ML20212K774
| ML20212K774 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 11/03/1986 |
| From: | Jackson L TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212K537 | List: |
| References | |
| 1707.01.01, NUDOCS 8703090415 | |
| Download: ML20212K774 (34) | |
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@ NUC PR REQUIREMENT NUC PR NUC PR POLICY STANDARD gg nonreau nonervure PROCEDURE No. _
1707.01.01 PROGRAM NUCLEAR PROCEDURES STATT sik."W 0 31986
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NUCLEAR POWER INFORMATION
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N71A1 REVI5 ION LCG
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RLN!SION DATE-
- PAGES AFFECTED DESCRIP?!GI CF CHANGE 4/30/81-All General revision to describe the controls over quality.
assurance program-related DPM's,the new review / approval
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cycle 'with associated cova. sheet, and the schedule for isolamentation of new recuirements.
10/20/81 Page 6 To more clearly present :Lnformation about the scope of the waiver. Ensures that all manual holders know about approved waivers.
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1/28/82 All To reflect reorganization and change in implementation schedule.
6/9/82 All To update and to include revised cover sheet.
5/10/83 All.
Added ' definitions; clarified use of QA-implementir.g I
division procedure waivers and receipt by users'
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crganizations.
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$EP 2 0 '83 All (pages 1-14)
To be in complianco with applicable sections of 0QAM.
DEC 2119g4 Allkpages1-14)
To indicate that the procedure is applicable to the M
entire divisien. Add program interpretations require-As-wa4 4 ment, Add requirements to show applicability of pro-cedures in. scope. To change titles on change request form to be in line with citlwu un coversheet and add
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current revision date on procedure. To clarify role of RMCU in preparation and processing of program pro-
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Coversheets for canceled procedures will be
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in circulating copies only. To remove requirement for j
Chief, QSB, to approve waivers on non-QA procedures.
a To remove resource approval from the waiver. request (it vill be covered in Program Procedure 104).
t To clarify that program procedures having disapproved waivers shall be implemented within 90 days of dis-approved waiver date. To give the site director the flexibility of implementing area plan as it' relates to plant mode or activities without requiring a waiver.
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Added requirement of justification statement and require-of signature en coversheet of Nuclear Services ment Director.
(Continued on next page.)
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-e x OFFICE OF NUCLEAR POWER REVISION LOG PROCEDURE No.
1707.01.01 REV.NO.'
PAGES AFFECTED DESCRIPTION OF CHANGE '
DATE EC21 g (Continued)
JUST1FICATION: Changes were necessary to clarify items relating to the processing and preparation of program I
procedures and waiverst also to give the plant more i
flexibility in the implementation of program procedures i
per A. H. Qualls change request (L65 840113 354). This is an interim revision pending restructuring of the NUC PR program procedures--formerly part of the area plan.
0 All (1-15)
General revision. Changed title (formerly Program Manual),
3/21/85 reformatted and revised in accordance with new PMP philosophy, updated to address currarit NUC PR organization, and changed allowable designation from QA Program Related.
QA I=plementing, and Non-QA to NUC PR Requirement, NUC PR Policy, and NUC PR Standard.
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Tnis revision will be designated Revision "O" to initiate the use of revision levels.
1 Pages 2, 6-10,13-15 Deleted requirement that "NUC PR Standard" procedures be 4/10/85 implemented within 90 days or waived, made implementation optional, and deleted Attachment 5, " Waiver Request."
Revised Attachment 4, " Change Request," to expedite handling by RPS and include requirement that all regulatory co==1tments be identified for any procedure cancellation.
Changed names of RMCU and ARMS to RPS and RIMS, respectively.
2 Pages 3, and 8-10 Revised 5.6 to eliminate reference to waivers. Revised 007 3 0 W 6.6.3 to show revisiens will be identified by asterisks
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instead of the vertical line. Section 6.8.2 revised to
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clarify (definition and intent of NUC PR Standard procedures.
Added 6.9 to dascribe the procedural controls to be observed during the transition frem PMPs to Power and Engineering (Nuclear) directives.
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All (1-16)
This is a general revision to recognise organizations not previously covered by PMPs, to enable the revision or NOV 0 319 M tssuance of new PMPs, to previ6e an acceptable means to issue CNP interface procedures prior to availability of the new ONP Nuclear Procedures System, to document l
concurrence by affected managers of "NUC PR Requirement" h
L and "NUC PR Policy" R4Ps, and to establish the Manager, i
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i NOV 0 31986 D PROGRAM PROCEDURES PAGE I __ DATE F'
_RCC2 DURE NO. 1707.01.0?
REVISION 3
ss KEWORDS: Program Procedures s
1.0 PURPOSE This procedure establishes the controls and responsibilities.for preparation, approval, revision, and implementation of Program Manual Procedures (PMPs) issued by the Office of Nuclear Power (ONP) until the
. system of ONP Directives and Standards replaces them.
2.0'.
SCOPE
' he program manuals comprise a system of procedures issued by ONP.
These program procedures establish work practices for conducting ONP activities, identify and interpret requirements and commitments, define
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.. administrative and work standards, and provide guidance important for consistent, safe, and effective operation of the nuclear facilities.
All ONP divisions, sites, and staffs included in the current organization are considered to be within the scope of this program procedure.
ONP directives may be prepared to describe the interim procedures system controls in effect for specific plant sites or projects. Such directives take precedence over this program procedure, but any program procedures 7 ;_,
identified by those directives continue to be controlled by this program s
procedure. Sites and projects that do not have interim procedures system controls in effect under ONP directives shall continue to meet the requirements of appropriate program procedures including those of this program procedure.
3.0 REFERENCES
1 Scurce Documents
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3.1.1 10 CFR 50, Appendix B.
3.1.2 Topical Report - TVA-TR75-1A.
'3.1.3 NQAM, Eart III, Section 1.1.
-u 3.2 Reference Documents PMP 1707.03.01, " Controlled Documents."
4.0 DEFINITIONS 4.1 dom.mitment - An agreement made with a regulatory agency (principally the NRC) by an authorized representative of TVA, which agreement requires TVA to complete a specified action within a specified time frame and is documented in a formal written communication to or from the regulatory agency. Written comunications cenfirning commitments made verbally in the first instance need not be docketed.
