ML20082J912

Rev 14 to Operational QA Manual

ML20082J912
Person / Time
Site:	Callaway
Issue date:	08/31/1991
From:	UNION ELECTRIC CO.
To:
Shared Package
ML20082J874	List: ML20082J870 ML20082J912
References
NUDOCS 9108290074
Download: ML20082J912 (7)

Text

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4 OQAM I 5.4 The approval, issue and control of implementing procedures, manaals and policy shall be prescribed in Administrative Procedures consistent with the requirements of Sections 2, 5 and 6.

I 5.5 Administrative Procedures shall be reviewed by the Quality Assurance Department as described in Section 2.6, item 3.

l 5.6 Maintenance and modification procedures shall be reviewed in accordance with Section 6.2.

I 5.7 Special process procedures supplied by outside organizations shall be reviewed in accordance with Section 9.4.

I I 5.8 In addition to the procedures identified in Table 13.5-1 of the Callaway-SA FSAR (CALLAWAY PLANT ADMINISTRATIVE PROCEDURES), the OQAP includes procedural coverage in the following areas: design control; design change control; preparation, review, approval, and revision of specifications, drawings, requisitiona, Engineering Service Agree-ments, contracts and procedures (instructions); QA indoctrination and training; auditor training; supplier evaluations; receipt and transfer of records; document control; quality program audits; corrective action; inspection; inspection, test and operating status; and special processes.

5.9 Applicable procedures shall be reviewed and revised as necessary as described in Appendix A, Regulatory Guide 1.33 (ANSI N18.7-1976, Section 5.2.15).

5-2 Rev. 14 8/91 o108290074 910822 PDR ADOCK 0500o483 L p PDR l

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.OQAM i

s 2337 15.0 NONCONFORMING MATERIAL, PARTS, OR COMPONENTS f f

1848 15.1 Material nonconformances include material deficien- I 1870 cies (including-inoperative and malfunctioning j

' 1907 structures, systems, and components). . Material j

- 12045 nonconformances identified under the UE OOAP shall. '

2112 be~ controlled to prevent the inadvertent- use of j material, parts, or components which are defective  !

or of indeterminate quality and to identify dccumen- l tation inadequacies. Measures shall be established t regarding identification, documentation, status  !

control, disposition, and notification of affected i organizations.  !

1848 15.2 Under the UE 00AP, Nonconforming Material Peports j 1903 (NMRs) ,. nonconformance logs, or other administrative j 1907 controls shall be employed to identify and control i 2334 nonconformances. Nonconformance logs may ue em- l ployed to control deficiencies of a minor nature or i to control documentation deficiencir . both of which  !

can be cor ected by bringing the deficiency into j compliance w1_th the original requirements. Material }

1885 nonconformances shall be controlled, as appropriate, t by documentation, tagging, marking,- logging, or  !

physical segregation. The programs describing the (

t administrative nonconformance controls shall delin-eate.the methods of identifying corrective action to i be taken for a nonconforming item or series _ of _!

nonconforming items. Until suitable documentary [

evidence is available to show the equipment or l material is in conformance, affected systems shall be considered inoperable and reliance shall not be placed on such systems to fulfill their intended  ;

safety function.  :

i 11906 Plant and other UE organization's procedures shall '

15.3 prescribe measures for the control and disposition ',

of- UE purchased items and services identified by  ;

outside organizations as nonconforming. Procurement 3558 documents shall specify those nonconformances to be ,

3576 submitted to UE for approval of the_ recommended l 3598 disposition. As specified in procurement documents, ,

3599 actions ~taken in response to these nonconformances 3600 shall be documented and forwarded to UE along with the hardware and accompanying quality verification documentation. Nuclear Engineering shall be respon- l sible for assuring the processing of supplier-recom- l mended dispositions for Plant-initiated procure- i ments. Similarly, other UE or outside organizations shall approve or be requested to provide a technical  :

evaluation regarding supplier-recommended disposi- j tions of nonconformances regarding procurements they ,

initiate.

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• OQAM APPENDIX A REGULATORY GUIDE 1.33 (cont.)

With regard to Section 4.5 of ANSI N18.7 -

1976 titled Audit Procram: The UE audit program shall be implemented in accordance with and to meet the requirements of Regulatory Guide 1.144 (ANSI N45.2.12) as endorsed in this Appendix, the OQAM, and the Callaway Plant Technical Specifications.

