ML20003F862
| ML20003F862 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/03/1981 |
| From: | Finfrock I JERSEY CENTRAL POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20003F859 | List: |
| References | |
| NUDOCS 8104230743 | |
| Download: ML20003F862 (16) | |
Text
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JERSEY CENTRAL POWER 4 LIGHT COMPANY OYSTER CREEK NUCLEAR GENERATING STATION 00CKET NO. 50-219 REVISION 5 to AMENDMENT 71 to the OYSTER CREEK FACILITY DESCRIPTION AND SAFETY ANALYSIS REPORT This Revision 5 to Amendment No. 71 to the Facility Description and Safety Analysis Report for the Oyster Creek Nuclear Generating Station revises the Quality Assurance Plan for the Oyster Creek Station.
JERSEY CENTRAL POWER S LIGHT COMPANY By AN Vice Preside PSL l
Director - O ste Creek STATE OF NEW JERSEY )
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COUNTY OF MORRIS
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Sworn and subscribed to before me thisjf day of 6b 1981.
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Notary [dslic M!C"AEL U,00 ART NOTARY PU3UC OF NEW JER$EY My Omam tw es steen 31,190
i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
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DOCKET NO. 50-219 JERSEY CENTRAL POWER 5 LIGHT COMPANY)
CERTIFICATE OF SERVICE This is to certify that a copy of Revision 5 to Amendment No. 71 to the Facility Description and Safety Analysis Report for the Oyster Creek Nuclear Generating Station, which was filed with the United States Nuclear Regulatory Commission on April 3, 1981 has this 6
day of April 1981, been served on the Mayor of Lacey Township, Ocean County, New Jersey, by deposit in the United States mail, addressed as follows:
The Honorable Jorge Rod Mayor, Lacey Township P.O. Box 475 Forked River, New Jersey 08731 JERSEY CENTRAL POWER 4 LIGHT COMPANY By lMu l
Tice Presideny - Jp4L l
Director - OA teF Creek DATED:
April 6, 1981
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OYSTER CREEK NUCLEAR GENERATING STATION
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(609)693-6000 P.O. BOX 388
- FORKED RIVER
- 08731 April 6, 1981 The Honorable Jorge Rod Mayor of Lacey Township P.O. Box 475 Forked River, New Jersey 08731
Dear Mayor Rod:
Enclosed herewith is one copy of Revision 5 to Amendment 71 of the Facility Description and Safety Analysis Report for the Oyster Creek Nuclear Generating Station.
This Revision modifies the Quality Assurance Plan of the Oyster Creek Station.
This document was filed with the Nuclear Regulatory Commission on April 6, 1981 Very truly yours, e
Ivan R. Fin ock, Jr.
Vice President -JCP6L Director - Oyster Creek enclosure
ATTACHMENT h
GPUN position regarding NRC " Request for Additional Information and Staff Positions on the Operational Quality Assurance Plan for Dyster 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 l
Assurance Plan. Each of these 35 items is listed below along with the GPUN i
position and action taken relative to incorporation in Revision 5 of the Operational Quality Assurance Plan.
l (1)
Section (II)
Please provide Jerse'y Central Power & Light Company's qualification requirements for the-Manager-Operational Quality Assurance and the Quality Assurance Supervisor.
4 Position:
The minimum qualification requirements for Quality Assurance personnel are contained in the OQA Plan,-
Page 32.
d 1
(2)
Sections (II
& XII)
The Operational-Quality Assurance Plan states on 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 Le done annually.
Please revise the Operational Quality Assu ance Plan to reflect this staff position or provide justification for -
i the deviations.
4 Position:
The requirement for management reviews of the OQA Program are contained in Section II.2(b) (page 15).. It will be done once a year.
In addition,Section XII.0, which previously contained the requirement for_ independent review of the OQA Program every two years, has been deleted.
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(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.
Position:
The Statement of Policy and t.uthority, Pages 1 and 2, has
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been revised to incorporate these measures.
(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.
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Attachment Page 2 Position:
Section V.2.B' (P. 74) has been revised to require that for those items which are identified on the Quality Assurance Systems List as being nuclear safety related, GPUN retains the responsibility to assure that the applicable parts of 10CFR50 Appendix B are included in the procurement documents and implemented 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.
Position:
The second paragraph of p. 47 incorporates the require-ment that, "In the case of formal classroom training, documentation of material content, attendance, time and date, instructor and, where applicable, any docu-mented 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.
