ML20212L294
| ML20212L294 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/16/1986 |
| From: | Olmstead C, Schweitzer J, Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20212L243 | List: |
| References | |
| NDP-600-2, NUDOCS 8701290404 | |
| Download: ML20212L294 (9) | |
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NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 TITLE PAGE 1 OF 7 CONTROL OF NONCONFORNING ACTIVITIES ISSUE DATE
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, REVISION NO. 2
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Oriainator Date Menacar. QA Date
- VP. fear!==* Divl=1m/ ~ Sate EFFECTIVE 1-7/2 PAGES Attachment A/2 1.0 PURPOSE This procedure establishes measures to assure that each nonconforming activity I
will be adequately documented and evaluated for reportability, that corrective action responsibilities will be appropriately assigned, that corrective action responses will be approved by responsible management, and that corrective action implementation will be independently verified.
2.0 AEELICABILITY 2.1 This procedure applies to organizations and PGE employees identified in NDP 100-1. Attachment I.
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l 2.2 Nonconforming materials, parts, and components are identified and con-trolled in accordance with NDP 600-1.
j 3.0 DEFINITIONS 1
3.1 Nonconformina Activity - A quality-related activity that deviates from i
an approved procedure, instruction, or regulatory commitment, or is performed without a procedure.
3.2 Nonconformina Activity Resort - A report used to document a nonconform-ing activity, corrective action, reportability evaluations, approvals, and verification of corrective actions.
3.3 sinnificant Condition Adverse to cuality - A departure from specified requirements is considered to be a significant condition adverse to quality if the condition appears to be an event which:
(1) requires tsporting iri 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less in accordance with the Plant Operating License, 10 CFR 20, 20 CFR 50.72, or 10 CFR 73, (2) requires reporting in accordance with 10 CFR 21, or (3) involves a significant breakdown in the QA Program implementation.
4.0 REFERENCES
4.1 PGE-8010. " Nuclear Quality Assurance Program".
4.2 WDP 100-4, " Reporting Requirements".
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8701290404 870109 PDR ADOCK 05000344 P
PDR r
NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 ISSUE DATE May 16, 1986 REVISION NO. 2 PAGE 2 OF 7
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4.3 WDP 600-1, " Control of Nonconforming Material. Parts, and Components".
4.4 NDP 700-4, "10 CFR 21 Reporting of Nuclear Plant Defefets or Woncompliances".
4 4.5 WDP 100-11. " Protection of 3afeguards Information".
4.6 Trojan Operating License, NPF-1.
5.0 PROCEDURg3 1
5.1 CENERAL t
A.
A manager or supervisor who identifies or is informed of a noncon-forming activity is responsible for assuring that the nonconforming i
activity is, or has been, documented on an NCAR (Attachment A) unless it has been documented previously in a Licensee Event Report, i,
Abnormal In-House Event Report, a 10 CFR 21 Noncompliance Report, or a 10 CFR 73.71 Report. Minor deficiencies which are not reportable and do not affect ouality, safety, or negatively impact other groups 2
engaged in quality-related activities may be corrected as a management function without issuing NCARs.
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B.
Each nonconforming activity identified during an audit, surveil-lance, or review shall be documented on an NCAR. If corrective
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action for the nonconforming activity is completed and verified during the audit, surveillance or review, the NCAR form requires entries only by Quality Assurance.
C.
NCARs that involve safeguards information shall be processed in j
accordance with WDP 100-11.
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5.2 NCAR INITIATION A.
An NCAR may be initiated by any PCE employee and shall be approved by the employee's supervisor.
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B.
The initiator shall complete Items [2), [3), and [5), and may com-plate Item [4] of the NCAR form. If it appears that the nonconform-ing activity is a significant condition adverse to quality, or is potentially reportable, this information shall be included in Item [4] of the NCAR form.
C.
