ML24212A344
| ML24212A344 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/25/2024 |
| From: | Portland General Electric Co, Trojan Independent Spent Fuel Storage Facility |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML24212A342 | List: |
| References | |
| Download: ML24212A344 (1) | |
Text
Trojan Independent Spent Fuel Storage In stallation Quality Assurance Program
IMA performed for a specific or general issue of concern at any time, separate from the required 24-month periodic assessments.
1.3 Additional PGE Senior Management Oversight
The ISFSI Manager and QA Manager report to the Corporate Execu tive Responsible for Trojan.
However, one or more temporary or permanent senior management posi tions may be appointed between the ISFSI Manager and/or the QA Mana ger and the Corporate Executive Responsible for Trojan to provide additional management over sight as circumstances demand. In this case, the Corporate Executive Responsible for Trojan re tains the responsibility as the highest-level PGE responsible manager for the impl ementation of this QA Program.
1.4 ISFSI Organization
1.4.1 ISFSI Manager
The ISFSI Manager reports to the Corporate Execu tive Responsible for Troj an and is responsible for the day-to-day implementation of the QA Pr ogram. Reporting to the ISFSI Manager are the ISFSI Staff line organizations th at implement the tasks required to operate the ISFSI in a safe, secure, and efficient manner.
1.4.2 ISFSI Staff
The ISFSI Staff reports to the ISFSI Manager. Responsibilitie s, qualifications, and training required for ISFSI staff personne l performing ITS activities are detailed in the Trojan ISFSI FSAR and associated implementing procedures. ISFSI Staff personnel sh all not be used to perform audits of ISFSI ITS ac tivities as provided for under th is program. Appendix A provides the Trojan ISFSI functional organi zation chart depicting the groups th at comprise the ISFSI staff.
1.4.3 QA Manager
The QA Manager reports to the Corporate Executiv e Responsible for Trojan and is responsible for independent oversight of the implementa tion of the Trojan ISFSI QA Program. The QA Manager also has an indirect reporting responsibi lity to the ISFSI Manager for ensuring efficient day-to-day implementation of the QA Program by the line organization. If disagreements are identified that cannot be resolved between th e QA Manager and the ISFSI Manager, then these are referred to the Corporate Executive Responsible for Trojan for resolution.
Although the QA Manager reports indi rectly to the ISFSI Manager in the context of day-to-day ISFSI operations, the QA Manager does not exec ute line organization work. Rather, the QA Manager acts in an advisory capacity to others in the line organization to ensure compliance with this QA Program. In the oversight role, th e QA Manager is responsible for implementing independent QA functions including, but not limited to, quality control (QC) inspections, surveillances, audits, and advising the Corporate Executive Responsible for Trojan on the scope of IMA assessments. In the oversight role, th e QA Manager has the authority, direct access to responsible levels of management, organizationa l freedom, and access to work to perform these
PGE-8010 Page 9 of 36 Proposed Revision 31 Trojan Independent Spent Fuel Storage In stallation Quality Assurance Program
duties, including independence from cost and sc hedule considerations when opposed to safety function considerations.
The position of the QA Manager shall meet the following minimum qualification requirements:
- a. Graduate of a four-year accredited colle ge or university, a working knowledge gained through training and work experience of regulatory requirements, codes, standards and guidance documents that typi cally form the basis for a nuclear quality assurance program and its implemen tation plus five (5) or more years in positions of leadership, such as lead engineer, project engineer, quality engineer, audit team leader, etc.
AND
- b. At least two years of leadership experie nce should be associated with nuclear quality assurance activities, and at least one year of this experience shall be in a quality assurance organization. An add itional two years of quality assurance program implementation may be substitute d for the one-year experience within a quality assurance organization.
1.5 Corporate Executives Responsible for Support Organizations
Corporate executives with respons ibility for nuclear support activities shall assure that their assigned managers implement the QA Program, as applicable. Managers of nuclear support organizations that implement elements of th e QA Program, such as records management and procurement services, are responsible for ensuring that procedures that implement the applicable portions of the QA Program are establis hed, implemented, and maintained.
At least biennially, the PGE cor porate managers of nuclear suppo rt organizations shall review and document the status and adequacy of the pa rts of the QA Program they are executing and submit it to the ISFSI Manager, QA Manager, an d Corporate Executive Responsible for Trojan.
1.6 Delegation of Work
PGE retains and exercises the responsibility for the scope and implementation of this QA Program. Positions identified in this QA Program ma y delegate all or part of the activities of planning, establishing, and implementing the prog ram for which they are responsible to others, but retain the responsib ility for compliance with program requirements . Decisions affecting safety are made at the level a ppropriate based upon their nature and effect, with technical advice or review as appropriate.
The responsibility for im plementing certain elements of th e QA Program may be delegated to other organizations duly qualified to perform such activities. However, the ultimate responsibility for compliance with, and effective implementation of the requirements of this QA Program in those areas remains with PGE via the acceptance process for procured items and services.
PGE-8010 Page 10 of 36 Proposed Revision 31