General Revision MANUAL-1707.01.01 l
TVA 7929c toNkl.as)
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PROGRAM PROCEDURES
.PAGE 2
DATE NOE0.7toog
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REVISION 3
4.2 May - Use of the term "may" connotes permission which is neither a' requirement nor a recommendation.
4.3. NUC PR Policy - Program procedures are so designated if the actions described therein stem from TVA/0NP policy and are not regulstory in nature.
4.4 NUC PR Requirement - Program procedures are so designated if they require specific actions to meet regulatory requirements or commitments.
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4.5 NUC PR Standard - Program procedures are so designated if they 9, ',-
describe a standard way of perfor.aing prescribed activities, convey technical or administrative guidance, or contain recommendations for work performance.
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. --4. 6 Program Manual Procedure (PMP) - A document that describes a func-1 -
tion or activity to be performed and identifies requirements,.
responsibilities, or methods for its performance, as applicable.
4.7 QA Implementing - A term used to designate program procedures before the designations of NUC PR Standard, NUC PR Requirement, and NUC PR Policy were established. Program procedures designated
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as QA Implementing contain regulatory requirements or commitments
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considered within the scope of the quality assurance program.
f-4.8 QA Program Related.- A term used to designate program procedures before the designations of NUC PR Standard, NUC PR Requirement, and NUC PR Policy were established. Program procedures designated as QA Program Related contain quality assurance program requirements and are considered extensions of the NQAM.
4.9 Reference Document - A reference document provides related information which may be used in preparation of a program procedure.
4 4.10 Shall - The term "shall" denotes a requirement.
4.11 Should - The term "should" denotes a reconsnendation based upon
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administrative policy, consistency between plants or work
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Compliance is discretionary based upon technical or supervisory
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judgement.
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4.12 '[ource Document - A source document identifies requirements or commitments which are used in the preparation of a program i
procedure. A source document may be a regulation, regulatory document, or documented commitment.
q, MANUA!.-1707.01.01 General Revision TVA 7989C tomal ell
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e Will - Use of the term "will" means that an organization or r
4.13 individual is expected or supposed to carry out the designated action.
5.0 RESPONSIBILITIES 5.1 Manager of Nuclear Power The Manager of Nuclear Power or his designate shall approve all new or revised program procedures designated as "NUC PR Requirement" or "NUC PR Policy."
5.2 Director of Nuclear Quality Assurance The Director of Nuclear Quality Assurance or his designate shall review and concur with all program procedures designated as "NUC PR
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Requirement" to verify that they do not conflict with the He shall also review other
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established quality assurance program.
program proegdures (NUC PR Policy and NUC PR Standard) during the coordination' phase in accordance with 6.5.3 below.
5.3 Division Directors The division directors or their designates shall review and concur
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with all new or revised prograin procedures which affect their They shall approve program procedures which are divisions.
prepared by their divisions.
5.4 staff Managers The staff managers or their designaces shall review and concur with all new or revised program procedures which affect their staffs.
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They shall approve prcgram procedures which are prepared by their
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5.5 Site Directors L
The nuclear site directors or their designates shall review and 3Q.y,h**
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concur with new or revised program procedures which affect their 38 :-
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sites.
5.6 Program Coordinator The designated program coordinator is responsible for review and coordination of each program procedure or revision in his assigned program in accordance with 6.5.3 below.
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MANUAL-1707.01.01 General Revision rvA ru,c com.ni
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Title:
PROGRAM PROCEDURES PAGE 4
DATE PROCEDURE NO. 1707.01.01
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5.7 Division of Nuclear Services The Document Control and Records Management Branch (DCRMB) of the Division of Nuclear Services shall process, issue, and control program procedures in accordance with this procedure and 1
PHP 1707.03.01.
5.8 Nuclear Procedures Staff Followingconcurrencebytheaffectedorganizationsandapprovai by the sponsoring organization, the Manager, Nuclear Procedures Staff, shall review and approve program procedures prepared by that staff.
6.0 REQUIREMENTS f
6.1 Designation 6.1.1 A program coordinator shall be designated for each program by the responsible manager or director.
6.1.2 There are three categories of program procedures: those designated "NUC PR Requirement," those designated "NUC PR Policy," and those designated "NUC PR Standard." (See
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section 4.0, Definitions.) Additionally, there are
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previous designations still in existence as identified in section 6.9.
6.1.3 Program procedures may reference but should not duplicate docu.ments available to the plants and support organiza-tions, such as TVA administrative procedures, regulato ry dccuments, and supplier bulletins. The program procedures
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may, however,,,be used to interpret or amplify the contents of such documents.,
6.2 ' Numbering for Proce ures
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6.2.1 Program procedures shall be consistently numbered in each program manual, using the program araa number (first two digits), the element number (next two digits), a decimal, and two or more digits for the sequential number.
If subdivision within an element is necessary, a second decimal and two or more digits may be inserted af ter the element number.
Example:
1708.08 or 1708.01.08 6.3 Procedure Organization 6.3.1 Program procedures shall include the following major
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sections, as a minimum:
General Revision MANUAL-1707.01.01 TVA Flate (ONeel.4$)
ti2Fds NOV 0 31986
Title:
PROGRAM PROCEDURES PAGE DATE PROCE E NO. 1707.01.01 REVISION 3
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Coversheet (attachment 1).
Revision log (attachment 2).
I Keywords Descriptive keywords for ADP listing.
,j 1.0 Purpose Contains a brief statement of the objective of the procedure.
2.0 Scope Contains a brief statement of the subject area (s) to which the procedure applies and identifies the organizations to which it is I
applicable (e.g., DNS and licensed
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nuclear plants only).
3.0 References In two parts:
- 1. Source Documents _
is a listing of source documents for this procedure.
- 2. Reference Documents lists other documents related to or used in preparation of the procedure.
(If none enter "None.")
4.0 Definitions Lists and defines significant terms used in the subject procedure.
(If none enter "None.")
5.0 Respohsibilities identifies the responsibilities of functional position and
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i organizational units for
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implementing the subject procedure. Normally not l
designated below division or major staff levels.
