IR 05000219/1988001
| ML20153B344 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/19/1988 |
| From: | Blumberg N, Dev M, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20153B336 | List: |
| References | |
| 50-219-88-01, 50-219-88-1, GL-82-12, NUDOCS 8803220076 | |
| Download: ML20153B344 (14) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-219/88-01 Docket No.
50-219 License No.
OPR-16 Licensee: GPU Nuclear Corporation p
P.O. Box 388 g
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Forked River, New Jersey Facility Name: Oyster Creek Generating Station
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Inspection At:
Forked River and Parsippany, New Jersey InspectionConf.ed-January A*,8,1988 Inspectors:
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[ I 6 Od M. Dev, PE, Reactor Engineer date
'/.... Cliveira, Reactor Engineer
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'd a te Arproved by:
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N. Blumberg, Chief Operati 1 Program date Section, OB, DRS Inspeccion Summary:
Routine, Unannounced inspection conducted on January 4-8, 1Q86 (Inspection Report ho. 50-219/88-01)
Areas Inspected:
Review of the Licensee's Actions on previously identified NRC concerns, Oys'.ar Creek Nuclear Generating Station (OCNGS) Offsite Review Committee (General Office Rev;ew Board - GORB), OCNGS Organization and liministration, QA Audits, cnd Audits Program Implementation.
a Results:
No violations or
,ations t a identified.
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DETAILS
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1.0 Persons Contacted 10yster Creek Nuclear Generating Station (0CNGS) -
General-Public Utilities Nuclear (GPUN) Corporati,on
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R. Brown, Manager,. Plant Operations K'.-Fickeissen, Manager, Nuclear Safety
- P, Fiedler, Director,.0CNGS
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- I. Finfrock, Jr., _Vice President (GPUN - Parsippany)
- M. Heller, Licensing Engineer D. Jerko, Licensing Engineer (GPUN --Parsippany)
- J. Kowalski, Licensing Manager M.- Laggart, Manager - BWR-Licensing (GPUN - Parsippany)
- D. MacFarlane, Site Audit Manager R. Markows'.1, Manager, Quality Assurance Program Development & Audit
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(GPUN - Parsippany)
- J. Sullivan, Plant Operations Director United States Nuclear Regulatory Commission (USNRC)
E. Collins, Resident Inspector, OCNGS f
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J. Wechsleberger, Senior Resident Inspector, OCNGS
- Indicates those persons who were present at the exit meeting on January 8, 1988.
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The inspectors also contacted other licensee technical and administrative personnel during this inspection.
2.0 Licensee's Actions Previously NRC Identified Concerns 2.1 (Closed) Unresolved item 50-219/86-03-01.
Inadequate training of Equipment Operators (E0s) in recording data.
The E0 had been
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observing recording data from instruments that had expired
calibration due dates and/or deficiency tags.
The E0s had not i
received training pertaining +o instruments found with these conditie s.
The inspector verified that the training had been given to tne m0s as described in mem3randa dated June 10 and 12, 1986.
The Training curriculum was revised to include the NRC item and the training was given during the Requalification Cycle 87-1 and
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completed on February 6, 1987.
This item is closed.
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2.2 (Closed) Violation 50-219/87-23-01.
This item pertains to the licensee's failure-to complete review of station procedures within
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-the required two year cycle.
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In a letter to the NRC, dated September 8, 1987, the licensee stated that all overdue station procedures were declared invalid, and the responsible department h? ads were advised to complete the biennial review of these procedures, as required.
In addition, the document contrel center was notified not to issue any invalidated procedures until they have been reviewed and approved for use.
Subsequently, the biennial review of these procedures were completed and approved procedures were available for use.
Review of the licensee's corrective action implementation for the biennial review of the station procedures indicated that the biennial review is current and adequate.
This item is closed.
2.3 (Closed) Violation 50-219/87-28-01.
Inadequate response by user departments to the "Controlled Test Equipment Discrepancy Investigation Record" form.
