLOW OIART OC IDENTIFIED COICITION.
Pmperes IICR & obtains l
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l reviews and approves IICR_
Su11 ding IICR Coordinator log and centrol origine)
TUGD5 IICR COPY Cooreinator Griffnel to t$e o
Disposittenin
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Use-As-Is and fleMtandard 8#11 ding QC Supervisor 11 0,
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F myiew and approve Suoervisor diseosition O!5P05!T!0 LIED COPY YES era a n emne." m. ired VE5 dec.ents I
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GA review and closure f Sw11 ding IICR rdinator CLOSED CtFY d
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REVISION NUMBER O
PAGE THAS UTiuTIES GENERATING CO.
CPSES 12
- AN 2 61984 CP-QP-16.0 12 of 13
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