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6.0 Requirements contains the specific require-l i
ments for control of work
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activities or processes,
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personnel qualifications, fi periodic reviews, acceptance
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criteria, and reporting activities. Designates specific records that shall be j
l retained to verify compliance i
with the process.
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PROGRAM PROCEDURES PACE 6__
DATE 1707.01.01 PROCEDURE No.
REVISION 3
t.ontent 7.0 Records Designates records generated by the procedure that are to be
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8.0 Attachments Lists and includes the attached documents. Each attachment shall be identified by title and number.
6.3.2 Supplements may be used to revise program procedures instead of a complete revision. The supplement will be attachec behind the revision log when used. Supplements require review, concurrence, approval, and control in the same manner as other revisions.
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'6.4 New or Revised Proeram Procedure Request All requests for new or revised program procedures or cancellation shall be in accordance with this section.
6.4.1 The Change Request Form memorandum (attachment 4) is the means of transmitting all requests for new or revised
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program procedures or their cancellation. They are to be
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duly reviewed and approved and sent from the originator's supervisor to the DCRMB for further processing and transmittal to the responsible organization with a copy to the Nuclear Procedures Staff. Each new or revised program procedure request will be entered into the DCRMB tracking system and forwarded to the program coordinator for handling.
6.4.2 For new progra'm' procedures, the request originator will
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- r prepare a draft of the procedure and attach it to the transmittal form (attachment 4).
For program procedure revision, the request originator will mark the changes on a copy of the latest revision and attach it to the V
t.ransmittal form.
f The request originator shall enter the appropriate informa-tion on and sign the transmittal form. The transmitta'l shall be reviewed and signed by at letst the originator's
,i supervisor before being sent to the responsible organization and the Nucicar Procedures Staff.
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The Change Request Form memorandmn includes space for 6.4.3
,," Reason for Request." An adequate reason for the request shall be provided including any commitment.
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DATE NOV 0 31986 PROGRAM PROCEDURES PROCEDL3E No.1707.01.01 REV!S!ON 3
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of a program procedure. The applicable block shall be checked for each such request.
6.4.5 The program Toordinator shall review and approve or disapprove t.he request within 20 days and, if he concurs, j
autnerize the effort. The change recuest originator shall be notified of the status by the program coordinator uit.hlu 30 days of initiation of the request.
6.5 Review /Aporoval Cycle for Procedures All new program procedures and revisions, including cancellations, shall be reviewed and approved in accordance with this section.
6.5.1 The assigned preparer shall write or revise a program He shall ensure that the program procedure e
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procedure.
complies with applicable requirements and identifies the source documents (e.g., ANS1 Standards, Regulatory Guides, CFR, TVA Code, etc.).
6.5.2 The supervisor of the preparer shall review the program procedure to ensure that it complies with quality and technical requirements and is properly marked for category.
4 6.5.3 The program coordinator shall review the program procedure to ensure that it complies with quality and technical 4
For all new requirements and to verify the proper category.
program procedures and revisions which involve changes in responsibilities or requirements, he shall submit draf ts to the affected divisiona, staffs, sites, and DNQA for review f
and comments, using the Request for Program Procedure Review (attachment 3T or a sinilar form for transmittal.
If the program procedure affects organirations outside ONP, the program coordinator shall also submit drafts to those affected organizathns for review and comment.
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Each reviewer shall coteplete the requested review of the a.
draft procedure and provide a response to the program p
e coordinator within the time specified on the form, normally 30 days from the transmittal date. Failure to respond or negotiate an extension within that period will.be interpreted as acceptance of the procedure as Written.
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Title:
PROGRAM PROCEDURES PAGE 8
DATE PROCEDURE NO. 1707.01.01 *r REVISION 3
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The program coordinator shail attempt to resolve the I
comments f rom the affected organization. Any remaining disagreements will be documented by the program coordinator and submitted to higher management up to and including the Manager of Nuciear Power for resolution and/or direction, c.
Following resolution of comments, the program coordi-nator shall finalize the program procedure draft and submit the final version to the DCRMB.
6.5.4 The DCRMB is responsible for typing the final program procedures and routing for signatures.
6.5.5 Each program procedure shall have a coversheet (attachment 1).
This coversheet includes a notation identifying the procedure as either "NUC PR Requirement,"
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"NUC PR Policy," or "NUC PR Standard," as well as spaces for the procedure number, program, and title.
It also provides spaces for designation of the current revision by number and date of issuance and for required review, concurrence, and approval signatures.
6.5.6 A revision log (attachment 2) shall be issued with each program procedure. Information entered on this log shail include the procedure number, date and number of the revision, the pages affected, and a description of the change.
6.5.7 Each program procedure designated as "NUC PR Requirement" shall be reviewed and signed by the Director of DNQA or his i ',,,,,, j ' ~,'
designate to ensure that there is no conflict with the established QA program requirement.
6.5.8 Each program procedure designated as "NUC PR Requirement" or "NUC PR Policy" shall be approved by the Manager of
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Nuclear Power or his designate before issuance. Each program procedure designated as "NUC PR Standard" shall be approved by the responsible manager or director.
j 6.5.9 Each new or revised program procedure shall be reviewed and concurred with by the division or site directors and staf f managers of the organizations affected.
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DATE N PROGRAM PROCEDURES PROCED E NO. 1707.01.01 REVISION 3
6.6 Page Identifichtion System Each program procedure page shall be identified with the 6.6.1 The page procedure title in the upper left-hand corner.
number, revision level, and procedure number (e.g.,
1707.01.01) will be shown in the upper right-hand corner.
Certain uniquely numbered program procedures in separate binders may be exempt from the page numbering system until 6.6.2 such time as they undergo a major revision.
Revised material (except general revisions) will be identified with one asterisk (*) in the left margin at the 6.6.3 beginning of any line containing material affected by Only the most recent revision will the current revision.
be identified by asterisks, and only the single most recent
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The note "* Revision" date will show'at the top of the page.
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will be printed on the bottom lef t corner of that page.
An effective page listing will be maintained by the Document Control and Records Management Branch (DCRMB)~
6.6.4 and included in each program manual.
