ML20002A921
| ML20002A921 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/05/1980 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8012090177 | |
| Download: ML20002A921 (11) | |
Text
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Jersey Central Power & Light Company Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 (201)455-8200 December 5, 1980 Director Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
Subject:
Oyster Creek Nt' clear Generating Station Docket No. 50-219 Revision to 0CNGS Operational Quality Assurance Plan Pursuant to our telephone conversation with Mr. Spraul on November 12, 1980, we are forwarding, as an attachment, our comments and responses to 34 of the 35 items identified in your letter of August 14, 1979, " Request for Additional Information and Staff Positions on the Operational Quality Assurance Plan for Oyster Creek Nuclear Generating Station". The remaining item that is not addressed in the attachment is your Item (7), which requests that we update our commitments on selected Regulatory Guides and ANSI Standards.
With the new GPU Nuclear Company Organization, it will take some additional time to establish our position on the Regulatory Guides and ANSI Standards with regard to the Oyster Creek Nuclear Generating Station.
During our telephone conversation of November 12, 1980, we also spoke of having a meeting in Bethesda on December 11, 1980, at which time we will review the information provided in the attachment to this letter. We will also be prepared, at that time, to present the revised organization for the Oyster Creek Nuclear Generating Station incorporating the GPU Nuclear Company.
Very truly yours,
E E
c Ivan R. Finf ck, r.
Vice President r.
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e ATTACHMENT Comments and Responses to NRC " Request for Additional Information and Staff Positions on the Operational Quality Assurance Plan for Oyster Creek Nuclear Generating Station" The NRC letter of August 14, 1979, contained 35 items requesting additional information or identifying the staff positions on the Operational Quality Assur-ance Plan, Rev. 2.
Following is a discussion of 34 of 35 items with recommenda-tions for incorporation or clarification.
The remaining item (Item 7) requested an update of our commitments to selected Regulatory Guide and ANSI Standards.
This update will be provided at a later date, under separate cover.
Each of the NRC comments, as provided in the August 14, 1979, letter, is provided below, along with our recommendation. Where reference is made to a position within the JCP&L organization, the corresponding position 1;. the GPU Nuclear Corporation organization has been identified in parenthesis.
(1) Section (II)
Please provide Jersey Central Power & Light Company's qualification requirements for the Manager-0perational Quality Assurance and the Quality Assurance Supervisor.
Recommendation: Make the following additions to Pages 29 and 30:
"The Manager-Operational Quality Assurance (Manager-Quality Assurance) shall have, as a minimum, a baccalaureate degree in engineering or science with at least five years of related experience, two of which should be associated with nuclear facilities.
In addition, the Manager-Operational Quality Assur-ance (Manager-Quality Assurance) shall meet the qualification requirements of an Audit Team Leader."
"The Site Ouality Assurance Supervisor (Oyster Creek Modifications / Operations QA Manager) shall have, as a minimum, a baccalaureate degree in engineering or science, or be a high school graduate with six years of nuclear and quality assurance experience."
(2)
Sections (II The Operational Quality Assurance Plan states on
& XII)
Pages 17 and 110 that management reviews the Operational Quality Assurance Program" at least every two years., It is the staff position that this should be done annually.
Please revise the Operational Quality Assurance Plan to reflect this staff position or provide justification for the deviations.
Recommendation: (1) Change the last paragraph on Page 17 to the following:
"The Vice President-Generation (Office of President-GPUNC) is responsible to regularly assess the scope, status, adequacy, and compliance of the Quality Assurance Program to the requirements of 10CFESO, Appendix B.
This assessment shall be the combined result of:
j
a.
Contact with Quality Assurance Program status through review of periodic status reports on the effectiveness and imple-mentation of the Quality Assurance Program, i
b.
Performance at least once a year of a preplanneo and documented assessment of the effectiveness of the Quality Assurance Program to assure that the program meets regulatory requirements, and the policies and directives of JCP&L. This assessment may be performed utilizing the safety review groups, an independent consultant, or his own staff.
Any corrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution.
(2) Delete Part 0,Section XII, Page 110.
(3) Section (II)
Describe measures for communicating to all responsible organizations and individuals that quality policies, QA manuals, and procedures are mandatory requirements which must be implemented and enforced.
Recommendation: Add the following paragraph to the President's Policy Statement:
The effectiveness of any Quality Assurance Program is dependent upon the individuals who implement the program. Accordingly, all personnel of the Jersey Central Power & Light Company and their contractors must comply with the requirements of this Quality Assurance Program. Al'i members of management must give full support to maintaining an effective quality program as defined in this Plan.
(4) Section(V)
Items F and G on Page 78 discuss the evaluation of contractors from a quality standpoint by the Manager-Operational Quality Assurance.
