ML20155B950

Interim Change I88-1 to Rev 11 to QA Program Plan for Facility

ML20155B950
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/03/1988
From:	PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20155B948	List: ML20155B943 ML20155B950
References
NUDOCS 8806140030
Download: ML20155B950 (25)

Text

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3gg g Conditions adverse to quality, noted during QA department audits and sur.

2nt.Chg. veillances, which directly affect plant activities, are reported to the plant 187-2 General Manager for his action. Those which do not directly affect plant activities are reported to appropriate management of the activity audited for their action.

The QA department perforos selected audits, surveillances, and reviews to verify that quality related items are designed, specified, fabricated, shipped, stored. installed, inspected, and tested, and services related thereto are in accordance with applicable codes, specifications, and procedures. QA Department personnel are authorized access to Company records and personnel in the conduct of this responsibility.

Disputes involving quality-related activities, occurring due to a difference of opinion between the QA Departcent and other departments or branches and which remain unresolved, may be brought to the attention of higher canagement for resolution.

1.2.2.1.2.1 Oualitv Assurance Manarer The QA Hanager reports directly to the Vice President, Nuclear, and is responsible for preparing the initial QA Program and subsequent revisions and recoacending approval to the Vice President, Nucl ear. The QA Hanager has the authority and independence to identify quality problems: initiate, recommend.

or provide solutions to quality problems through designated channels; and verify implementation of solutions to quality probleos. The QA Hanager directs Item 1, the Quality Operations Branch, the Quality Support Services Branch, and Int. Chg. the Quality Inspection Branch 185-1 thw QA Cyerations-Branch, the QA Engineering and Support Branch, the Assistant to the QA Haneger,-end the -Quality 4-ontrol Group in the implementation of the overall QA Prograc, including contractor QA involvement.

1.2.2.1.2.2 Ouality Assurance Ooerations Branch Manager (QOBM)

The Quality Assurance Operations Branch Manager (QAC .",[has r:; an;EbE14 ties which-1nclude che following: directs the Quality Audit Group and the bbterial i Quality Group in the accomplishment of the following responsibilities: l Interic Change 187-2 and 1881 to l 1-3c Revision il l

1 I

8806140030 880603 PDR ADOCK 05000344 P nnn i

Idem.2,

. 'IM. Chg.

187-2 . .

a. A::: ft: th: Q.' Manage- in hi: ab::ne: :n Q.' ==tt::: ::n ::ning T*T cp ::t!=nr.

Item 1, a.

Int.Chg. b. Coordinates and schedules the activities of QAEs'and QA/QC Specialists in 188-1 the Branch, and consultants conducting audits, survelliances, or reviews of

. and offsite the TNP operations; onsite dipport organizations; and contractors, suppliers, vendors, and service organizations.

b. reports of

b. Reviews and approvesdits , survelliances, and reviews :cpert: of T'T Quality

t!:! tic: perforced by the dperations Branch, including audit findings and Stop Work Orders prior to issue, 1::uts and-:: ch all :nsit: Non:an!= :ing A:tivity Repc::: (NC.'R ) nd :::he :nd t rend: 21] V=ne :tfor=:r: ^ ep^rt :

'NCE:) issued :: T:c,jer

c. Reviews the QA Program and procedures and evaluates the quali:y and technical qualifications of contractors, suppliers, and service organizations required to support the Trojan Nuclear Plant.

d. :ce! der QA eng!r^erir; support to-the TNp ot her department e : :d _

ccetractors by conducting Q? c ! :ections; by ree! ming design charger :nd

=cdificatione, pe:1!! cation:, 2nd purchase requ!:! tion:; :nd by advicing c: qual!t :::haesr-preeedure:, and ::& iqu::

d. Maintains and contro1r the naluated Contractor and Supplier List for quality-related procurement.

l Quality Support Services

e. Interfaces with the Q? Engi. :::ing :nd Supp :t _ Branch Manager, and the Inspection Branch Manager Quality Cent:c! Supe.:!cc: to provide unifora implementation of the QA ,

Prograc and coordination of curveill:ne::, audit: :nd support functions.

Interic Change 187 2 and 188-1 to 13d Revision il a

Item* 2, Int.Chg.

'

• 187-2 '

f. Acts as a cumber of the PRB.

g. Assists in the development and naintenance of the PGE QA Program and QA Departcent Procedures.

A

h. Verifies that QA activities at the plant are perforced in compliance with the QA Program through surveillances, audits, and reviews.

1. , Interfaces with the NRC Regional *0ffice plant operations inspectors during onsite visits.

,j. Recommends procedural changes, if necessary, when deficiencies are detected Item 1, l .

through audits, surveillances, inpsections, or other ceans.

In t . Chn . ' k . Reviews and concurs with all quality-related purchase requisitions and material /

188 l services requests and conducts quality-related material receipt inspections.