With regard to Section 5.1 of ANSI N18.7 - 1976 titled Procram Rgscrintion: The fourth sentence in this Section requires a " sum-mary document." UE's OQAM is organized in accordance with the 18 criteria of 10 CFR 50, Appendix B. UE interprets this OQAM and applicable Regulatory Guides as endorsed in this Appendix to fulfill the requirements for a " summary document."

With regard to Section 5.2.2 of ANSI F18.7 - 1976 titled Proced-ure 1.dherenc.g: The temporary change requirements of this Section are delineated in the Technical Specifications for activities occurring after the Operating License (OL) is issued; the requir-ements of the Callaway Plant Technical Specifications shall be used to control temporary changes.

With respect to Section 5.2.6 of ANSI N18.7 - 1976 titled Eauin-ment Control: UE shall comply with the " independent verification" requirements based on the definition of this phrase as given under our commitment to Regulatory Guide 1.74 in this Appendix.

Since UE sometimes uses descriptive names to designate equipment, the sixth paragraph, second sentence is replaced with: " Suitable means include identification numbers or other descriptions which are traceable to recoros of the status of inspections and tests."

The first sentence in the seventh paragraph shall be met after clarifying " operating personnel" to mean trained employees assigned to, or under the control of, Plant management at Calla-way.

With regard to Section 5.2.7 of ANSI N18.7 - 1976 titled Mainte-nance and Modification: UE shall interpret the word " original" in the first sentence of this Section to modify ONLY the words

" design bases." This interpretation is to assure that original inspection requirements are not imposed, without appropriate review, on modifications or maintenance activities which are similar in nature to original construction activities. In devel-oping means to assure the quality of maintenance or modification activity, inspection requirements from associated construction activities shall be considered. Operational inspection require-ments shall assure quality at least equivalent to the original quality.

I I A-8 Rev. 14 8/91

. OQAM.

APPENDIX A REGULATORY GUIDE 1.33 (cont.)

Where changes are made to the technical or quality requirements on procurement documents, they shall be subject to an equivalent l level of review and approval as the original document by the j i originating organization.

With regard to Section 5.2.15 of ANSI N18.7-1976 titled Review.

Accroval and Control of Procedures; in lieu of the wording starting with the second sentence in the third paragraph of this section beginning with "The frequency of ..., " through the end of the fourth paragraph, which ends "... a procedure review.", UE provides the following alternative guidance: " procedures shall be revised as necessary. These revisions will generally be initiated I through reviews conducted by knowledgeable personnel during I routine performance of activities. Examples of such reviews i include evaluations of problems encountered during performance of  !

a procedure, evaluation of corrective actions for self-identified  ;

deficiencies or events, evaluation of events occurring at other plants, evaluation of procedure changes necessary to implement modifications, evaluation of procedure changes necessary to implement License, Technical Specification, FSAR or OQAM revi-sions as well as evaluations of changes necessary to resolve Regulatory Issues. Such changes shall be implemented as neces-sary. In some situations such implementation will be completed prior to completion of the in-process activity. Guidance on the need tc revise procedures shall be provided in plant administra-tive-controls."

With regard to Section 5.2.17 of ANSI N18.7 - 1976 titled Insoec-tion: The third paragraph is replaced with the following:

Inspections for modifications and nonroutine maintenance shall be conducted as indicated in our reference to Section 5.2.7 of this standard.

The following is a clarification to the sixth paragraph:

Inspections may not require generation of a separate inspection report. Inspection requirements may be integrated into approp-riate procedures or other documents with the procedure or- docu-ment serving as the record. However, records of inspections shall be identifiab 2 and retrievable.

With regard to Section 5.2.18 of ANSI N18.7 - 1976 titled Control of Special Processes: UE shall comply with the following sentence l in lieu of the last sentence of the referenced Section.

For special processes not covered by existing codes or standards, or where item quality requirements exceed L the requirements of established codes or standards, l personnel, equipment and procedure qualification shall be defined by engineering.

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Attachment 3 Page 4 of 6'

8. When procedure changes are in order but immediate revision is not required,-the department responsible for revising the procedure tracks such changes until they are implemented.

9. The plant reference tracking system also provides a procedure cross reference database. This system provides responsible departments with a notice to review their procedures for possible revisions when a referenced procedure or document has changed.