Please clarify that the evaluations are such that the Jersey Central Power &
Light Company is assured that Appendix B to 10CFR Part 50 will be implemented.
Recommendation: Add to Se: tion V 2.A (P. 77) the following:
"For those items which are identified on the Quality Assurance Systems List as being nuclear safety related, JCP&L retains the responsibility to assure that the applicable parts of 10CFR50, Appendix B are included in the procurement documents and implemented 1
by the contractor."
(5) Section (III)
Page 52 addresses training of personnel. Please provide a commitment that methods are provided for documenting the content of each training session, who attended, the time and date, and the results.
Recommendation: Add the following paragraph to p. 52:
... where required, operators are formally licensed or qualified.
"In the case of fonnal classroom training, documentation of material content, attendance, time and date, instructor and, where applicable, any documented results of training shall be maintained as evidence of completion."
(6) Section (III)
Describe measures which assure that (1) quality related activities are performed with specified equipment under suitable environmental conditions; and, (2) prerequisites are satisfied before inspection and test.
Recommendation: The measures necessary for providing the assurance stated above are addressed in Section VI of the 0QA Plan and are included, for specific applications, in the implementing procedures, instructions, and checkli sts.
JCP&L does not see a need to expand on the requirements as srcified in the 0QA Plan.
(7) Section (III)
Update position on Regulatory Guides and ANSI Standards.
Recommendation: This item will be the subject of separate correspondence.
(8)
Sections (IV, V and XII))
Item AE on Page 67 and Item S on Page 71 both use "should" in two places.
Please change these "shoulds" so that a commitment is provided or justify not doing so.
Similarly, address the two " mays" in Item Y on Page 82 and the two " mays" in Item A on Page 108 to indicate requirements or justify not doing so.
Reconinendation:
Revise as follows:
Section-AE
" Modification and addition procedures, requiring welding (P. 67) shall include, as appropriate, requirements for material checks, weld preparation, fit-up, welding, NDE heat treatment and pressure tests to be utilized. These requirements, when specified, shall also include space for sign-off to verify that critical steps were performed."
Section S (P. 71)
" Maintenance, repair and replacement procedures requiring welding shall include, as appropriate, requirements for l
material checks, weld preparation, fit, welding, NDE, heat treatment and pressure tests to be utilized. These requirements, when specified, shall also include space for sign-off to verify that critical steps were performed."
A
Section Y (P. 82)
Delete this section in its entirety.
Section A (P. 108)
- "...Re-audits of deficient areas shall be conducted to verify implementation of corrective actions.
In addition, unscheduled audits shall be conducted, from time to time, on any aspect of this Operational Quality Assurance Program."
(9) Section (III)
Describe provisions which assure that the NRC will be notified of changes to the Operational Quality Assurance Plan prior to implementation and in organizational elements within 30 days after annoucement.
(Note that minor editorial changes and personnel re-assignments of a nonsubstantive nature do not require NRC notification.)
Recommendation: Revise the paragraph on Page 51 which discusses the revisions to the Plan to the following:
The Manager-Operational Quality Assurance (Manager-Quality Assuranc e) has the direct responsibility for ensuring that this Operational Quality Assur-ance Plan is implemented and that it provides for adequate control of all programmatic activities affecting quality. He is also responsible for ensuring that the Plan is modified and updated as standards, regulations, results, and experience diitate.
Revisions to the Plan shall be considered signifi-cant if they alter the degree of compliance with regulatory requirements.
Changes for the organi-zation shall be considered significant except in the area of quality assurance.
Changes in name or title with no basic change il function also shall not be considered significant.
Editorial changes and typos which do not change the intent of the words or scope of the program shall not be consider-ed significant.
Significant plan revisions shall be submitted to the NRC.
NRC approval is required prior to implenantation.
Changes considered by the Manager-Operational Quality Assurance (Manager-Quality Assurance) and the Vice President-Generation (Vice President-Nuclear Assur-ance). The Manager-Operational Quality Assurance (Manager-Quality Assurance) is responsible for notifying the NRC of such changes to the Plan within 30 days of the change.
(10) Section'(IV)
Describe measures which assure that (1) design documents identify inspection and test criteria; and, (2) design characteristics can be controlled, inspected, and tested.
.i -
f Recommendat, ion:
Refse as follows:
/
Item I, Page 65 design bases shall include, as appropriate: physics, stress, materials, thermal, hydraulic, radiation and accident analysis; appropriate design bases, codes, standards and regulations; fire protection requirements; inspection and test requirements, as applicable to assure that the design may be surveillance tested and inservice inspected, as appropriate; acceptance and rejection criteria; quality assurance /
quality control; compatability of materials and accessibility for inservice inspection, maintenance, repair and replacement.