I Support Services 1.2.2.1.2.3 Ouelity ' :- = :: En;i :crin: and ';u:- .. Branch Manarer I

Support Services (OSSBSD The Quality Aesurance-Engireer-ing--end Support Branch ? tanager (4AE-6BM+-has serves as the Assistant QA Manager, acting for the QA bbnager in his absence on

, QA matters, and directs the @ alit the ualit

) i c,m,1baicies under--thia P =g::y Systems . = hic!'Groug=,

inel u- the g=11=y Support Group,

=5

! and the Quality following Achievement Program Coordinator in the accomplishment of the responsibilities:

i

.  :::: Ec: : ': Q 4:nage in-hi ab::n:: cn Q =c::::: it,vc1v:ng aff+++e-4 activitics.

+a. QA/0CSpecialist,

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in the Branch.

Coordinates and schedules the activities of/QAEs and consultants ::niu: ing

~ '! 2 surveillances, or r-tLenr c! c!!

it: cuppc:: c:gani:::icns.

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c ,.

r et ieus QA Progr?m 2nd precedures c! c!! site centracters , supp!!-re. 2.a

-ser"!:^ c gari:::!c : : quired :: :uppc:: th: :cjan :;uclea ?! -

l l d. Evalue :: :h: quali:y and :ethn! cal quali!i ::1on c! cont-rec:ct:, tupp!!er:.

2nd sc ~!ce organizations; ret ! :: cv' app:=c: :!!:!te p :p ::A

qualit -related purchere requicit! ne; cci

:cinc :nd cont:c!: the Ev:!ue::d Cc-t:: 'c: and Supp!! - Lic: Ec Quali:: P-lat:d ":::: ::-::::.

Interic Change 187 2 and 188 to 13e Revision il

Iten;2,.

Int.'Chg.

187-2 Nuclear Division and

. ReviewsandconcurswichbfaitePG: departmental -@+ procedures Item 1, Int.Chg. which implement QA Program requirements 138-1 end coordinates interfacing procedures between departments.

c. Issues and tracks all Nonconfoming Activity Reports (NCARs) and Nonconformance Reports (NCRs) to completion.

!. P:vi cu : and approv : audit, curve 1Manemnd rev!:t- repor+e-of--of-fw+

cupp^rt crganint-Lons-performed. by the Eng!r: ? ring and Supp^rt Er:nch, including audit findk;5: and Stcp ver' Order: pr!ct to 12:ve; :nd !: ue and trech: 211 o!!:1te en cricrc!ng Actlvit; *:p^rt: ??? R )

d. Reviews NCRs for quality trerds and reports on the results of reviews.

e. Develops and maintains the PGE QA Program and QA Department Procedures.

5  ::1::: in the d::: lope:,t and maint:n n:c :f-ect GA Pr:graz;, qA=

Dep:::=ent Proc-edurs: , a nd--Meens-ing-Decu= e n t : .

f. Develops QA training programs, coodinates training, and maintains training records.

g. Quality Operations Branch Manager and the Quality Inspection gag g if. Interfaces with the%QA954 to provide uniform implementation of the QA Prograc and coordination of surv:111 rce: and :udit: -f support org2r!':*12.- functions.  ;

h.

/. Provides QA engineering support to ef!:it: cupport departments and 1 l

1 contractors perforcing activities for the TKP by conducting QA orientations; by reviewing significant design changes and codifications procedures, and specifications; and by adv1 sing on quality cethods.

procedures, and techniques.

i 73 3Ii7I IO I : ^ 3 C _2 : " l l  !

The A

:1:::nt to tF: QA Hanager d:vtlops and zaintain5 the PC: QA Progra and Q? D: pert =:nt-Preeedure:; ensun>-thet-Nm4eer Divi:icn qualit progr == :nd procedures ceet FCE Q? Program requirerente: nd devel^p Q? .:!ning p:^3rs==.

Interic Change 187 2 and 188 2 to 1 aa Revision il

I, tem 2, '

-Intn C%g. -

187-2 g 1.2.2.1.2.4- Quality In,spection Branch Manager  ;

1.2.2.1.2.5 cueIuv-4onen1 s=.-Aeor-Item 1, .

.i Int. Gg, Inspection Branch Manager I 188-1 The Qur'ity Cwauol L +cciwr provides QC/NDE coverage of construction, maintenance, and codification activicles; condttets-eaterial-receipt  ;

Mpecs-lons, and develops, caintains, and approves QC/NDE procedures and guidelines for observations of in process work.

lt 1.2.2.1.2.5 1.2.2-14.4 Oualification Recuirements for Nuclear Oualitv Assurance ,

Devartment Personnel t The QA Department Hanagement and Staff cust be knowledgeable of the QA Prograc and 10 CFR 50,- Appendix B, and maintain up tc date knowledge of applicable  ;

regulatory guides, codes, and standards related to quality assurance.

e Fbnager t QA Departcent L.ag:r.:= per waael must meet all of the following qualifications: '

l a. Graduate of a four-year accredited engineering or science college or  ;

university.

b. Eight years' experience in power plant engineering, construction, or h operatLons; four years of this experience in the field of QA, or  :

l equivalent number of years of nuclear plant experience in a supervisory l

l position, or a combination of the two; at least one year of this four i years' experience shall be nuclear power plant experience in the l

icplecentation of the quality assurance program.

lQADepartment Staff QA Engineers cust meet or exceed the following

!qualificalion requirements:

I  ?

a.