If the initiated NCAR requires Plant action, it shall be transmitted to the QA operations Branch located at Trojan for processing, unless the NCAR was initiated by the QA Engineering and Support Branch. If the initiated NCAR requires headquarters or support organization action or if it was initiated by QA Engineering and Support, it shall be transmitted to the QA Engineering and Support Branch for processing.
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NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 ISSUE DATE May 16, 1986 REVISION NO. 2 PAGE 3 OF 7
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5.3 QA EVALUATION
'e A.
UponreceiptoftheinitiatedNCAR,theQAEngine[ringandSupport or the QA Operations Branch shall evaluate the NCAR for validity, and, if valid, shall complete Items [11', [6), [7]. [8),jnd[9]of the NCAR form. This should be completed within fivs working days.
1.
If the stated nonconforming activity appears to,imeet the defini-tion of a "significant condition adverse to quality",sa Severity Level I shall be assigned in Item [7] of'the NCAR form'with an appropriate response due date (less than.30 calendar days).
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2.
If the stated nonconforming activity cloes net appear to meet the definition of a "significant condition adverse tq quality", a Severity Level II shall be assigned,in Item [7] of the NCAR form with a 30 calendar day (from the datei the NCAR is distributed) response due date.
B.
Initiated NCARs determined to be invalid during the QA evaluation shall be returned unsigned to the initiator with a cover memo explaining the determination.
5.4 NCAR ISSUING AND TRACKING A.
The QA Engineering and Support Branch shall-issue and track all-
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NCARs which are to be assigned to headquarters or offsite support organizations, including contractors or suppliers.
B.
The QA Operations Branch shall issue and track all NCARs which are to be assigned to plant organizations or onsite support organizations, including contes: tors or suppliers.
C.
Each QA branch shall maintain the status record for NCARs that it is required to track. Each shall issue NCAR numbers, track corrective action responses, verify corrective action implementation, and docu-ment NCAR closeouts. Each shall maintain a separate, unique number-ing system in which the designation for an NCAR shall consist'of the letter "H" (headquarters or support organizations) or "p" (plant),
the last two digits of the year in thich the NCAR is identified, a hyphen, and the sequential number of the appropriate log. Each NCAR number originated by the QA Engineering and Support Branch shall begin with an "H"; le, the first NCAR originated by the QA Engineer-ing and Support Branch in 1985 shall be designated as H85-1.
Each NCAR originated by the QA Operations Branch shall begin with a "p";
le, the first WCAR originated by the QA Operations Branch in 1985 i
shall be designated as p85-1.
For NCARs initiated by individuals i
outside NQAD, the re consible QA branch shall uniquely identify the I
WCAR by an "M" preceding the "H" or "p",
ie, NH85-1.
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NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 ISSUE DATE May 16, 1986 REVISION NO. 2 PAGE 4 OF 7 5.5 NCAR DISTRIBUTION C
After the QA evaluation, the valid (numbered) NCAR shall be distributed as follows:
A.
NCARs issued for Plant Action:
1.
Initiator.
2.
QA Operations Branch Manager, j
3.
Responsible Organization's Manager / Supervisor (for action)
(original).
4.
Plant General Manager.
5.
Manager, NQAD.
6.
Chairman of the Trojan Nuclear Operations Board.
7.
Chait1 nan of the Plant Review Board.
8.
Vice President, Nuclear.
B.
NCARs issued for Roadquarters or Support Orzanization Action:
1.
Initiator.
2.
QA Engineering and Support Branch Manager.
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Responsible Organization's Manager / Supervisor (for action)
(original).
4.
Plant General Manager.
5.
Chairman of the Trojan Nuclear Operations Board.
6.
Vice President, Nuclear.
5.6 CORRECTIVE ACTION RESPONSE A.
Upon receipt of the NCAR, the responsible supervisor shall evaluate the NCAR, complete Items (10] through (13) in accordance with the instructions on the back of the NCAR, and return the NCAR to the applicable QA branch by the response due date with a copy fur-l nished to the organization determined to be responsible for reporting the NCAR, if any.