The form requires the user departments of the discrepint or questioned test equipment to determine if the calibration error efforts the results of the tests.
The inspector verified that the new procedure and the new recording form emphasizes the requirement for adequate and timely responses.
The new procedure is A100-ADM-3053.01, which is listed in Attachment 1 of this report.
The inspector verified that actions stated in the licensee's response to the NRC, dated December 10, 1987, were complete and adequate. This item is closed.
3.0 Offsite Review Comm:ttee (General Office Review Board - GORB)
3.1 Inspection Criteria / References The scope of this inspection was to ascertain 1: the functions of the Oyster Creek Offsite Pe 'tw Committee were performed in accordance with regulatory requirements established in the following documen+ s, and the licensee's rians and procedures listed in Attachment 1.
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10 CFR 50.73, Licensee Event Report System.
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OCNGS Technical Specifications Amendment 117, Section 6, Administrative Controls
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OCNGS Updated Final Safety Analysis Report, Chapter 13, Conduct of Operations, Rev 2, 1987 ANSI N18.7-1976, Quality Assurance for the Operational Phase of
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Nucleai Power Piants.
Regulatory Guide 1.33-1978, Quality Assurance Program
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Requirements (Operation).
3.2 Program Review The licensee's Gen tral Office Review Board (G0RB) functions and activities were reviewed to verify that:
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The administrative controls, duties and responsibilities of the
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in;luding the composition of the ccmmittee and subcommittees are adequately defined.
The committee's independent review has adequately evaluated the
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OCNGS potentially significant nuclear issues.
The action items and associated resolutions are properly
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reviewed, evaluated and documented.
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The GORB meeting frequency and meeting agenda provided adequate assurance that the Oyster Creek GORB investigation and recommendations are properly implemented.
3.3 Program Implementation and Findings 3.3.1 The licensee's operational quality assurance plan, 1000-PLN-7200-01, (Attachment-1) paragraph 2.8.5 provides for the. safety review program which establishes an offsite general office review board (G0RB).
This is a group of senior level individuals with diverse backarounds.
The GORB reports to and takes general direction from the office of the President, GPU Nuclear Corporation (GPUNC).
The primary responsibility of the G0RB is to independently consider potentially significant nuclear and radiation matter >, including related management aspects of those matters, and advise the office of the President, GPUNC.
The basic authority of GORB is to investigate and recommend.
It has no authority to direct or require action.
The Chairman of the GOR 3 is appointed by the Chief Executive Officer (CE0), GPUNC.
The GORB members are recommended by tne CEO and approved by the GPUNC board of directors.
3.3.2 The inspector revierad the Oyster Creek GORB composition and the members qualification.
The ;ix member consultants and five GPUN senior personnel represented diverse backgrounds and have varied experience and expertise in the areas of nuclear plants design, construction, operations, and plant related safety and licensing.
The inspector reviewed the previous two years of the licensee's GORB meeti.gs agenda.
These ceetings were instrumental in establishing action items which required plant modification and changes to the plant procedures.and the techn' cal specifications.
These action items were assigned to the cognizant departments for their resolution and implementation.
It was noted that the GORB-Chairman updates and maintains the status of all su a action items.
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3.3.3 The inspector reviewed'the GORB Major Issue Committee on Risk Control Report of July 1986 (Attachment-1) which implemented the NRC final safety goal policy statement adopted on June 19, 1986. The inspector reviewed the following GORB items:
(1) G0RB Major Issue Committee on Planning, Design and Modifications Report dated, July 20, 1987.
The report provided a critique on the Oyster Creek lith refueling-and discussed planning to-optimize the 12th-
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refueling outage activities during 1988. The committee recommended to retain and store plant e
operating ~ cycle information;' establish data acquisition, and identification of key generic and plant specific technical problems; and implement an
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action. plan.
The licensee is reviewing the recommendations.
(2) GORB Ad-Hoc Committee Report on the GPUN Safety Review Process.