Graduate of a four year accredited engineering or .vcience college or univer sity with four year's experience in FOver plant engineering, l construction, or operations; two years of this expea ience in QA or l quality control; one year of this experience in nuclear power plant QA

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program implementation; or .

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Interam Change 187 2 and 188 1 to  ;

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0 I l-19 5ggg Revision 11

Item 1, Igb*,

Quality Support Services Yncse onsite s &mitted to the G Q w a;::a2 Bmnch for review huality-related procedures arefevi+wed-by-the-QA8BM to ensure require-I ments of the QA Program are met.

I8

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Procedures which describe activities that interface with offsite groups IS7-J are submitted to the of f site groups for review.

2.2.2.3 Support Oroanizations' Ouality-Related Procedures Offsite PGE support organizations' quality-related procedures are prepared, reviewed, approved, issued, and cor. trolled by the originating organiza-Item 1' tion and provide details for im Int.Chg. ta ion tv of he upport QA Pr ervices hese F nacer Ie:-1 procedures are submitted to the vA ",chscr and to interfacing organha-tions for review to assure compliance with the requirements of the QA Prog ram. The support organizations include:

a

, Nuc-lear-Quality-Anurante Depar-taeM-t Int.

ISS-;

V.

Purchasing & Materials Management Department;

b. c'. Nuclear Plant Engineering Department; i

l i c. d. Fuel Operations Department;

d. e. Oregon Analytical Laboratory Department;

4 e. f'. Environmental Sciences Department; l'

.f. (. Corporate Records Department; i

g. b',

Nuclear Safety & Regulation Department;

h. t'. Corporate Security Department.

2-4 Revision 11

l In addition, the Nuclear Safety & Regulation Department is responsible for I the preparation, issuance, and control of Nuclear Division Procedures.

Nuclear Division Procedures are concurred with by the QA Manager and approved by the Vice President, Nuclear. Nuclear Division Procedures are l used to control selected activities of Nuclear Division and other support organizations.

Department procedures may supplement Nuclear Division Procedures, but shall comply with them.

Audits by the 0A Department provide assurance of compliance with applicable departmental and division procedures.

2.2.3 Ouality Assurance Program of Contractors. Suppliers, and Service Orcanizations The PGE 0A Program imposes applicable quality assurance requirements based on 10 CFR 50, Appendix 8, and other recognized QA standards for requiring contractors, suppliers, and service organizations to maintain and use adequate quality assurance programs.

2.2.3.1 Onsite Contractors'. Suppliers' and Service Organizatiens' Program Evaluation Ite:n 1 In Chi (Q3M)

The Quality -Assur;r,cc Operations Brar.ch Manager (QA00") is responsible for assuring that quality assurance programs of contractors. suppliers, and service organizations performing onsite quality-related activities have been evaluated by the QA Department or approved consultants for acceptance l

when required by procurement documents.

The originator is responsible for requesting the QA Department to perform QA program evaluations of organi-zations considered for contracting through onsite-prepared procurement documents.

l l

e 2-5 Revision 11 1

4 2.2.3.2 Contractors'. Suppliers', and Service Oroanizations' Program Item 1,,

lut.Chg. Evaluation Offsite 186-1 Operations Branch N nager (QOBM)

The Quality 4::ur:nce Engineering and Support Sr:nch ":n:gcr 'OAESS") is responsible for assuring that the quality assurance programs of contrac-tors, suppliers, and service organizations who provide quality-related material, parts, components, and services are evaluated for acceptance, when required by the procurement documents. For procurement dor,uments which they initiate, PGE of fsite support organizations are responsible for requesting QA program evaluations of such organizations considered for cont ra c ting .

The QA Department reviews and concurs with offsite-prepared quality-related procurement documents and Quality Plans for Acceptance of Items or Services. Informational copies of all quality-related purchase orders and local purchase order forms are sent to the QA Department.

2.2.4 Indoctrination. Orientation, and Trainino New employees whose duties and responsibilities are related to quality-related activities participate in quality assurance indoctrination and/or training programs. In addition, it is the responsibility of the employee's supervisor to arrange for quality assurance orientation sessions and the additional training necessary to maintain proficiency in the QA Progr3m requirements.

2.2.4.1 Indoctrination and Orientation of Plant Staff The plant General Manager has responsibility for plant staff indoctrina-tion and orientation regarding the QA Program and applicable implementing procedures, instructions, and changes.

Attendante of the plant staff at orientation and indtctrination sessions is documented.

The plant General Manager is responsible for assuring that the record of attendance for the plant staff is maintained.

t j

2-6 Revision 11

Nuclear' Plant Engineering Department. Copies of each list are issued in a

( controlled manner by Nuclear Plant Engineering. All revisions to the lists are reviewed, approved, and issued in the same manner as the original.