Distribution of Procedures and Manuals _
6.7 The issuance of Program tianuals shall be controlled in accordance with PMP 1707.03.01.
Each plant site and the POTC shall be issued at least one Additional site or POTC 6.7.1 ' copy of each Program !..inual.
copies may be requested through the Plant Document Control Units (PDCUs) or.,the POTC Instructional Materials Center.
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Manuals will be issued to other organizations upon written "MT-to the DCRMB signed by the division director or request equivalent.
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A master set of manuals which contains all program
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6.7.2 procedures will be maintained by DCRMB.
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Program procedures will be forwarded to persons and organizations included on authorized distribution lists.
6.7.3 New/ revised program procedures shall be correctly filed, and receipt acknowledgement forms shall be returned.
6.7.4 4
MANUAL-1707.01.01 General Revision Ev A nuc tor.s..,
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Wij W MCA Mw NOV 0 31986 PROGRkM PROCEDURES PAGE 10 DATE f][N PROCED3 5"50. 1707.01.01 REVISION 3
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6.8 Receipt of Procedures by Implem[ntinhOrganization
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6.8.1 Responsible management shall dmplement the requirements identiiied in the program prycedures designated as "NUC PR Requirement" within 90 days of receipt. As an alternate, unless commitments to regylanory agencies limit the implementation interval, a s'ite or division director day
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uubmit to t!;e Manager of Nuclear Power or designate for his approval aniimplementation plan and schedule within this 90-day period, ~0nce approved, the implementation time I
sfacifiedintheplanandscheduleisarequirementthat y
chall be observed.
6.8.2 ThecompliancemethodklogiescontainedinNUCPRStandard procedures are nonmandatory and responsible manraement may establish alternate methods to cosply.with identified
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regulatory requirements. The regulatory requirements contained in NUC PR Standard procecares are mandatory, and s'
responsible management shall ensure regulatory requirements are adequately addressed in other procedures or instructions.
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6.8.3 Approved delayed implementation plans shall be hent to the f
originator's site Plant Document Control Unit (PDCU).
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Requests from headquarters organizations shall be r.ent,to the DCRMB. _The PDCU shall distribute the approved plan to controlled ranuals at that site and send a copy to the DERME.
The DCKMB shall prov.de an informarhon copy to the program coordinator. The PD;U shall issue'ar.' addendum to the effective page list *;; list pages inserted in site manuals only.
._,._,7 3-6.9 Transition From PMPs to ONF Directives and Standards
, 6'.9.1 In the process of documenting the new organizational structure and responsibility assignments within ONP, the
-PMPs will be' phased out and replaced with ONP directives and standards. 'The purpose cf this A*ction is to describe the l
interim procedural controls of PhIs to be observed during l
this transition period. The Nucicar Procedures Staff will coordinate this transition.
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REVISION 3
l, As a result of the reorganization, the Office of Nuclear 6.9.2 Power now includes several organizations (DNE, DNC, ECP, NMRG, PMO, etc.) that were not in the nuclear power The 1
organization when the PMPs were originally written.
program procedures are not applicabic to these new organizations except as follows:
The newly revised or issued program procedt!fe specifi A.
cally includes the new organizations in their scope.
(i.e., branch, group, The organization has some unit B.
section) which was transferred from another organization and the unit was previously under the scope of certain In this case, the program procedures m-program procedures.
applicable to the transferred unit are applicable to the new organization.
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In addition to the designations in section 6.1.2 of this 6.9.3 procedure, during this transition period some program procedures may retain other designations (e.g., QA Implementing, QA Program Related, or Non-QA), and some remain unclassified. Compliance with the requirements of program procedures designated QA Implementing and QA Program Related is required in the same manner as those designated
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"NUC PR Requirement" according to paragraph 6.8 above.
Program procedures designated as Non-QA or those still u
unclassified shall be reviewed by'the responsible organizations
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to determine if they should be made mandatory.
Those that Others 57.*
are made mandatory shall be appropriately classified.
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will remain Non-QA or unclassified and will be considered as
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non:nandatory, guidance as specified in paragraph 6.8.2 abovt.
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ONP directives prepared to describe the interim procedures 3!-$f?' " '
6.9.4 system controls in effect for specific sites or projects yi,
take precedence over this program procedure for activities at or in support of the appropriate site or project.
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Program procedures identified by those directives shall be
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prept. red, revised, reviewed, approved, and controlled in
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accordance with this program procedure.
'.0 RECORDS 7
Historical files of all program procedures and approved requests for implementation time extensions shall be raaintained by the DCRMB as QA The program coordinator and reviewers, shall document the records.
A record to document review and coordination of a procedure in RIMS.
that a periodic audit on each program manual is performed to verify correct distribution and proper up-to-date status shall be maintained.
' Working files of all program procedurcs should be maintained by the i
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DCRMS for background information only.
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FROCED M O. 1707.01.01 REVISION 3
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i 8.0 ATTACHMENTS j
J - Procedure Coversheet - Revision Log form g
.} - Procedure Review Request Form il - Change Request Form
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MANUAL-1707.01.01 General Revision i
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General Revision TV A 7939C (Opep.t.as)
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PROCEDURE.40. 1707.01.01 REVISION 3
ATTACHFJ.NT 2 l
OFFICE OF NUCLEAR POWER REVISION LOG Pet 0CEDURE NO.
Ap. MO.
PAGES AFFECTED DESCRIPTION OF CHANGE DATE d
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MANUAL-1707.01.01 General Revision TV A 7929C (OND.I.06) 1 I
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2 REVISION 3
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a ATTACHMENT 3 l
REQUEST FOR PROGRAM PROCEDURE REVIEW t
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3 To:
Those Listed i,
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- Date:
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Subject:
REQUEST FOR REVIEW OF PROGRAM PROCEDURE O New Procedure No.
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Title:
j 0 Revision to Procedure No.
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?
Title:
The proposed new procedure or revision identified above may affect
)
your organization or activities. Please provide your consients i
4 within days of the above date by either marking them in the attached draft or by separate memorandum addressed to me.
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MANUAL-1707.01.01 General Revision
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' ATTACHMENT 4 CHANGE REQUEST TOPd To: DCRM3 085' LP 4S 1268-C Procedure No.