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' % NUCLEAR DIVISION PROCEDURE NDP NO. 600-2
~1 ISSUE DATE May 16, 1986 REVISION NO. 2 PAGE 5 OF 7 1.
The probable root cause of the nonconformance shall be entered z
y in Item [10] of the NCAR form.
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5 2.
Results of the responsible supervisor's reportability evaluation shall be documented in Item [11] of the NCAR form, including l
identification of the organization responsible for reporting the NCAR, if any.
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3.
The corrective action response shall include action (s) taken or planned to be taken, including the estimated completion date(s)
I in Item [12] of the NCAR form.
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If the deficiency has been determined to be a "significant con-dition adverse to quality", the corrective action response shall include corrective action taken or planned to be taken to preclude repetition.
i B.
Upon receipt of an NCAR which appears to be invalid, the responsible supervisor shall return it unsigned to the applicable QA branch with l
the criteria fer determining it to be invalid, and with a copy furnished to the initiator.
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5.7 QA RESPONSE EVALUATION A.
Upon receipt of ar. NCAR with an approved corrective action response.
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the applicable QA branch shall evaluate the NCAR and corrective l
action response for adequacy. Any problems found during evaluation will be resolved with the responsible manager / supervisor who approved the corrective action, if possible. If resolution cannot i
be reached, the problem will be referred to the next higher level of management. If the response is accepted, Item [14] of the NCAR form shall be completed.
1.
Notify the responsible supervisor of the acceptance.
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2.
Update the NCAR Status Record.
B.
Upon return of an NCAR which appeared invalid to the responsible supervisor, it shall be reevaluated by the applicable QA Branch Manager and voided, jlf appropriate. If resolution cannot be reached, it shall be referr ed to the Vice president, Nuclear by the l
NQAD Manager.
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5.8 CORRECTIVE ACTION VERIFICATION A.
The applicable QA branch shall verify implementation of the corrective action by performance of reaudits, surveillances, or reviews, as appropriate.
1.
Verification shall be performed in a ti'ely manner such that m
NCARs are closed soon after the corrective action completion
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date (usually within 30 days).
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NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 ISSUE DATE May 16 1986 REVISION NO. 2 PAGE 6 OF 7 2.
Verification shall be documented in Items [15] and [16) of the NCAR form.
c B.
If corrective action has not been completed by the scheduled corrective action completion date, the applicable QA branch shall issue the responsible supervisor an overdue corrective action notice by documented telephone call or memo, and request the responsible supervisor to establish a new corrective action completion date with his management's approval. The new date shall be noted on the NCAR Status Record.
C.
When corrective action completion has been verified, the NCAR closure shall be documented in Item [17).
5.9 RECORDS A.
Copies of closed NCARs issued for Plant Action shall be sent to:
1.
Initiator.
2.
QA Operations Branch Manager.
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3.
Responsible Organization's Manager / Supervisor.
4.
Plant General Manager.
5.
Manager, NQAD.
6.
Chairman of the Trojan Nuclear Operations Board.
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7.
Chaiman of the Plant Review Board.
8.
Vice President Nuclear.
B.
Copies of closed NCARs issued for Headquarters or Support Organization Action shall be sent to:
1.
Initiator.
2.
QA Engineering and Support Branch Manager.
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Responsible Organization's Manager / Supervisor.
4.
Plant General Manager.
5.
Chairman of the Trojan Nuclear Operations Board.
6.
Vice President, Nuclear.
C.
The responsible QA branch shall process a c'opy of the completed NCAR for retention as a lifetime QA record.
NUCLEAR DIVISION PROCEDURE NDP NO. 600-2 ISSUE DATE REVISION NO.
'2 PAGE 7 OF 7 May 16, 1986 S.10 IDENTIFICATION OF TRENDS C
WQAD shall establish and maintain a method for analyzing and reporting BCAR trends. Annually, NQAD shall complete an evaluation of the NCARs for trends, prepare a trend report, and distribute a copy of it to each affected organization's manager, the Chairman of the Trojan Nuclear Operations Board, the Chairman of the Plant Review Board, and the Vice President, Nuclear.