2.3 PLANT MODIFICATIONS 2.3.1 General When any design work or installation activities associated with a modifi-cation to an operating plant are to be performed by a PGE organization, the work or activities shall be performed in accordance with this QA Program.

2.3.2 Design PGE design activities for plant modifications are performed in accordance with Chapter 3.0 of the QA Program as modified by the applicable equipment appendices.

2.3.3 Installation The installation or construction of a modification is performed in accor-dance with approved PGE procedures or by a contractor working to an approved QA Program and procedures which have been reviewed and accepted by PGE or its designee. These procedures include the necessary limits and tolerances on material, equipment, processes, procedures, and sequences. I

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Tb2y also include the qualitative and quantitative acceptance criteria for 4 determining that the important operations have been satisfactorily accom-plished.

The procedures also identify applicable inspection points.

I em 1, When the installation is delegated by the plant General Manager to d con-Int.Chg .

tractor not performing work under the plant procedures, the contractor's Ib 'I procedures are reviewed and approved by the responsible supervisor and the QA00". Quality Operations Branch Manager.

2-9 Revision 11

order. The requisition package may include a special Quality plan for '

Acceptance of Items or Services-(QPA) for any procurement with special receipt inspection, source verification, post-installation testing, or storage / handling requirements.

I 1

Changes to the MSp are reviewed and approved through the same procurement process as the original. '

(QON0 Item 1, The Quality Assurance Operations Branch Manager 'Q/.00.".) or his designated Int'Ch

• 1 188 1 alternate reviews and approves all quality-related -or. cit: pnp; red MSRs'to assure that quality requirements have been adequately specified. Supple-ments to prs which change OOBM only the commercial aspects do not need QA00M QOBM approval, and the 4pMM44 approval of a MSR related to a SPRR is considered to be approval of subsequent reorders if no quality or technical require-ments are changed. The items listed below shall be considered during this  !

! review, and the applicable items shall be included on the MSR, or its attachments: i l

a. A detailed description of, or reference to3 the specific 1 i

technice.1 and quality requirements to which the item or services are to be manufactured or procured;

b. A listing of all quality documentatier. cequired to be i l

submitted to purchaser cr retained by the supplier, l

c. Quality assurance program requirenents and 10 CFR 21 applicability; i

NOTE: Local purchase orders cannot be used in circumstances where 10 CFR 21 ir applicable.

d. Shop inspection and quality control requirements; i

l l

l l

4-2 Revision 11 1

where the quality assurance and technical requirements of an installed safety-related item cannot be determined Nuclear Plant Engineering approves the evaluations performed to establish the requirements and controls necessary to assure appropriate quality and performance. These evaluations shall assure that interfaces, interchangeability, safety, fit, and function are not adversely affected or contrary to applicable regula-ltoryorcoderequirements. The results of these evaluations shall be documented.

When it is necessary to procure or utilize a replacement or spare part '

which is technically different than the original, a Spare Parts Equivalency Evaluation Report is completed to document the method for assuring equiva-1ency. If the evaluation determines that the item is not equivalent to the original, the replacement must be handled as a Request for Design Change (RDC) or a Plant Configuration Change (PCC) in accordance with Chapter 3.0.

4.2.3 Prtparation of Purchase Orders / Contracts Approved prs and SPRRs are submitted to the P&MM Department for procure-ment. Local purchase order book renewal requests and term purchase order renewal requests are submitted to the P&MM Department for reauthorization, renegotiation, or cancellation.

The P&MM Department issues purchase orders / contracts in accordance with the

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information contained in the approved PR, SPRR, or term purchase order '

renewal request. The P&MM Department is not authorized to change the technical or quality requirements of the initial procurement documents ,

Item 1, without approval from the orig tgr. The originator may only change

.'M s i Int.Chg. quality require.nents with the QAOBM's approval. The P&MM Department shall i 165-1 '

l discuss changes in commercial terms with the Action Party if these changes may have any effect on technical or quality requirements.

Copies of purchase orders and changes thereto for all quality-related items and services are transmitted to the QA Department and the plant MCS.

4-4 Revision 11 i

I 1

e index to assure thap it is maintained up-to-date. Additionally, procedures are reviewed after design changes to the plant or unusual incidents (ie, accidents, unexpected transients, significant operator errors, or equipment nelfunctions).

Lower tier procedures or instructions prescribing quality-related activi-ties are approved by the responsible supervisor and distributed in a controlled manner.

Deviations may be made if the basic intent of the lower tier procedure or instruction is not altered and a method has been established to control the documentation, approval, and distribution.

_6.2.2 Document Control Procram Onsite 6.2.2.1 PGE Plant Oroanizations

\

The plant Of fice Supervisor has responsibility for the distribution to '

appropriate assigned copy holders of documents, changes, and revisions which are originated at the plant. ,

In addition, the assigned copy holder i or the plant Of fice Supervisor assures that all changes and revisions are entered into controlled documents and that the superseded documents are l destroyed or marked either "Void" or 'S!serseded" if retained in the controlled documents.