This change will support a more effective allocation of plant resources. Rather than review procedures which are used infrequently, or which are not likely to be used in the near term, simply to satisfy a two-year review cycle, plant )

1 resources can be more focused on supporting planned '

activities and addressing current problems.

l Section 5.9 fold)

This specific section is no longer necessary as we have revised our interpretation of ANSI N18.7, Section 5.2.15, which was the source of OQAM, Section 5.9. As indicated in the justification to the change in OQAM, Section 5.3 events, which include accidents, unexpected transients, operator errors or equipment malfunctions are evaluated through our corrective action program to identify necessary procedure changes. (Appendix A, Reg. Guide 1.33)

[7] Transfer analysis and trending of NMRs associated with installed equipment to Nuclear Engineering.

Transferring a portion of NMR trending more clearly defines organization responsibilities in identifying and analyzing trends and places responsibility and authority for such trending in a more appropriate portion of our organization.

(Section 15.10)

[8] Clarify corrective action trending internal to UE as separate from external organizations.

This clarification is required due to the implementation of a consolidated corrective action program for Callaway Plant, which necessitated development of a separate supplier correct'ive action program. The semiannual periodicity was established in the OQAM during initial license development.

It was not our intent.to trend supplier related conditions l adverse to quality semiannually. Suppliers are audited triennially, or more often as needed. In addition, annual i

evaluations of suppliers are performed which include review l

of audits performed as well as supplier performance reported in other Nuclear Division programs for identifying and controlling adverse conditions (e.g., SOSs and NMRs) which

. Attachment 3 Page 5 of 6 are described.in OQAM, Section 18.12. This documented esaluation serves as a trend analysis of individual suppliers. UE believes this periodicity is appropriate and since it was our original intent, this is simply an OQAM clarification, and.does not represent a lossening of the original quality program. (Sec11on 16.1)

[9] Revise wording per NRC request, dated 09/07/90.

(Section 16.5)

(10) Clarify Manager, QA, and NSRB responsibilities for assessing audit planning, audit results, and program effectiveness.

The Manager, QA monitors the audit program on a continuous basis to assure audits are effective, meet requirements, and provide appropriate coverage. He does this through review and approval of quarterly audit schedules, attendance at audit moetings, involvement in selected audit finding issues, and review of audit reports. This is considered a clarification to existing commitments. (Section 18.6)

[11) Change endorsenent of Reg. Guide 1.8 to Rev. 2 for Shift Supervisor, Operating Supervisor, Reactor Operator, and Shift Technical Advisor.

This brings training and qualification of licensed operators in line with current requirements. (Appendix A, Reg.

Guide 1.3)

[12] Clarify an existing interpretation for QC inspection and frequencies.

QC inspections and frequencies are defined in the OQCM or procedures as described in our commitment to Reg. Guide 1.33 (ANSI N18.7-1976, Section 5.2.17). This change only clarifies an existing interpretation and does not reduce existing commitments for QC involvement in maintenance or modification activities. QC inspections, including frequency and type, are determined en an activity basis by Enginecring and Quality Control personnel. Once determined, the inspections are documented in an Operating Quality Control Manual (OQCM) which is used by job planners or procedure writers to define hold and witness points applicable to an activity. Initially, the inspections defined in the OQCM were established by_considering the type and frequency of inspections used in construction procedures and specifications. Review of the current inspection j effectiveness is continual and includes consideration of new ~

industry techniques, manufacturer's recommendations, plant

! and equipment performance, as wall as actual inspection j results. As such, inspections may not necessarily duplicate l those performed during construction. Changes to the OQCM '

inspections are authorized by Engineering and Quality

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- . Attachment 3 Page 6 of 6 Control personnel. This program implements the guidance in l ANSI N18.7 and ensures quality at least equivalent to the original construction (Appendix A, Reg. Guide 3.33)

[13) Delete clarification to ANSI N45.2.2-1972, Section 6.6.

Clarification no longer needed. (Appendix A, Reg.

Guide 1.38)

[14) Removed first line supervisors from organization charts (except those identified in the OQAM, Section 1.0). This is justified per guidance in NUREG-0800, Section 17.2; and Reg.

Guide 1.33 (ANSI N18.7-1976, Section 3.2) which only requires lines of authority, responsibility, and communication be established from the highest managewant level through intermediate levels for those organizational 1 units assigned safety related activities. (Figures B and C)  !

[15] Commitment Tracking System (CTS) number (number in left margin) changes, additions, or relocations. This is an internal tracking system for UE commitments and has no impact on the stated commitments. (Sections 2.10, 9.2, 10.10, 10.11, 10.12, 10.14, 11.2, 11.8, 12.2, 12.3, 13.1, 13.2, 13.6, 13.9, 16.1, 17.4, 18.0, 18.2, 18.4)

Pages with no revision bars have text moved to another page due to use of new word processing software. No changes have been made to the text.

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