Current Revision Level Procedure Title NEW PROCEDURE PROCEDURE REVISION PROCEDURE CANCELLATION (ettach draft)
(attaca marked copy)
Draft final
[
Procedure is ( ) NUC PR Requirement ( ) NUC PR Policy ( ) NUC PR Standard CCt0'UMENT Consitaent No.
Dae Date
===.
Reason for Request===
Reason for Cancellation:
5,
( )
A.
This procedure is no lonaer applicable. Justificassen
( )
B.
Requirement (s) La now addressed procedure No.
MT Regulatory Consitmaats (NRO, IPA, OSHA, etc..) are rentained in this les er de procecure and the site shall ensure continued implementation (attach list of ceamitments).
~
Request initiated by:
(Name)
(Istie a Graanasatton) o i
I Reques't reviewed by; l
(Name)
(Title - Organtsation)
Program Coordinator concurs with the request and aatborizes final revision
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(Tatle - Orsagapatton)
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General Revision MANUAL-1707.01.01 TVA 7939C (OMP t 4S)
4 y.:
[
s' ATTACHMENT J
~ECSP CORRECTIVE Action Tracking Document.
(CATD)
. INITIATION t
~
' _I/ No 1.
Inunediate Corrective Action Required: /_/ Yes
/
i.
2.
Stop Work Reconsnended: -/ /
i 3.
CATD No.
80503-SQN-03 _
Yes /I/ No 4.
INITIATION DATE 11/18/86
_5.
RESPONSIBLE ORGANIZATION:, SQN Site Director ~
6.
PROBLEM DESCRIPTION:- /I/ QR / / NQR The following ' discrepancies were identified pertaining to as-
~
designed latest drawing revisions in the DMS do not reflect the 3
latest drawing revision at on-site and off-site Drawing - Control Centers.
(
l.) DMS identifies drawing 17W600-4 Revision 3, Chattanooga DCC 3
latest aperture card is Revision-2 dated 6/7/78 2.)
DMS identified drawings 47W450-28 Revision 3; 47W845-4 Revision 25;'5 Revision 13; 6 Revision 2.
Aperture cards were not available for drawings at Chattanooga DCC 3.)
DMS identified drawings 47B601-55-23 Revision I and 45N706-l' d
Revision 22 where Chattanooga DCC and Technical Information ill Center in Knoxville has aperture cards with a later revision.
Site DCC has an aperture card with a later revision for drawing 47N706-1 Revision 22 but no card for-C drawing 47B601-55-23 Revision 1.
// ATTACHMENTS 7.
PREPARED BY: NAME G. A. Collins L;h. 1 DATE: 11/18/86 f
8.
CONCURRENCE:
CEG-H R. K. Maxon W g/f M sWt
//V/4 DATE:
/ /-2/fle 9.
APPROVAL: ECTG PROGRAM MGR:
/)/(r _
_ DATE:
(/-//9'/,
t CORRECTIVE ACTION
- 10.
PROPOSED CORRECTIVE ACTION PLAN:
Tc77NE/17WC//6D A 4
l-l1 i+.
I1
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR: g(g( M //n DATE: /~J -/* 7
- ?
12.
CONCURRENCE: CEG-H A4r /h DATE: r /zo /s p i!-
SRP:
/'
DATE:
'i ECTG PROGRAM MGR:
DATE:
i!-
ll VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
i i
q-SIGNATURE TITLE DATE Lf
l'
~~_..;---.
CATD. No. 80503-SQN-03 The situation, as it relates to Drawing Management System (DMS), described in 80503-SQN-03 was identified as a problem in DNE. and was reported in SCR GENIMS8501 (copy attached) which was completed and closed November 14, 1986..This SCR addressed timely and accurate entry into DMS.
Also, a similar problem exists in each DNE engineering project as it relates to aperture cards.
This situation has been identified cnd proposed corrective action documented in the preliminary DNE Project Records Management and Document Control Report.
Phase I now under review in DNE.
f In accordance with SCR GENIMS8501, each, engineering project has to develop procedures which will ensure timely and accurate entry of into the DMS.
Also, the ERIS has developed a Program Control Croup which will conduct program surveillances throughout DNE to identif y deficiencies and ensure they are corrected in a timely manner.
The group is currently being
. staffed and functional documents are prepared.
Initial implementation should begin April 1.1987.
The ERIS is developing the Drawing Change Authorization (DCA) Pilot which will be a QA-qualified system and ensure the information entered related to drawings and the change control process is accurate.
The original DMS is currently being reviewed in conjunction with the Engineering and Computer Methods Branch to ensure that the input and output data is verified to qualify the system for Usage level 2 (The system is used to generate or act upon Nuclear Design Output.
The output must be verified.
The actual deficiencies identified and shown on CATD No. 80503-SQN-03. Part 6, items
- 1. 2 and 3. have been corrected and coordinated with the TIC Center in Knoxville, Site Document Control and with the Chattanooga DCC.
DE01;LJ7 044.01
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ATTACHMENT K'
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3 L
ECSP CORRECTIVE Action Tracking Document (CATD)
. INITIATION t
1.
Inunediate Corrective Action Required: /_/ Yes /X/ No 2..
Stop Work Reconsnended:
/~/ Yes /X/ No 3.
CATD No.
80503-SQN-04'-
4.~ INITIATION DATE 11/18/86 5.
RESPONSIBLE. ORGANIZATION: SON Site Director G
6.
PROBLEM DESCRIPTION:
/X_/ QR /~/ NQR f
Corrective Action Report (CAR) SQ-CAR-85-03-005 was initiated due
.to a QA Survey Deficiency Report.
The CAR was completed by I
~ revising the applicable NQAM and Administrative Instruction AI-25 '
f Revision 13 dated 4/4/86.
Discussion with the Survey Team Leader revealed that corrective action was not accomplished on the actual deficiencies as identified on QA Inplant Survey Checklist i
Number IC-85-S-002 dated 3/14/85.
h
// ATTACHMENTS I
7.
PREPARED BY: NAME G. A. Collins (.r? A ( '/L ~ DATE: 11/18/86 8.
CONCURRENCE:
CEG-H R. K. Maxon'/WK///4--V-DATE: //-3/T(e 4
9.'
APPROVAL: ECTG PROGRAM MGR O////% %e=< tfb DATE:
//-//>f4 CORRECTIVE ACTION.
10.