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D, . --

J procedurce and chinistrative policies rc::c:rai G The c

Plant Operating Manual (POM)&ical %A-r+v46-by-the-+1ect--Revtewstart c' *n:

c 15 T-! eci he

(.,,+cnPRS}-and.i.:apppOVed-by,Tm'an Te~N-plant.-Generak-Mandgee::icne

. a!TW . (T pricr to i-:e~entat n ac set fcr*h in TTE C. E. 3.

Item 1 All POM orders, instructions, procedures, and tests preshribino quality Int.Ch'. 3 related activit Support ervicts ISS-1 Manager -(gggggg)ies are reviewed by the Quality A:surance Optrat4 ens-ym S"y or designee prior to issuance to assure that appropriatey l

!.pecified quality assurante requirements are in compliance with the provisions of the OA Program.

Changes to the POM are reviewed, approved, controlled, and distributed in the same manner as the original issues.

Deviations to the POM which do not 6-2 Revision 11

change the incent of the approved documents are controlled in.accordance with the Technical Specifications. In accordance with the requirements of 10 CFR 50.59(b), a written safety evaluation of a change to a procedure as described in the Updated FSAR, which provides the basis for the deter-mination that the change does not involve an unreviewed safety question, shal2 be prepared prior to implementation of the change.

Each plant supervicor responsible for a volume of the Plant Operating Manual performs periodic reviews of the volume for technical content and ,

adequacy.

At least annually, the plant Office Supervisor verifies that controlled copies onsite of the Plant Operating Manual contain only the effective resisions of procedures.

Item 1, 6.2.2.2 OA Department Int.Chg.

185-1 4

6.2.3 Document Control Program Offsite 6.2.3.1 PCE Support Organizations For PCE support organizations, the Nuclear Safety & Regulation Department (NSRD) is responsible for issuing topical reports and other licensing documents (except for certain special licensing topicals such as this QA Program and the Trojan Security Program), the Trojan Operating License, and Nuclear Division Procedares to assigned copy holders as controlled docu-ments. NSRD transmits instructions for entering changes into controlled documents and requests that superseded documents be destroyed or marked either "Void" or "Superseded" if retained. The QA Department is responsi-ble for issuing the QA Program and the Evaluated Contractor . .d Supplier List for Quality-Related Procurements, including changes. FlF: corporate Security Department is responsible for issuing the Trojan Security Plan (including the Security Force Training and Qualification Plan) and its l changes. Other quality-related documents are controlled and distributed internally by individual PGE support organizations.  ;

6-3 Revision 11 i

can be temporarily implemented following PGE review, approval, and documentation of the change.

The support organization requiring a contractor to perform quality-related activities may request the assistance of the QA Department in reviewing and evaluating the contractor's procedures and instructions for adequacy and compliance with quality assurance requirements. Instructions and procedures Item 1, cove ggg quality-related activities to be performed onsite shall be sent to Int. Q . lthe9AseMforreview.

Ice-1 6.2.4 PGE Drawint.s Nuclear Plant Engineering and Trojan Plant Engineering are responsible for the review of drawings prepared by PGE to ascertain that the drawings accurately reflect the configuration of the plant or modification desired and that the appropriate quality assurance requirements are specified in compliance with the provisions of the QA Program.

Comments by reviewers of drawings prepared by PGE are resolved by Nuclear Plant Engineering. The Action Party or requisition originator is lresponsibleforrequestingreviewsbyNuclearPlantEngineeringorTrojan Plant Engineering of drawings submitted by contractors and for resolving comments with the contractors. The Branch Ma1 agers of Nuclear Plant Engineering (also known as Discipline Chiefs) or their designees shall approve these drawings prior to use.

Corporate Records is responsible for the distribution of all drawings and '

I aperture cards. Nuclear Plant Engineering is responsible for the approval of new vendor / contractor drawings and their entry into the drawing control system. Distribution of drawings and aperture cards is based on a Nuclear Plant Engineering control list of individuals /organloations requiring drawings or aperture cards.

6-5 Revision 11

. ~

requirements of the procurement docunents have been met and any applicable special Quality Plan for Acceptance of Items or Services (QPA) is followed.

Item 1, Prior to receipt of lity-related items, any onsite-prepared special QPA Int Chg, is reviewed by the 4M444& or designee for inclusion of appropriate quality ISS-1 requirements. Results of the receipt inspection are documented by the inspector on the special QPA, purchase order, or specified attachments. <

Individuals performing material receipt inspections are qualified in accordance with ANSI N45.2.6.

The purchase order package and any documents which may have arrived with or prior to the shipment p.re examined to ensure that all documents required upon receipt have been received. This includes review of supplier diserapancies dispositioned "repair" or "use-as-is" to assure Nuclear Plant Engineering concurrence is documented.