Item J, Page 65 Design documents and specifications shall i' clude the identification and documentation n
of the invoked design bases; regulatory requirements; codes, standards; inspection and test criteria; quality requirements; and measures provided as appropriate to assure that design requirements are factored into fabrication and installation inspection and testing and are adequately controlled.
(11)
Section(IV)
Item L on Page 64 addresses the use of a designer's supervisor to independently verify a design.
If permitted, this activity should be under the following controls :
If in an exceptional circumstance, the designer's inrnediate supervisor is the only technically qualified individual available, this review can be conducted by sapervisor provided that:
a.
The other provisions of Regulatory Guide 1.64 are satisfied.
b.
The justification is individually documented and approved in advance by the supervisor's management; and, c.
Audits by the Quality Assurance organization cover the frequency and effectiveness of this practice.
The commitment to Regulatory Guide 1.64 should reflect this position or provide an alternative for the staff's evaluation.
(See Item 7)
Recommendation: Revise Item L on Page 64 as follows:.
Among other things, satisfactory design control requiresthat an independent design review or design verification be per formed. The independent design verification or checking process may be accomplished by means of design reviews, alternate calculations, or qualification testing. The individual. responsible for the design verification is other than the individQal who performed the original design. This independence requirement is met by members of-another group.
The individual's immediate supervisor may perform the independent design review if the supervisor did not specify a singular design approach or rule out certain design considerations and did not establish the design inputs-used in the design.
(12) Section (IV)
Describe measures which assure that materials, parts and equipment which are standard, commercial (off-the-shelf), or which have been previously approved for a different application are reviewed for suitability prior to selection.
Recommendation:
Incorporate the following addition to Item IV 1.H (Page 64):
...or consistent with currently acceptable requirements.
"In the special case of commercial grade material, the suitability of that classifi-cation will be reviewed for each application by the responsible engineering group.
(13) Section (V)
Section V.1 needs to be clarified in the area of timeli-ness.
Please show that procurement documents are reviewed and approved prior to release and that contractors' quality assurance programs are reviewed and concurred with prior to initiation of activities affected by the program.
Recomendation:
Incorporate the following addition to Item V 1.M (Page 73):
... access requirements have been established, "Under nonnal circumstances, procurement documents a
are reviewed and approved prior to release.
When emergency procurements are required, the procurement document may be released prior to final approval; however, the item shall not be released until the 4
approvals of the procurement documents have been obtained and the compliance with the requirements of the procurement documents has been demonstrated."
~0~
-(14) Section (V)
On Page 79, Item I states that contractors must be evaluated at least once every five years to remain on the Contractor Classification List.
Please pro-vide a commitment to meet the staff position relative to the requirements of Section 3.4.2 of ANSI N45.2.12, Draft 3, Revision 4 (February 1974) which follows:
In lieu of conducting annual audits of active suppliers (not including principal contractors), NRC will accept a commitment to the following alternative program as assurance that an acceptable external audit program has been established:
1 In lieu of routinely conducting an annual reaudit of each active supplier, a formal evaluation of the supplier is performed each year after the i
initial audit to determine if a reaudit is required during the upcoming year. This evaluation must be formal with the results documented and approved by responsible QA management, and it must consider pertinent factors such as the results of other audits, history of performance of product and/or service, and effectiveness of implementation of the supplier's QA program.
The annual assessment shall consider the complexity j
of the component concerned and the degree of the quality and process control required by the supplier's e ffort. As a result of this evaluation, suppliers requiring a formal reaudit are identified.
Regard-less of the results of the evaluation, suppliers j
will be reaudited every three years.
Recommendation:
Revise Section V 2.I (Page 79) as follows:
(1)
Del ata last sentence.
(2) Add the following:
Contractor's continuation on the list will be controlled through an annual evaluation of the contractor's performance using pertinent results from manufacturing surveillance, source inspection, receiving
-inspection, and other appliable factors. The evaluation will include a recommendation as to the need for a scheduled program or problem area audit. Auditing like surveillance and inspection, will be treated as a Quality Assurance tool used for evaluation.
Further-more the recommendation to to audit will include
-provisions for reviewing the importance and impact of the particular contractor's scope and status.
(15) Section (VIII)
Describe measures which assure that correct item identification is verified and documented prior to release for fabrication, assembling, shipping and ins tall ation.
Recommendation: Sections VIII C, D and F contain requirements for procedures to control the identification and marking of materials, parts and components during both on-site and off-site fabrication, installation, main-tenance repair and replacement.
Included in these procedures are the requirements for verification and documentation of the item identification prior to release. Additions or changes to the Operational Quality Assurance Plan are not considered to be war-ranted.
