ML20215K110

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Rev 2 to Qa/Qc Review Team Project Procedure CPP-017, Preparation of Qa/Qc Program Deviation Repts
ML20215K110
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/13/1986
From: Zill R
EVALUATION RESEARCH CORP.
To:
Shared Package
ML20215J430 List: ... further results
References
CPP-017, CPP-17, NUDOCS 8610270372
Download: ML20215K110 (9)


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EVALUATION RESEARCH CORPORATION C0 CRO W SCOPY CONTROL N0._ acalf COMANCHE PEAK RESPONSE TEAM PROJECT PROCEDURE FOR QA/QC ISSUE-SPECIFIC ACTION PLANS PROCEDURE NO: CPP-017 REVISION: 2 ISSUE DATE: 08/13/86 i

PREPARATION OF QA/QC PROCRAM DEVIATION REPORTS Prepared by: Date: /M h Approved by: . Date:

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Approved by: N Date: h /> 86

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QAMCReviewTeamLpader O

8610270372 861010 PDR ADOCK 05000445 A PDR

CPP-017

'i Rsvision: 2 1.0 PURPOSE This procedure establishes the methods to prepare, review, approve, distribute, and control reports concerning any deviations in the Comanche Peak Steam Electric Station (CPSES) QA/QC Program.

Furthermore, it establishes measures to ensure QA/QC program deviations are transmitted to the Texas Utilities Company (TUGCO)

, for further evaluation in accordance with Reference 3.1.

2.0 APPLICABILITY This procedure is applicable to QA/QC Review Team personnel implementing Issue-Specific Action Plans (ISAPs).

3.0 REFERENCES

3.1 CP-QP-16. (Later), "CPRT Evaluation and Reinspection Program."

3.2 CPSES Final Safety Analysis Report (FSAR) 3.3 CPP-010, " Preparation of Deviation Reports."

3.4 CPP-011. " Evaluations of Adverse Trend Analysis, Construction Deficiencies, and QA/QC Program Deficiencies."

4.0 GENERAL Cognizant QA/QC Review Team personnel document any apparent failures in the QA/QC program to meet regulatory requirements,

! e.g., Reference 3.2, or other licensing commitments. Consequently reviews are conducted to verify that a failure in the QA/QC program

exists and to determine if verified failures are QA/QC program deficiencies. The QA/QC Review Team Leader (RTL) approves in

, determinations regarding QA/QC program deficiencies and ensures that any other appropriate actions, due to the nature of the PDR, are effectively accomplished. Approved PDRs are transmitted to TUGC0 for further disposition in accordance with Reference 3.1.

4.1 Responsibilities 4.1.1 QA/QC Review Team Personnel f Cognizant QA/QC Review Team personnel initiate reports

of apparent failures in the QA/QC program in accordance with this procedure.

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CPP-017 Rsvision: 2 4.1.2 External Source Issues Deputy Program Manager The External Source Issues Deputy Program Manager reviews and approves reports which document an apparent failure in the QA/QC program.

4.1.3 QA/QC Review Team Leader The RTL ensures that reports approved by the External Source Issues Deputy Program Manager are verified and that those determined to be QA/QC program deviations are evaluated further to determine if the reported condition constitutes a QA/QC program deficiency.

The RTL ensures that the impact of each QA/QC program deviation is considered with respect to the quality of construction.

4.1.4 QA/QC Records Administrator The QA/QC Records Administrator distributes and- .

controls reports of QA/QC program deviations and QA/QC program deficiencies.

4.2 Policy Activities performed under this procedure shall conform to the policies contained in the latest CPRT Program Plan, ERC Management Program Plan, and applicable ISAPs.

Where an activity is designated as the responsibility of the External Source Issues Deputy Program Manager, or higher, it may be delegated by that individual to an individual under his or her supervision.

4.3 Conflicts P

In the case of a conflict between this procedure and the documents referenced in Section 4.2, the latter shall govern.

4.4 Definitions 4.4.1 QA/QC Program Deviation A verified failure of the QA/QC program to meet regulatory requirements, (e.g. ,10CFR50, Appendix B), l FSAR commitments, or other licensing commitments.