Accepted items are appropriately marked, removed from the inspection area, and located in a controlled storage area or issued for use.

Nonconforming material, equipment, and components are held in a segre-gated area, where possible, and are identified and handled in accordance with Chapter 15.0 of this QA Program.

Copies of the completed purchase order / contract, any special QPA, and the required documentation received are filed in the plant file in accordance with the requirements of Chapter 17.0 of this QA Program.

7.3.3 Surveillance of Onsite-Procured Services from Contractor and Service Orr.anizations When services for quality-related items are purchased from contractor or j

service organizations, the QA Department assures that approved procedures and qualified personnel and equipment are used during the performance of l these services at the plant. Activities are selected by the QA Department i

7-4 Revision 11

l 7.4.3 Receipt Inspection l

Unless acceptance will be solely in accordance with routine practices and procedures for quality-related items, and except for new fuel, Item 1, QPAs are prepared for quality-related items procured offsite. The gogy Int.Chg. QPAs are reviewed by the yASCSM or designee for inclusion of 188-1 appropriate quality documentation requirements.

For quality-related items to be received onsite, the approved copies l of the QPAs are sent to the plant MCS along with the procurement documents. Receipt inspection is performed in accordance with Section 7.3.2 of this QA Program. For new fuel, receipt inspections are performed using the applicable onsite fuel handling procedures.

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14.0 INSPECTION, TEST, AND OPERATING STATUS 14.1 PURPOSE This chapter provides measures for the identification of the inspection, test, and operating status of quality-related items throughout receipt.

Installation, and operation of the nuclear power plant to preclude bypass-ing of requirements and inadvertent operation.

14.2 GENERAL Procedures are established to indicate, by the use of suitable means, the status of inspections and tests performed on individual items. These pro-cedures provide for identification of items which have passed required inspections and tests where necessary to preclude inadvertent bypassing of such inspections and tests.

14.3 INSPECTION. TEST AND OPERATING STATUS PROGRAM ONSITE 14.3.1 Inspection and Test Status The plant Operations Supervisor, TPE Branch Manager, Plant Modifications Item 1 Inspec t InL'Ch6! ' Engineering Bbnazer Supervisor, Maintenance Supervisor, and the Quality Ce.Jrs, ion Branch ISS-1 Eu;;F>irer are respontible for assuring that necessary inspections or tests are conducted in their areas of responsibility and that the status of these inspections or tests is complete or current.

The cognizant Shift Supervisor is responsible for maintaining sufficient knowledge of tests or inspections in progress to control the overall plant operation.

Personnel performing tests or inspections affecting plant operations keep the Shif t Supervisor or Control Room Operator advised of the current status of tests or inspections in progress.

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15.2.3 Nonconformance Report A Nonconformance Report is required for quality-related items which do not conform to the specified requirements under one or more of the following circumstances:

a. When physical deficiencies (other than documentation) are Item 5, detected at receipt inspection; Int. 0.g. b. See botton of this page, piecse.

187-2

$ When deficiencies are found and the deficient condition is not being reworked at PGE using a MR; d

c .' When deficiencies are dispositioned as "repair", "use as is",

or "reject";

e.

d. When the identification or documentation required for trace-ability of an item is lost or illegible.

An NCR is originated by personnel aware of the above circumstances to document nonconforming material, equipment, or parts. The NCR identifies the noncenforming item, describes the nonconformance, the disposition of the nonconformance, the inspection requirements, and the recommended corrective action by the responsible supervisor.

NCRs are evaluated to determine if an unreviewed safety question exists in accordance with 10 CFR 50.59, or to determine if significant condi- i i

I tions adverse to quality exist in accordance with 10 CFR 50, Appendix B, or if def ects resulting in substantial safety hazards exist in accordance Int.Chr. with 10 CFR 21. Procedures governing these evaluations are identified in Ib1 NDPs.

"y.,: :," 4 T- Quality Support Services Branch q' ' _ iprocessed throu h the G. :.;;;ti:= :: .:' j to Pa-c.02C, a ,

Rev. 11  : 2 <tng sys:cm to r::ns; tor tr.evf- NCRs are/sent to-thp-Qual ty-GentMT Group which maintains an i y g C-5444cs 1cs 4c-.tnd disposition, approval, and corrective action yn g , p',, b.

Vr.en do y entation deficiencies are detected at receipt inspec:icn an yg 7_ g -

zt se deetred to reacive and snetall the item prior to rexirt of require: ,

cos:c:entation; l

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Int. Q g.

185-1 Quality Support Services !sranch-pgy, e. . m . . ....

.. p . g 66-8 Ferfermanes-Henisering-and-Tw .,e-Anatyeie

• • - M - Hie sfollow-up.

RJ9,44- TAe-QueMty Centr &l+ ,e semiannually reviews NCRs for quality yten g, trends. Results of the reviews are fr rwcrded to the plant General Manager, Int. Chg. the QA Manager, and the Trojan Nuclear Operations Board.

187-2 Nuclear Plant Engineering has the responsibility to review NCR dispositions and to recomend approval of appropriate corrective action including pos-sible design changes.