PROPOSED CORRECTIVE ACTION PLAN:
Tee'TNF M4C#6b i:
5 f
r M
/ / ATTACHMENTS
{
DATE: /-2-#) -
2 11.
PROPOSED BY: DIRECTOR /MGR:,/rf'47 A'd /'/
)f 12.
CONCURRENCE:
CEG-H
/7A M - -
DATE: 2/u/p r SRP:
DATE:
C ECTG PROGRAM MGR:
DATE:
f, VERIFICATION AND CLOSEOUT Ir.
13.
Approved corrective actions have been verified as satisfactorily implemented.
[
SIGNiTuRE T1TtE DiTE o
i
.~. -
^l CATD. NO. 80503-SQN-04 With the issuance of AI-25, Part I, Revision 17 and the issuance of SQEP 49, Revision 0, " Review and Approval of Vendor Drawings," adequate controls will be in place to direct the verification and use of vendor drawings.
In addition, proposed AI-23, Revision 24 and SQEP 39 Revision ) " Review of Vendor Manuals" will also address the use of vendor drawings contained in vendor manuals.
As a part of the corrective action of Corrective Action Report (CAR)
S no commitment was made to back-check all drawings
( Q-CAR-85-03-005, contained in our present vendor manuals. However, the issuance of the above AI's, procedures provide adequate guidelines and steps to have vendor drawings placed in the DMS and as-constructed program for use in the plant.
In addition, the 10 drawings identified in the deficiency IC-85-S-002 are in the TVA drawing system and are statused accordingly.
In addition, all drawings contained within vendor manuals are for infornation only and more if that drawing must be verified with site document control before work can commence.
DE01,LJ7044.01 SQEP Feb. 13, 1987
S.J
- y ATTACHMENT-L ECSP CORRECTIVE Action Tracking Document-(CATD)
INITIATION.
~
1.
.Immediate Corrective Action Required: /_X/ Yes / /. No
'2..
Stop Work Reconsnended: /;/ Yes /X] No 3.
CATD No.-
80503-SQN-05 4.
INITIATION DATE 11/18/86 5..
RESPONSIBLE ORGANIZATION: Soit site Director 6.
PROBLEM DESCRIPTION: /X_/ QR /;/ NQR-NSRS-report I-86-185-SQN " Vendor Drawing Control" identified deficiencies with the-vendor drawing control program within the Division of Nuclear Engineering (DNE).
Corrective Actions were
[
addressed throughout the report with no evidence of a tracking document for" the deficiencies such as CARS /DRs.
The-report identified SQN vendor drawing controls are in progress through-performance of a vendor drawing audit.
QACEG identified - that this is not an ongoing audit and a' systematic plan to provide C/A has not been adopted.
Additionally no independent organization I
such as QA is utilized-to
-verify completion of f~l C/As.
// ATTACHMENTS r.
7.
PREPARED BY NAME G. A. Collins G. A. C//s DATE: 11/18/86-8.
CONCURRENCE: CEG-H R. K. Maxon-7JE/P/4 4 DATE: //- 2/- P G 9.
APPROVAL: ECTG PROGRAM MGR:
fl/ W / u orf 4 DATE:
t/~ # - W
~
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
T e 7N6~Nff/CN6b M
r d
a 1
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/ / ATTACHMENTS j
11.
PROPOSED BY: DIRECTOR /MCR: //A' /d /A DATE: >- N S 12.
CONCURRENCE: CEG-H Mtp/,.
DATE: 1/u/s >-
SRP:
/
_ DATE:
ECTG PROGRAM MGR:
DATE:
1 i
VERIFICATION AND CLOSEOUT
]'
j.
13.
Approved corrective actions have been verified as satisfactorily
[
implemented.
4 1
SIGNATURE TITLE DATE J
'02 M 1967' 09:21 PROJ MGMT/DSC-P SQN 615 870 7466 P.11 Page 1 Corrective Action (continued)
TVA drawings and vendor drawings under TVA control:
1.
Establish a single point of review for legibility when a drawing is identified for revision. Drawings should meet the following criteria:
DNg drawings to be microfilmed (TVA and/or vendor) shall be full-size original or first generation, right reading duplicate of the original and,
have consistent background de'nsity, and image density that will reproduce every line, number, letter, and character with sufficient clarity to permit reproducibility through four renerations (the fourth generation copy will be legible to the naked eye).
ERIS personnel will provide training in determining legibility to branch / project personnel as requested.
(
2.
A final review for legibility by a micrographics authority be performed as part of the drawing review process.
.3.
Restore an'y drawings *whi'ch s're not legible before revisions are issued.
Yendor drawings under vendor con'troit 1.
Include a review for legibility in the review process for vendor drawings and place drawings in one of the three following categories:
s.
Drawings to be restored immediately.
'b.
Drawings tio be restored on the next revision
- c.
- Drawings which will not be restored because they lack engineering or technical value.
' NOTE: The use of this' category should be more the exception than the rule. It should be used very rarely and then only for "Information
'Only" drawings.
These drawings should not be used for design or' construction and should never be given the status of " Approved" or
" Accepted for Use."
Vendor drawings are to be placed in one of the above categories before they are given the status of " approved" or " accepted for use."
2.
In the event that acceptable drawings cannot be obtained from the vendor,,
TVA will restore these drawings and the costs of restoration will be withhold from the final contract payment to the vendor. It it is not possible to withhold costs, TVA will absorb those costs.
Through the CAD program each time the CCD is revised a'new legible original will be generated wh$ch will minimize the illegible drawing problems.
02/80/8987 09:20 PROJ MGMTeDSC-P SQM 615 670 7466 P.10 glGNIFICANT CONDITION REPORT on Q g A
- Q Pro;ect/ Plant and Unit L2,J Date LLJ SCR Nutnbar end Rev.
All Nuclear Projects / plants IHN 2 01one scacENsarsso2
@ Preparer one Organization
@ oC NCR NoJDefictency Report 7
Condon E. Payne. ERIS Wor DC use omy)
{ @ Contract NumDer
@ Vendor Nf ridieu.A N./A, _,
so
.y
,emeni vicieie.
j Ru.al 1y As.au.Ian.ca._Ie.co.rds abal.1 bs._Lesi.ble giia source of n.quiremeni m._-.