The report recommended update of the plant Technical Specifications, procedures, training and qualification of the personnel, and the plant safety review process.
The President,
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GPUN, reviewed the committee's recommendation and appropriate actions were taken.
(3) The inspector reviewed the GORB Ad-Hoc committee report on the Oyster Creek containment integrity status dated December 9, 1987. The Ad-Hoc committee recommended that thickness measurement uncertainties be included in minimum wall thickness estimates.
The committee is pursuing the results of the drywell thickness measurement plans along with the inspection and repair plans of the cavity liner.
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(4) GORB Quality Assurance Committee concluded that
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the licensee's activities were in compliance with l
the applicable requirements. On committee's recommendations the licensee established a new j
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The group overviews the implementation of the
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corrective action identified in the QA audit
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findings.
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~3.3.4 The licensee's next.GORB meeting was scheduled for January 12-13, 1988; The inspector reviewed ~the meeting agenda.
The agenda included review of the licensee independent onsite_ review group (IOSRG) activities, licensee event reoorts'(LERs), Technical Specifications change requests, responses to NRC inspections, industrial safety u; Mates,.
safety limit-violations, action item updates, retitw of the standing committees-and the major issues commi:;cas reports and recommendations.
The inspector discussed with the GORB Chairman who provided an overview of the important 1: sues.
scheduled for discussion in the meeting, including itens such as drywell thinning, life extension, standard for instrument loop error analys_is, and methodology to improve low feedwater. control problems. The GORB activities'were found adequate. The inspector did not have further question at that time.
3.4 Conclusion The licensee's offsite review committee (G0RB - General Office Review Board) administrative controls, duties, And responsibilities are adequately defined and implemented in accordance with the licensee's policy, QA plans and administrative procedures (Attachment-1).
Composition of the GORB and it subcommittees, members qualification, meeting frequency and quorum were found satisfactory.
The major issue committees and the standing committees were found to have evaluated and provided recommendations related to the OCNGS potentially significant nuclear issues to the President - GPU Nuclear, through the GORB Chairman, in a timely manner.
The GORB assigned significant nuclear safety issue action items to the cognizant committees based on the committee's qualification and expertise.
The GORB has also maintained and updated the status of these action items, including their implementation.
Based on the review of the GORB's functions and activities, the inspector cencluded that the licensee's action is adequate.
No violations were identified.
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4.0 Organization and Administration 4.1 Inspection Criteria / References
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i-The scope of this inspection is to ascertain whether changes made to the Oyster Creek onsite organization are in conformance with the requirements of the Technical Specifications; and the use of overtime by the operations staffs are administratively controlled in
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accordance with the procedural requirements.
The eference regulatory documents and' licensee's administrative procedures are i
listed in Attachment 1.
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4.2 Program Review The inspector review the Oyster Creek Nuclear Generating Station organization to verify that:
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The onsite organization is functioning as described in the Technical Specifications.
Personnel cualification levels are in conformance with the
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applicable codes and standards a:, described in the Technical Specifications.
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The lines of authority and responsibility are in conformance with the Technical Specifications.
The operations personnel overtime limits and authorization are
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administratively controlled and implemented in accordance with
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the administrative proceduras, 4.3 Progrcm Implementation and Findings 4.3.1 The Oyster Creek Nuclear Generating Station (OCNGS)
Procedure-101, Organization and Responsibility delineates the OCNGS organization, as established by the GPU Nuclear Organization Plan.
The OCNGS is headed by the director, Oyster Creek whose responsibilities and major functions are listed in the Technical Specifications and in the GPU Nuclear Organizations Plan.
Four department heads: Plans and Programs, Plant Engineering, Plant Material, and Plant Operations; and two staff members heading safety review group, and special projects report to the director Oyster Creek.
The inspector discussed with the cognizant station management and reviewed the qualification of selected operation personnel.
These individuals met their qualification requirements described in the facility FSAR.