E Disagreements regarding the NCR disposition are reported to the plant General Manager who has the responsibility for resolution. In all cases, the items of disagreement and resolution shall be documented on or attached to the NCR.

"Use as is" or "repair" dispositions require the review and approval of the Manager of Nuclear Plant Engineering.

The disposition and corrective action are approved by the plant General Manager.

. Item 1, support Services Branch bbnager Int.Qg. Quality Control Hold Tagy associated with an NCR are removed only when ISS-1 authorized by Quality wentiel S werviser or designated members of the Quality C;ntrol C oup. Support Services Branch.

QA personnel may suspend any safety-related activity, with the exception of reactor startup or power generation, which is not being accomplished in accordance with specified requirements or will result in a nonconformance.

Nonconf ormances which appear to warrant suspending reactor startup or power generation are reported to the QA Manager and to the plant General Manager f or imediate resolution.

15.2.4 Evaluatino and Reporting af 10 CFR El Defects Def ects in quality-related items are documented and controlled in accord-l ante with a NDP. Any employee who has reason to suspect the existence of a '

15-4 Revision 11  ;

16.0 NONCONFORMING ACTIVITIES AND CORRECTIVE ACTION 16.1 PURPOSE This chapter describes the corrective action measures applicable to non-conforming activities to assure that. conditions adverse to quality are identified, evaluated, and corrected and for those significant conditions adverse to quality, corrective action is taken to preclude repetition.

16.2 CORRECTIVE ACTION PROGRAM 16.2.1 General '

l 1

A Nuclear Division Procedure (NDP) governs the use of a Nonconforming Activity Report (NCAR) to assure that each nonconforming activity 3nd its

. cause is identified and corrected in a timely manner.

Nonconforming activilles can be identified through random observallons, reviews, inspections, or audit / surveillance activities. Any PGE employeo has the authority and responsibility to report a nonconforming activity to their manager or supervisor who will assure that the nonconforming activity is or has been documented on an NCAR unless it has been previously i documented in (1) a Licensee Event Report (LER), (2) an Abnormal In-House Event Report (ER), (3) a 10 CFR 21 Report, or (4) a 10 CFR 73.71 Report.

An NCAR is used to document the nonconforming activity, the corrective action, the reportab.8.lity evaluation, the approval of the actions taken for resolution, and ver.fication of corrective action.

Iten 1, Perfonnance $bnitorin / Events Analysis Branch Int.Chg. Annually, the 165ME prepares a trend evaluation of NCARs and transmits the results to the attention of responsible management, the Chairman of the Trojan Nuclear Operations Board, the Chairman of the Plant Review Board, and the Vice President, Nuclear, for review and assessment.

The QA Department may initiate suspension of any operation except reactor startup or power generation when a condition considered adverse to quality 16-1 Revision 11

has occurred or is developing. Nonconformances which appear to warrant suspending reactor startup or power generation are immediately brought to the attention of the plant General Manager for action.

Copies of NCARs which identify sir,nificant conditions adverse to quality ,

are distributed to members of-the Plant Review Board Trojan Nuclear Operations Board, and the Vico President, Nuclear, for information and review.

16.2.2 Corrective Action Associated With Nonconforminr Activity Reports All Nonconforming Activity Reports (NCARs) are processed and controlled by the Quality Assurance : D.W:Y[Onc. If the initiated NCAR require: cetica ISS-1 Of pl?nt OrgSni?2tione Or Onsite Support Or8enizat10n , it 10 ifenemi4 h 4-tc the Q? ^peratienc Eranch--f or-procesedng. If the in t-ieted NCAR require

" dquarter: Or OfSelt Oupper4-ertanizat!On cetien, it 10 tr:nonitted to the Q1 Engineering and Eup,oort Braneb fer-prce:::ing.

NQAD evaluates each NCAR for validity and will forward valid NCARs to the Item 1, responsible supervi r manager for corrective action and a determination a e ects Int.Ch,l" of the root cause/of the nonconf orming activity. NCARs determined to be Ice-1 6l invalid during the QA evaluation will be returned to the originator with an explanation regarding the determination.

The responsible supervisor or manager evaluates the nonconforming activity to determine if a significant condition adverse to quality exists cr if it is potentially reportable. Nonconforming activities determined to be significant conditions adverse to quality require corrective actions to be taken to preclude repetition. Responses to NCAR(s) are due by the date(s) specified on the NCAR(s).

The responsible supervisor or manager documents proposed corrective actions Int.Chg.

ISS-1 which include an identification of the root cause\on\the addNCAR eff*Ct9and submits 16-2 Revision 11

i l them to the plant General Manager or his designee or offsite manager, as It s 1, appropriate, for approval. Following approval of the corrective action.

Department Int.Q g. the NCAR is transmitted to the appropriate QA Org:r.i::tien for evaluation 188-1 of the proposed corrective action to determine if the action is adequate:to close the NCAR. (Unacceptable corrective action is documented and resub- ,

mitte6 to the responsible organization management for additional corrective action.) Inappropriate or incomplete corrective action may result in suspension of the associated operation or activity.