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~
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o neition 8
E E
Legibility problema with DNE drawing originals (TVA and vendor) and the reproductions distributed for use as as-constructed drawing originals.
.E 5
Reference:
Attachments
[
'@ @ System
-~
~
@ UNID/ Component Code (For OE Use Only)
N/A N/A
.6 Q Date of QMethod of Discovery 5
Occurrence 5-19-86
{ Estimated O Actuai ina1ysis on 1,1bi11ty
'5
@ Significant Condition Lft,,J orgenaation to osterrNne corrective Action E
Adverse to Quality
.e>.
Q Yes CN BFEP, BLEP, SOEP. and VBEP k
E 11 eigniilcant, NEB.NLS Contact I[6-20-86
@ Contacted by I GA} Oste Roy Hollidav Lanny Cox
@ le e Potential Generic Condition b f yes, snit. ate Attaenment 6 of OEP 17and i
Evalystion Required?
l list Attachment 6 RIMS Accession No.!
@ Branch Chlaf or OC Ouelity Manager (Distr bute quired-see bt 30.1 O vei 5 ". J
, s/
@ nooi ceo,e Eased on ERIS analysis (B26 860519 006, copy attached) there are inadequate j
controls in the drawing review and issue process to ensure legibility of g
sdrawing originals and reproductions prior to issue and distribution.
wy In the.past, the responsibility to ensure legibi11ty of drawing originals e
j
' depended upon one design section supervisor. Scheduling priorities to issue t
the drawing'oand the quantQy"pf illegible drawings usually would preclude any 3
ae tvon..
-cowrocc.4k _ _ _
g E Corrective Action 5
E Browns Ferry initiated in June 1985, a computer-aided drafting (CAD) program to 8
restore the key operational drawingo that support the operation of the plant 3
(flow diagrama, control diagrams, key electrical diagrams, etc.).
Other 5
drawings are being scheduled to be restored by CAD under a continuing Drawing
,6 Restoration program. This is a long-term program supporting the Baseline j
hlkdown progract and e:itablishment of the single drawing of record called y
Configuration Control Drawing (CCD).
f
.This CAD program of drawing restoration will conform to the following f
requiroments.
(continued on page 1)
G oNneNn Nvieve of oE Work (Provide initleis)
Se eos Ce f
a 2
Completion g
January 1. 1990 5 E ^< tion nea 4,eo io Preveni ne.orrenet ranPai 8
a
02/20/1987 09110 PROJ MGMT/DSC-P SQN 615 870 7466 P.07 CATD NO. 80503-SQN-05 Sequoyah Engineering Project will either issue for revise existing Administrati new to clearly define and establish controls of Sequoyah Engineering Project SQEP "as-designed" and "as-constructed" drawing originals. This will be done by May 15, 1987.
In addition, to address the concern of the illegibility of drawings within the Division of Nuclear Engineering (DNE), attached is a copy of SCRGENER18602 which addresses this item.
Finally, to address the control and use of records and drawings within DNE on a continuin basis, the pro ram roup being established by ERIS see CATD No. 8050 -SON-02. Part 1 wil survey and audit and make I
r(ecommendations to ensure compliance with programs and procedures.
Y e
k
..s..
CATD. NO. 80503-SQN-05 At this time, with the information provided in NSRS Report I-86-185-SQN there is no specific procedural violation identified. However, the concerns raised are part of the overall problem of design change control at SQN. These problems are being addressed in programs and procedures and are currently being implemented to correct. In eld.ilve, t thi: tis, ti ::
f rertrel i-r: p::::dur-1 *=q"irr:et f;; SQ" ""! Cagia ::ir;; *::erh L or n.. 40. d.e.i e e_
ite.
s:=ix. Uoh o yh,. ho lly h.v.. su y, l
SON-6-002-005 & SON-6-002-006
(
Since the establishment of the Engineering Records and Control Services i
l section on site under the control of the Project Services Branch on site.
administrative controls have been placed on the ordering of washoffs for all Sequoyah related drawings.
In addition to the controls stated in the NSRS report I-86-185-SQN, the following controls have been implemented:
t
- 1) Only M-5's are technical supervisors in design sections are allowed to l
, sign out drawings.
- 2) In order to obtain a washof f or ESP for any drawing, the ERCS section has developed a form (See attachment A) which is required before issuance of a washof f.
A records is kept of this request on site, and with every request a check is made to prevent duplication of an earlier request. Each request must have adequate justification and must be signed by the Project Engineer or his designee.
DE01;LJ7044.01 SQEP Feb. 13, 1987
~.....
.~
ATTACHMENT M
. r; ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION
~
1.
Immediate Corrective Action Required: /}/ Yes // No 2.
Stop Work Recommended
/~/ Yes /X/ No 3.
CATD No.
80503-SQN-07 4.
INITIATION DATE 11/18/86 5.
RESPONSIBLE ORGANIZATION: SON Site Director 6.
PROBLEM DESCRIPTION:
/I] QR /;/ NQR NSRS report numbers I-83-13NPS, R-85-07NPS and I-86-129-SQN identified numerous deficiencies regarding QEB, OC, and Nuclear Powers control of QA records.
Documented evidence of the
[
deficiencies are not addressed on a tracking document such as a CAR for the implementation of corrective action.
Contrary to requirements established in NQAM, Part III, Section 7.2 paragraph 4.1.6 "The responsible supervisor shall enter the problem into the appropriate corective action system (e.g.,
// ATTACHMENTS 7.
PREPARED BY NAME G. A. Collins (./ 4, G//w DATE: 11/18/86 8.
CONCURRENCE: CEG-H R. K. Maxon 6#MM DATE: / /4/-Ph 9.
APPROVAL: ECTG PROGRAM MG2:
&//4iksewf DATE:
//-t/-66 CORRECTIVE ACTION 10.
PikOPOSEDCORRECTIVEACTIONPLAN: [cF Th 6 /6A Chol)
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR,f/ g 8 d / A DATE: /-7.p ",:P 12.
CONCURRENCE: CEG-Il
/" N?/4 ~
DATE: s/,s.,3/ep SRP DATE:
ECTG PROGRAM MGR DATE:
VERIFICATION AND CLOSE0UT I
l 13.