4.3.2 The OCNGS Procedure 106, Conduct of Operations, paragraph 6.7 (Attachment-1) establishes requirements for overtime control and authorization for the plant personnel performing safety-related activities.
Through the administrative.nrocedures, 2000-ADM-2401.02 ar.d 1000-P0l.-2401. 03, the licensee implemented the NRC requirement for per Generic Letter GL 82-12," Requirements for Limiting Consecutive Work Hours for Designated Employees" at OCNG ?
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The inspector discussed with operations staffs and reviewed'
the' equipment operators and the control room operators overtime summary documentation. Other than the plant management, the union is involved in the~ review of the eligibility of the personnel overtime assignment at OCNGS.
The overtime assignment was found to be adequately documented -and met the regulatory requirements.
4.3.3 The inspector also reviewed the scope of the licensee's selected QA audits (paragraph 5.3 and Attachment-1).
These audits have verified the adequacy and effectiveness of the licensee's organization and administration relative to the audited activities.
The audits were comprehensive and had addressed the level of staffing and staff qualification.
Review of the licensee's Quality Assurance Plan
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1000-PLN-7200.01 indicated that the QA department
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organization chart did not reflect the updated configuration. The chart depicted that a manager, quality assurance was in-charge of both TMI-1 and Oyster Creek modifications and operations QA activities, whereas in actuality there are two separate functional entities one for TMI-1 and the other for Oyster Creek.
The organization description in the text had correctly narrated the current organizational status.
The licensee representative stated that this document is currently being revised to incorp-orate the recent changes, including the organization chart.
The inspector did not have further questions at this time.
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4.4 Conclusion The Oyster Creek Nuclear Generating Station onsite organization is functioning as described in the facility Technical Specifications.
The operations staff's qualification and training met the licensee's commitment as delineated in the facility's FSAR. The facility is adequately staffed and tna lines of authority and responsibility are properly defined and are in conformance with the Technical Specifications.
The licensee overtime documentation exhibited proper controls of the operations personnel overtime limits and authorization. The implementing procedures incorporated the NRC requirements for limiting consecutive work hours for designated employees per Generic letter GL 82-12.
Based on the above, the licensee's onsite organization and admini-strative control found effective and adequate.
No violations were identified.
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5.0 Audit Program and Implementation 5.1 Requirements 10 CFR 50 Appendix B Criterion XVIII requires the licensee to have a comprehensive system of planned and periodic audits to verify compliance with all aspects of the quality assurance (QA) program and to determine the effectiveness of the program.
The technical Spec.fication (TS) Section 6.5.3 requires audits of the facility activities be performed and lists the audits and their periodicity.
5.2 Audit Program The documented audit program is described in: FSAR Chapter 17 Operational QA Plan, Procedure No. 1000-PLN-7200.01, Section 9.0; and QA Department Procedure Nos. 6100-QAP-7218.01 anc'.02.
The above procedures and supporting documentation were reviewed (see Attachment 1).
They adequately describe the audit organization and delineate the responsibilities of the audit personnel including their independence.
The procedures provide for establishing, planning, trair.ing, implementir:g, and maintaining the audit program dynamic as well as current.
Sources readily available to the Site auditors include:
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Licensee Actions Items (LAIs) which include NRC concerns such as Inspection Reports, Bulletins, In'ormation Notices, Generic
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Letters, etc.
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Licensee Event Reports (LERs) and Significant Event Reports (SERs).
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Corporate and Three Mile Island Audit Reports.
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QA Trend Analysis Repnrts, Vice President Reports, and QA Board of Director Reports.
Independent Safety Reviews, QA Surveillance Reports, and
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Deviation Reports.
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Corrective and preventive actions and subsequent follow up actions to sources researched.
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To assure independence, the Site Audit Manager reports to the Manager
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of QA Program and Development who reports to the Corporate Director l
of QA. Assisting the Site Audit Staff Manager are three lead
auditors and one lead auditor in training who have a broad range of l
plant operating experience.