If corrective action cannot be completed as scheduled, the responsible Itea 1 supervisor or manager is required to provide the pprepriate QA crDepartment g r ni 158-1 ntica with a new completion date for corrective action.

Item 1, Department verifies Int.G g. The QA creeni : tion: 'ecrify implementation of the corrective action through IN~I reviews, audits, or surveillances.

Correction action determined by the QA Department to be ineffective or not accomplished in a timely manner shall be brought to the attention of the l Vice President, Nuclear, by the QA Manager.

16.2.3 Corrective Action Associated with Reportable Events Any PCE employec has the authority and responsibility to report a possible violation of the Trojan Nuclear Plant Technical Specifications or any of ]

the events defined in 10 CFR 50.72 or 10 CFR 50.73 to their manager or fsupervisorwhoassuresthatanAbnormalIn-HouseEventReportiscompleted I

and forwarded to the Plant Review Board (PRB) for review and evaluation. I unless immediate notification of the Nuclear Regulatory Commission is required per regulations. The results of PRB evaluations are documented in accordance with Plant Operating Manual procedures with a copy to the originator.

1 If it is determined to be a Reportable Event, a Licensee Event Report will s

be written and submitted to the Nuclear Regulatory Commission in accordance with regulatory requirements.

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e 18.0 AUDITS i

18.1 PURPOSE This chapter describes the audit program utilized to verify the implomenta-tion, adequacy, and effectiveness of the QA Program, f18.2 AUDIT / SURVEILLANCE / SURVEY PROGRAM 18.2.1 General The QA Department h2s overall responsibility for the scheduling and imple-mentation of the PGE QA Department external audits and surveys of contrac-tors, suppliers, and service organizations and PGE internal audits of the PCE support organizations and plant activities. In addition, the QA Department performs surveillances or reviews of selected quality-related activities to assure their performance in a specified manner.

Item 1, (QOBM)

Int.Chg.

- The Quality Assurance Operations Branch Manager (QAOBM) is responsible for 7gO~1 and offsite the conduct of PGE QA Department onsite' internal audits and surveillances to determine the adequacy and effectiveness of the QA Program and to verify adherence to license requirements and compliance with the POM. Pss-S&

Item 1, l Int.Chg. U^E2#'"^' ^If*ll^ !"t^""21 22dit Of PCE 22EF0rt ^TE**I 2!103 r; th; 163-1 rerpencibility Of the Quality Accurence Engin:: ring end support Br:n:h T.;r.:Ec r 'QAESS") .

)

18.2.2 Audit Personnel Members of the various PGE engineering and environmental disciplinas, Fuel Operations Department personnel, plant personnel, or an outside consultant may be utilized in the performance of audits and to provide expertise in the particular activity that is being audited. In all cases, audit team I personnel will be independent of the activities being audited. l l

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Program Deficiency:

Failure to develop, document, or implement effectively any applicable element of the QA Program required by contract or commitment.

May be referred to as a "deficiency" without reference to "program" in audit reports.

Programmatic Chsnre: A change which affects the QA Program.

Proof Test: A test of a completed system or component which verifies, under controlled conditions, whether specification requirements have been met.

Purchased Services: Purchased services are services procured by PGE to sup-port quality-related items. Examples include design, analysis, evaluations, reviews, audits, calibration, and data reduction.

0A Department: Nuclear Quality Assurance Department.

QA, E : Quality Assurance Engineer.

Iten 1, qqg , Qualhy4ssuranhM Mr.p Int.Og.

I88-1 pg g galigy u g g Se gices Br gch J n g I

I 00Nt: lity rations Branc bbnazer.

jO BM- Litf-Apsuranoe-Operayons-Branch-Menager.

QA Manater: Nuclear Quality Assurance Department Manager.

qAP: Quality Assurance Procedure - Plant.

Item 1, OIB'!: Qualit y Inspection Bnnch Mana:;er.

Int.0g.

' q;;:

i Quality control-supervisorr ISO-I . O-DeslRnated Purchase Requisitions: A purchase requisition which has the sym-

'bol "Q" placed in front of the purchase requisition number to indicate that the requisition and the items it requests are covered under the PGE QA Program and that department procedures and controls apply to the processing and handling of the purchase requisition and documents resulting therefrom.

0-Listed: "Q-listed items" is the designation given to those portions of I safety-related systems, structures, and components of a plant that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. The Q-list identifies those i systems, structures, and components which, based on the guidelines set forth  !

in Section 3.2 of the FSAR, have been determined to be safety-related. The Q-list enumerates safety-related systems, structures, and components to which {

j the QA Program applies. I lqM: Quality Plan for Acceptance of Items or Services.

1 Quality Assurance (OA): All those planned and systematic actions necessary to provide adequate confidence that an item or a facility will perfom satisfac- i torily in service.

G-9 Revision 11