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CPP-017 Rsvision: 2 4.4.2 QA/QC Program Deficiency Any identified QA/QC program deviation meeting one or  !

more of the following criteria:

Inadequacy of a QA/QC program element such that substantive revision of the program or other corrective action is required to bring it into compliance with the regulatory requirements, FSAR commitments or other licensing connitments, or Extensive evaluation would be required to determine the effect on the quality of construction.

5.0 PROCEDURE ,

l 5.1 Initiation I I

Cognizant QA/QC Review Team personnel identifying an apparent QA/QC program deviation, shall initiate a QA/QC Program Deviation Report (PDR) in accordance with Attachment 6.2.

Upon the completion of a PDR, the preparer signs and dates the O report, then forwards it to the External Source Issues Deputy Program Manager for review and approval.

5.2 Review and Approval Reviews are conducted by responsible personnel to ensure that the report is logical, to verify the apparent failure, to determine whether the discrepancy constitutes a QA/QC program deficiency, and to evaluate its affect on the quality of construction.

5.2.1 External Source Issues Deputy Program Manager The External Source Issues Deputy Program Manager reviews the report to ensure that it is logical and to confirm that the reported condition constitutes a QA/QC program deviation. Moreover, the Deputy Program Manager ensures that specific reference to the appropriate criterion is denoted. Accordingly, the Deputy Program Manager checks the block on the form marked "YES," then signs and dates it.

Should the Deputy Program Manager disagree with the originator's assessment of the finding, he or she checks the block marked "NO" and provides reasonable O justification in the " REMARKS" portion of the form, then obtains the concurrence of the originator.

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CPP-017 Ravision: 2 Should the originator maintain that the finding does O differ from the specified criterion, he or she checks the block on the form marked "PENDING," then signs and dates it.

As required, the Deputy Program Manager determines any impact the QA/QC program deviation may have on the quality of construction. That is, due to its nature, the QA/QC program deviation may implicate the adequacy of the installed hardware. The Deputy Program Manager documents the results of the reviews and includes information relative to appropriate actions (e.g.,

initiate a Deviation Report in accordance with Reference 3.3), the individual (s) assigned responsibility, schedules, etc. The report is also marked to indicate when there is no effect.

NOTE: Reviews may be documented in conference notes referenced on the PDR.

Upon the completion of reviews in accordance with this ,

section, the Deputy Program Manager sends PDRs:

l Determined to be erroneous and which indicates the originator's agreement to the QA/QC Records Administrator for control.

Determined to be accurate to the RTL.

Which indicate the originator's disagreement to the RTL.

( 5.2.2 QA/QC Review Team Leader Upon receint from the External Source Issues Deputy Program Manager, the RTL conducts a review to verify the apparent QA/QC program deviation and, as required, to determine whether the reported condition is a QA/QC program deficiency.

Should the review confirm that the QA/QC. program is adequate, the RTL checks the blocks marked "NO" and records reasonable justification on the form which supports the conclusion, then signs and dates it.

Should the review confirm that the QA/QC program is inadequate, the RTL checks the appropriate block.

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CPP-017 Ravision: 2 Finally, the RTL determines whether the QA/QC program I O' deviation constitutes a QA/QC program deficiency. That is, the reported condition will require extensive

)

corrective action to comply with applicable requirements and/or extensive evaluation to determine )

its effect on the quality of construction. The RTL checks the appropriate blocks, then enters any appropriate remarks.

QA/QC program deficiencies are evaluated further by the QA/QC Review Team in accordance with Reference 3.4.

Upon the completion of reviews in accordance with this section, the RTL signs and dates the PDR, then forwards it to the QA/QC Records Administrator for distribution and control.

5.3 Distribution and Control The QA/QC Records Administrator documents the completed PDRs on uniquely numbered transmittals which include provisions for the CPSES QC Coordinator to acknowledge receipt. In addition, the QA/QC Records Administrator maintains records to ensure that the CPSES QC l Coordinator is in receipt of all deviations / deficiencies, e.g., a file of transmittals Os forwarded to and received from the CPSES QC Coordinator.