Support from the Corporate QA auditors, l
technical expertise, and contractors is provided to the Site Audit l
Staff.
Corporate QA in turn receives support from the Site Audit Staff in their conduct of audits.
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The training of the staff is in accordance with procedure no.
6100-QAP-7218.02 and is primarily on-the-job training (0JT).
Formal training to supplement the OJT certification of lead auditors and the future Auditor Training Program were reviewed by the inspector.
Some of the courses provided are:
Probabilistic Risk Assassment, Nondestructive Examination, Technical Training, ASME Codes, and Chemistry Seminars.
An Auditor
"Job Task Analysis" survey, similar to an INPO job task analysis, was rEcently completed.
Evaluation of the results are in progress and will also be used in the development of the Auditor Qualification Training Program.
In conclusion the inspector finds the documented Audit Program to be in conformance with the regulatory requirements and licensee's
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commitments to industry standards. Management's involvement in improving the Site Audit Staff training is evident by the Job Task Analysis survey conducted and being evaluatad.
No violations or deviations were observed.
5.3 Implemer.tation of Audit Program To assess the implemention of the Audit Program, the inspector ot, served the following activities:
Turnover of the Maintenance Audit in progress from one auditor
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to another auditor. These auditors completed the turnover by going over the audit checklist, attribute by attribute, to be sure of the status of the audit.
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Field observaticns by the auditor during the conduct of the Security Audit.
This action also verified the disposition / corrective action Quality Deficiency Report (QDR)87-029 from a previous audit. A Corrective Action Follow Up Form was prepared by the auditor to close out tr.e QDR.
Preparations by an auditor for the pending Training Audit.
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Included in the preparation was the review of past findir:as including NRC findings.
One unresolved NRC finding being reviewed was 50-219/86-03-01 that was written by the inspectcr in February 1986.
It was noted that the auditor had not only requested data from the Licensing Department as he is required to do by procedure, but he also requested the NRC Inspection Report. When queried by the inspector on how he was going to verify that the corrective action was effective regarding training of the Equipment Operators (EOs) on the significance of a calibration sticker on installed measuring and recording devices, the auditor said that he was going ta observe E0s performing their plant tours.
It was during the plant tours
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that the inspector noted that the auditor could not properly verify the effectiveness of the Equipment Operators training.
In another case of preparing for an audit, one Site auditor was a member of the Safety System Functional Inspection (SSFI) of the emergency diesel generators-(EDGs)..He-showed the inspector the correspondence he researched in preparing for the SSFI.
. Included in his correspondence was a copy of the NRC Inspection-Report 50-293/85-85 dealing with a SSFI.
Status of Completion and Scheduling of Audits for 1985, 1986 and 1987 were' reviewed by the inspector. Also reviewed was the planned
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QA Audit Schedule for the period covering July 1987 through June 1989.
The audits were planned and sch.eduled in accordance with the Technical Specifications and the Operational QA Plan. Audits were conducted and issued on schedule. Corrective action responses were also received on schedule in accordance with procedure no.
6100-QAP-7218.01.
Reviews of selected audits listed in Attachment A confirmed that not only are the audits comprehensive and detailed, but are administratively controlled in a timely manner.
The inspector concluded that the implementation of the Audit Program is plan 1, conducted and administered by trained and qualified Site personi.i No violations or deviations were observed.
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5.4 QA/QC Interfaces The Site Audit Group rely on the expertise from the Site QA Modifications / Operations Groups to support their audit effort.
Site auditors are continually in contact with the Operations QA and QC personnel regarding current plant status and condition.
Memoranda by the Site Audit Manager requesting Operational-QA/QC personnel to volunteer their expertise in Site audits has resulted in large pool
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I of experts being available to the Site Audit Teams.
Corporate relies heavily on Site auditors to support the Corporate and Special audits. Corporate's confidence in the Site Audit Program is showr, by the wide distribution the Site Audits are receiving.