6.0 ATTACHMENTS Attachment A, Nonconforming Activity Report.
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'NINCENFORMIN3 ACTIVITY REPHRT NUMBER NDP. 600-2, Rev. 2 Page 1 of 2 Subject (2
Requirement 3
Nonconformino Activity r
I N
I T
I A
4 Recommendations T
0 R
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initiator
/ Organization
/ Supervisor Date 6
Corres. No.
8 Responsible Supervisor
/ Organization Q
A 7
Severity Level Response Due Date 9
OA Supervision Approval Date
- 0 Root Cause D 10CFR20.403 D 10CFR50.36 O 10 CFR 50.73 010CFR73.71 O OTHER REPORTABluTY INITIATED UNDER D 10CFR21 D 10CFR50.72 010 CFR 7032 D TS H2 R S E
Reportable? O Yes O No O Uncertain Review Referred To:
f.U P
Correenve Acton-(RemedWHnveengenve/ Preclude Repetton)
E O
R N
y S
I Ig.S 0
.(L R
E 12 Scheduled Corrective Actions Completion Date 13 Approved by
/
/
RESPONSIBLE SUPERVISOp MANAGEMENT DATE 14 Response Evaluated and Accepted QA SUPERVISION DATE Q
15 Corrective Actions verified A
l NCAR CLOSURE 16 verified by
/
17 Approval
/
oATE OA SUPERvtSION DATE NOTE-See reverse for preparation instructions.
PGE 2278 (Apr tel j
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WP 600-2 Rev. 2 AttactmenkA Page 2 of 2 INSTRUCTIONS FOR COPPLETING NONCONFORRING ACTIVITY EPORT (NCAR)
.M INSTRUCTION c
[1] Designated personnel shall assign an identification niaber to the NCAR and a short descr tivesubject.
[2] Initiator shall enter the specific requirement which has been violated, including the paragraph number.
[3] Initiator r. hall describe the violation of the requirement.
[4] Initiator may suggest corrective actions, including potential reportability.
[5] Initiator shall enter his/her name, organization, and date and obtain supervisory approval.
[6] Designated QA personnel shall enter the audit, surveillance, or review correspondence number.
[7] Designated QA personnel shall enter the severity
- level and corresponding response due cate.
[8] Designated QA pe w nel shall enter the supervisor and organization responsible for resolving the problem.
[9] Responsible QA supervision shall review, and if in agreement that it is a nonconfonning) activity, shall approve, date, and initiate action to complete
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Itens [1], [6, [7], and [8] above.
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i TE RESPONSIBLE SUPERVISOR SHALL COMPLETE ITEMS [10] TO [13), OBTAIN MANAGEENT APPROVAL, AND RETlNIN TE ORIGINAL NCAR TO TE APPLICABLE QA ORGANIZATION BY TE RESPONSE DE DATE.
[10] The responsible supervisor shall enter the probable root cause of the i
nonconfonnance.
[11] The responsible supervisor shall enter what corrective action has been or will be taken to resolve the nonconforming activity, what action will be taken to preclude repetition (if a significant condition adverse to quality), and shall enter the results of the reportability evaluations.
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[12] The responsible supervisor shall enter the scheeled corrective actions completion date.
[13] The responsible swervisor shall sign and date and obtain management approval.
[14] The applicable QA supervision shall evaluate the adequacy of the response and shall sign and cate when acceptable, and assign an individual to verlfy the corrective actions.
[15] The assigned Individual shall verify the corrective actions taken and enter the results of investigation to close the NCAR.
[16] The assigned individual shall sign and date when verification 1s acceptable, k
[17] The appilcable QA supervision shall review sign, and date the NCAR to Indicate acceptability of resolution and verificatio,n, and closure of the NCAR.
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