(16) Section (VII)
Describe measures which assure that special processes are performed using written process sheets (or equiva-lent) with recorded evidence of verification.
Recommendation: Section VII C requires that special processes be per-formed in accordance with qualified written procedures by qualified personnel.
Section VII I requires that when special processes are performed, they be per-formed using written and qualified procedures, they be performed by qualified personnel and records be main-tained to demonstrate that the qualifications and certifications are current.
Section IV 1.Z requires that modification and addition activities (which include special processes) be controlled by means of a job order system and that this system include QA review, i.e., verification and documentation of satis-factory completion. Additions or changes to further describe the requirements are not considered necessary.
(17) Section (VI)
Please clarify item I on Page 84 as to the prerequi-sites for an inspector to sign and date the authori-zation for work to proceed beyond a hold point.
Recommendation:
Prerequisites cannot be described because they are unique for each case. The inspector will establish the basis and criteria for authorizing the bypassing of a hold point at the time of consent and is respon-sible for assuring that these bases and criteria will not have a deleterious effect on the safe opera-tion of the plant.
Witions or changes to further describe the requi' +.nents are not considered necessary.
J j
i (18) Section (II) ~
Please clarify the last sentence in item J on Page 84 to indicate that the " pre-established requirement!"
are the original design and inspection requirements of acceptable alternatives.
Recommendation: Change the last sentence of item J, p. 84 to read as.
follows:
" Modifications, repairs and replacements are inspected in accordance with the requirements as established during the inspection planning and as required by the insoection packages."
(19 Section(VI)
Describe measures which assure that provisions are established for indirect control by monitoring, pro-cessing methods, equipment, and personnel if direct inspection is not Dossible.
Recommendation: Add to the end of item VI 1.C (Page 83) "In the event direct inspection is not possible or practical, surveillance of the activity will be performed by means of monitoring pro-cessing methods, equipment and personnel."
j (20)
(App. B)
Item VI B on Page 126 indicates that the Manager-Operational Quality Assurance concurs with maintenance, modification, replacement and repair procedures "on 7
a sampling basis." Please identify what personnel, knowledgeable in QA, reviews all of these procedures to determine the need for:
(a) inspection; (b) iden-tification of inspection personnel; and (c) documenting l
inspection results. This review should not be made on a sampling basis.
l Recommendation:
Delete the reference to "on a sampling basis as required by Quality Assurance" from item VI B on
- p. 126.
(21) Section(VI)
Please provide Jersey Central Power & Light Company's position on the attached "QA Branch Interpretation on Calibration Accuracy Requirements."
Reconnendation: The QA Branch Interpretation on Calibration Accuracy Requirements will be used as a guide in establishing the requirements-for specific measuring and test
- equipment.
If the piece of measuring and test equip-ment is unique, and, where practical and possible, the guidelines will be incorporated in the implementing procedures.
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(22) Jection (IX)
Describe measures which assure that qualified indi-viduals accomplish the special handling, preservation, storage, cleaning, packaging and shipping activities described in Section IX of the Operational Quality Assurance Plan.
Recommendation: Revise Section IX C (Page 96) as follows:
"The Station Superintendent (Director, Oyster Creek Operations) is responsible... under his control and for assuring that these procedures are implemented by suitably trained individuals.
The procedures will be prepared by contractors, Generation Engineering (Technical Functions) or Station Staff, as appropriate.
(23) Section (XI)
Please identify the individuals or groups having responsibility and authority for disposition and approval of nonconforming items.
For each means of nonconformance control noted in part D of Section XI, describe measures which assure that documentation:
(1) identifies the nonconforming item; (2) describes
.the nonconformance; (3) details the disposition of the nonconformance; (4) describes the inspection re-quirements; and (5) ine): des signature approval of the disposition.
Recommendation: Section XI D describes the various methods utilized for identification and control of nonconformance.
These include:
(1) Nonconformance and Corrective Action reports; (2) Job Orders; (3) Audit Notices; and (4) Reportable Occurrences.
Section XI C identi-fies that each of these methods is managed by means of administrative control procedures and that each of these procedures includes the specific requirements for: (1) identification and documentation of the non-coupliance, etc. through (7) Preparation of records.
Each of these administrative control procedures also contains the specific requirements for signature approval of the disposition, corrective action and follow-up.
'erther,Section XI J states that each Manager is nsible for disposition and corrective action of nonconfc-esnce within the scope of his responsibilities.
No additions or changes to the Operational Quality Assurance Plan are considered necessary.
(24) Section (XI)
The last sentence in part N of Section XI indicates that nonconformance dispositioned "use as is" or
" reject" require formal documentation in accordance with appropriate procedures. This appears to be too 1
.