Approved corrective actions have been verified as satisfactorily implemented.
t
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SIGNATURE TITLE DATE
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February 10, 1987
Subject:
SEQUOYAH CONSTRUCTION RECORDS PROJECT Beca ese.of problems associated with the retrieval of Sequoyah construction records, a unifonn, computer-based construction records system for all plant systems and components is being established and will provide all levels of plant supervision and engineering personnel with immediate access to construc-tion infomation..This program will provide a satisfactory method of tracing
.4 an item or activity in a systematic manner.
To ensure usability, the records must be retrievable; and to enhance retriev-ability, the essential infonnation should be edited and indexed in a manner that is understandable. We currently have four people going through construc-( the process of going through each one of these records, we are marking the tion computer printouts of 207 systems and approximately 300,000 records.
In
?
film location on the printout, the fields to be indexed, and making any addi-tions and deletions where needed.
^
The construction records accountability program consisted of universal, equip-ment, instrument, cable and conduit, and welding. Fields that need to be indexed on these records are film access number, document title (i.e. weld, equipment, instrument, universal, cabel and conduit), document cross reference (i.e. drawing number), equipment I.D. code, unit, system, keywords (i.e. test number), and rpmarks. On the weld program, the welder symbol and heat numbers are being added to the printout for indexing.
In addition to the 287 microfilmed rolls of inspection and test records, there are 326 rolls of construction contracts, 85 boxes of contracts and 26 boxes of field purchase orders / shipping tickets that are in the process of being filmed and indexed.
The attached chart shows the schedule of items and activities.. Total program completion is December 31, 1989.
e
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sp 11 AI-12 Page 16 E
Revision 25
+
i AIT rio mrr 1 TO:
D. C. Craven, QA Manager 3
FROM-(MichaelL.Scalf D,c u m e r Cd w.TR* A S o P 4. w s. &
3 DATE: - F:br= y 10, ;^p'
'r 56 -bR-g7-o(ooR -
sanaCri DIsCRE m cr 3 Pour no.
I.
References:
tenunvah-CATD Flament Ranrert AntinttnN e-1-
DESCRIPTION OF DISCREPANCY:
Jhe project to index and microfilm SQN construction records is not documented
.by a tracking system in accordance with NQAM Part III Section 7.2 Paragraph 4.1.6.
v t,
N A. -
i REPORT TO
'.. {C l' MS Tn u isr ;f m _ n e ' - ^ S trd $::tfa-ara.
CN t/ /= DA (Data) in writing d verbally N A l
~
Ismediate corrective action taken (if any):
~
.,,. See.. attached
~
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. Repo by M/
t Tit e Sunv. Doc CntrlDate 7 /10/A7' h :,.
I N
E Reviewed by MCTAV4 A.I Title QA Manager Date
~
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. C,'.
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Response by responsible supervisor and QA followup is X
is not.
f E,
required. If not regttired, mark the remainder of this form "N/A".
Initial response due date:
~
l The following corrective action has been will be taken:
4 e
Estimated Completion Date Resp. Supv.
Date
.~
Corrective action has been completed.
Verified By t
~
QA Representative Date I
Closed By I
QA Manager Date l
'0131A/ala
~ ~ ' -
CATD. NO. 80507-SQN-07 Deficiencies related to QEB records that are outlined in NSRS report I-83-13NPS were caused by the absence of an effective system for reviewing, indening, filing, and retrieving the records. QEB issued NCE No.
GENQIB8401 in response to the NSES findings. The corrective action for this condition was to develop an effective system to handle QEB records.
i The system was implemented and the NCR closed on August 28, 1984.
1 l
In a follow-up investigation, NSRS report R-85-07-NPS, it was found that although a records handling system had been implemented, QEB had no schedule for processing the backlog of SQN records.
QEB them esordinated with the responsible managers at SQN an acceptable completion date (June 30,1986) for processing the SQN QEB records. The next follow-up investigation, NSRS report I-86-129-SQW, found that "... work is steadily progressing toward the resolution of the remaining open items identified by NSRS." Subsequently, processing of the QEB records for SQN was completion on June 30, 1986.
j Although the original NSES findings also apply to WBN and BLN, the QEB f
recordh for tihese plants are not required to be completed until 6 months v.r.,%,-
j after commercial operation of the la'st unit of each plant.
t I
l Corrective action concerning the handling and procersing of the site construction recortda vill be tracked by the intiation of Discrepancy Report (DR) SQ-DR-87-0601 (attached).
l j
DE01;LJ7044.01 i
SQEP Feb. 13, 1987 i
4 m...
.-.~ m
r m
f-ATTACHMENT N ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION 1.
Immediate Corrective Action Required:
/_/ Yes /[/ No
~
2.
Stop Work Recommended: /;/ Yes /I/ No 3.
CATD No.
80503-SQN-06 4.
INITIATION DATE 11/18/86 5.
RESPONSIBLE ORGANIZATION: SON Site Director 6.
PROBLEM DESCRIPTION:
/I_/ QR /;/ NQR Completion of Significant Condition Report (SCR) SQN SQP 8604 Revision 0 is required.
Provide completion date and actions to to be taken to preclude recurrence of the conditions noted in the SCR.
I
// ATTACHMENTS 7.
PREPARED BY: NAME G. A. Collins (14. (V/a DATE: 11/18/86 8.
CONCURRENCE: CEG-H R. K. Maxon '7@/7k14 DATE: //-2./--Wp 9.
APPROVAL: ECTG 1ROGRAM MGR (f/4:2weef 4 DATE: //'//14
?.
CORRECTIVE ACTION p
10.
PROPOSED CORRECTIVE ACTION PLAN: N"2F'fNFA r7/C N 6b () Y N
1
/
E E
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I T
E E
I E
F E
R
/ /W E
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E AJ L
I E
/
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E
/
/
I W
/
%J f
/ / ATTACHMENTS 11.
M POSED BY D
TOR /MOR: ###d'/A DATE: /- :P-# ")
12.
CONCURRENC - CEG-H DATE:
DATE:
ECTG GRAM MGR:
DATE:
_ VERIFICATION AND CLOSEOUT 13.
Approved corr e actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
,