Corporate support in the Auditor "Job Tesk Analysis" Survey is evidence of Corporate's determination to continually improve the knowledge, skills and capability of the Site audit personnel.
In conclusion the QA/QC interface with the Site Audit Group is in conformance with regulatory requirements and the licensee's commitments.
No violations or deviations were observed.
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6.0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interview on January 4, 1988.
The findings of the inspection were discussed with licensee representatives during the course of the inspection and presented to licensee management at the January 8,1988 exit interview (see paragraph I for attendees).
At no time during the inspection was written material provided to the licensee by the inspector.
The licensee did not indicate that proprietary information was involved within the scope of this inspection.
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ATTACHMENT - 1 DOCUMENTS REVIEWED 1.0 Procedures A100-ADM-3053.01, Calibration of Maintenance Test and Inspection Tools, Gauges, and Instruments, Rev 0.
1000-PLN-7200, Operational Quality Assurance Plan, Rev. 1-00 6100-QAP-7218.01, Quality Assurance Audit Program, Rev. 9-00 6100-QAP-721812, Quality Assurance Auditor Qualifications, Rev. 7 1000-PLN-1291.04, GPUNC Nuclear and Radiation Safety Plan, Rev.1, April 1, 1986 1000-PLN-7200.01, Operational Quality Assurance Plan, Rev. 1, 1000-POL-2401.03, Extended Overtime Policy, Rev. O, April 9, 1984 1000-ADM-1291.01, Procedure for Nuclear Safety and Environmental In. pact Review and Approval Documents, Rev 3, October 1, 1987 2000-ADM-2401.01, Overtime Procedure for Exempt Employees, Rev. O, September 13, 1987 2003-ADM-2401.02, NRC Limits Consecutive Hours Worked Implemensation Procedure, Rev 0, July 4,1987 Station Procedure 101, Organization and Responsibility, Rev 16, February 21, 1987 Station Procedure 106, Conduct of Operations, Rev 45, August 13, 1987 GORB-1, General Office Review Boards Administrative Procedures, Rev 3, October 23, 1987 l
General Of fice Review Boards (G0RB) Responsibility, Authority,
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Organization and Resources, Revision 3, September 24, 1987 2.0 Memoranda, Letters and Reports:
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Report, Ad-Hoc GORB Committee on the GPUN Safety Review Process, December 4, 1987 l
Report of the GORB Committe on Risk Control, July 1986 l
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Oyster Creek G0RB Quality Assurance Committee Review of 14 Quality Assurance Audit Reports, May 7, 1985 Ad-Hoc Committee on Containment Integrity - Summary Status Report, December 9, 1987 Report of Meeting of TMI-1 and Oyster Creek GORB Committe V - Planning, Design and Modifications, July 20, 1987 Agenda for Oyster Creek General Office Review Board Meeting No.122, January 4, 1988 3.0 Licensing Reference Documents Oyster Creek Nuclear Generating Stat'on Technical Specifications, Amendment 117, 1987 Oyster Creek Nuclear Generating Station Updated Final Safety Analysis Report Rev. 2, 1987 ANSI N18.7-1976, Quality Assurance for the Operational Phase of Nuclear Power Plant Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation)
USNRC Generic Letter 82-12, Nuclear Power Plant Staff Working Hours
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4.0 Licensing Action items (LAIs)
NRC outstanding items 50-2/9/86-03-01 and 50-219/87-28-01 5.0 Site (S) and Corporate (0) Audits Site Audits S-0C-87-03, 04, 07, 11, 14, 17; S-0C-86-07, 09, 14: and Corporate Audit 0-0C-87-04, and 85-08.
6.0 Computerized Status Reports Status of Completion and Scheduling Oyster Creek Site Audits for 1985, 1986, and 1987.
Open Audit Finding Status as of 01/07/88 for Oyster Creek Audit Group 1985, 1986, and 1987 Audit
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