Copies are distributed to the:

Originator External Source Issues Deputy Program Manager QA/QC Interface Coordinator QA/QC Collective Evaluation Supervisor ,

The QA/QC Records Administrator forwards copies of reports which confirm that the QA/QC program is adequate to the originator and the External Source Issues Deputy Program Manager.

The QA/QC Records Administrator maintains the file of PDRs (marked (KKK-7F]).

4 6.0 ATTACHMENTS 6.1 QA/QC Program Deviation Report Flow Diagram.

4 6.2 QA/QC Program Deviation Report (Semple and Instruction).

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Attachmznt 6.1 CPP-017 Revision: 2 Page 1 of 1 QA/QC PROGRAM DEVIATION REPORT FLOW DIAGRAM EXTERNAL SOURCE ISSUES QA/0C PROGRAM DEV14T!09 REPORT DEPUTY PROGRAM MGR II POR MARKED j go ITUTE ENO (INCL'JDES , A DEV!ATION JUSTIFICATION) T YES 1I II POR MARKED ORIGINATOR EYES Y V QA/QC CONCUR YES T

NO

% REVIEW TEAM LEADER V v v v POR MARKED l POR WITH PENDING DETERMI NO

$1GNATURE VERIFIED TO BE A CONCURRENCE EV1ATI YES V

y rJR MARKED EXTERNAL SOURCE mVES

!$5CES DEPUTY PROGRAM MGR #

3I VES QC P NO 010 gn DEFICIENCY ygg T ORIGINATOR CONCUR-T i

1r 1P POR WITHOUT R MARKED POR WITH POR MARKED SIGNATURE NO

$!GNATURE CONCURRENCE AS REr)UIRED CONCURRENCE

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QA/QC O  % RECORDS ADMINISTRATOR i

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Attschmsnt 6.2 CPP-017 Revision: 2 s

Page 1 of 2 5

QA/0C PROGRAM DEVIATION REPORT COMANCRE PEAK RESPONSE TEAN QA/QC PROGRAM DEVIATION REPORT NUMBIA ORIGINATOR DATE (1) (2) (2)

REQu1 REM m (3)

DEVIATION (4)

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( [ ] YES

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DOES Tut ur0RTED C0pDin0N CONSnTUTE A QA/QC PROGRAM DMAn0NT

[ ] NO [ ] P DDING ,

REMARKS:

EETERNAL SOURCE ISSUES DATE ORIG 15ATOR DATE DEPUTY PROGRAM MANAGER 15 InE REPORTED CONDm0N:

1) A' m m ID PAILU M OF T E CPSES QA/QC PROGRAMT [ ] TES [ ] E0
2) A QA/QC PROGRAPt DEFICIENCYT [ ] TES [ ] NO REA505: (C B CE ONE OR SOTE VRIN TEERE IS A QA/0C PROGRAN DEFICI D CT)

[] Will REQUIRE EETWSITE CORRECTITE ACTION TO 00NLY WITE REQUIREMENIS

[] v111 REQUIH EITUSIVE EVALCAn05 TO DETERNIH TEE EFFECT ON THE QUALM OF CONSTRUCTION RDIARES:

QA/QC REVIEW TEAM LEADER DATE CPF-017.1, Revision 1 0

3 Attachm2nt 6.2 CPP-017 Revision: 2

  1. l INSTRUCTIONS TO COMPLETE

- /. FORM CPP-017.1 "QA/QC PROGRAM DEVIATION REPORT Originators initiate QA/QC Program Deviation Reports by entering:

(1) The unique report number obtained from the QA/QC Records Administrator. For example:

QA/QC PDR 1, Unique Number, e.g., 1, 2, 3, etc.

--QA/QC Program Deviation Report Prefix (2) Signature as originator and date.

(3) The applicable FSAR/ licensing commitment. l (4) The description of the condition which deviates from the referenced criterion.

Upon its completion, the originator forwards the PDR to the External O Source Issues Deputy Program Manager for review in accordance with Section 5.2.

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