Position:
The measures necessary for providing the assurance stated above are addressed in Section VI of the OQA Plan and are included, for specific applications, in the implementing procedures, instructions, and checklists.
i (7)
Section (III)
Page 52 states that Jersey Central Power & Light Company shall " utilize the guidance" of a number of Regulatory Guides and ANSI standards. Please make this a commit-ment to " meet the Regulatory Position" of the Regulatory Guides and " meet the requirements of ANSI N45.2.12 which is not endorsed by a Regulatory Guide.
In addition, we request you update your commitments in this area to the latest available NRC quality assurance guidance which is given in the following documents:
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a Attachment Page 3 f
Regulatory Guide 1.8 Rev. 1R 5/77 Regulatory Guide 1.28 Rev. 2 2/79 Regulatory Guide 1.30.
8/72 Regulatory Guide 1.33 Rev. 2 2/78 Regulatory Guide 1.37 3/73 Regulatory Guide 'l.38
'Rev. 2 5/77 Regulatory Guide 1.39 Rev. 2 9/77 Regulatory Guide 1.58 8/73 Regulatory Guide 1.64 Rev. 2 6/76 Regulatory Guide 1,74 2/74 Regulatory Guide 1.88 Rev. 2 10/76 Regulatory Guide 1.94 Rev. 1
-4/76 Regulatory Guide 1.116 Rev. 0-R 5/77 Regulatory Guide 1.123 Rev. 1 7/77 ANSI N45.2.12 (Draft 3, Rev. 4,.2/74).
We will evaluate " exceptions" (we suggest they be called " alternatives") to these documents upon receipt of the updated information. Indicate the NRC guidance which will not be followed and provide the alternative.
l Since your position on Regulatory Guide 1.54 is given in response to question 11 in Supplement 6 to Amendment 68 to -the Application for a Full Term License and since 'the NRC no longer reviews commit-ments to Regulatory Guide 1.54, reference to this Regulatory Guide can be deleted from the Operational Quality Assurance Plan.
Position:
Revision 5 of the OQA Plan (pages 47 through S8 inclusive) provides the GPUN position' with regards to Regulatory Guides. This section 'of the OQA Plan addresses each of the Regulatory Guides listed in the NRC comment except Regulatory Guide 1.28, in which case the later revision of the Guide was considered (Rev. 2 instead of Rev. 1).
In addition, Regulatory Guides 1.26 and 1.54 are discussed. The position on ANSI N45.2.12 is discussed relative to Regulatory Guide 1.144 which endorses the ANSI Standard.
(8) Sections (IV, V & 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 Similarly, address the two " mays" in Item Y on so.
Page 82 and the two " mays" in Item A on Page 108 to indicate requirements or justify not doing so.
Position:
The changes discussed above have been incorporated in Revision 5 of the OQA Plan;Section IV l. AE, page 64;Section IV.2.S, page 68;Section V.2.Z, page 80, and Section XII.A, page 107
M Attachment Page 4 (9) Section (III)
Describe provisions which assure that the NRC'will be notified of changes to the Operational Quality Assurance Plan prior to implecentation and in organi-zational elements within 30 days af ter announcement.
(Note that minor editorial changes and personnel re-assignments of a nonsubstantive nature do not require NRC notification.)
Position:
Section III has been revised to include requirements for assuring NRC notification of changes to the OQA Plan. The specific requirements are contained on.
Page 46.
(10) Section (IV)
Describe measures which assure that (1) design docu-ments identify inspection and test criteria; and (2) design characteristics can be controlled, inspected and tested.
Position:
This item had already been addressed in Sections IV.l.I and IV.l.J Revision 3 of the OQA Plan and has been retained in Revision 5.
m (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 immediate supervisor is the only technically qualified individual available, this review can be conducted by the supervisor provided that:
The other provisions of Regulatory Guide 1.64 are a.
satisfied.
b.
The justification is individually documented and approved in advance by the supervisor's nanagement;
- and, Audits by the Quality Assurance Organization" cover c.
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)
Position:
Section IV.l.L, Pages 61 and 62, has been revised to incorporate the controls noted in the comment.
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n ATTACHMENT Page 5
- (12) Section (IV)
Describe measures which assure that materials,' parts
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and equipment which are standard, commercial (off-the-shelf), or which have been previously ' approved -
for a different application are reviewed for suit-ability prior to selection.
1 Position:
Section IV.l.H, Page 61, has been revised to require that the suitability of commercial grade material,.
parts and equipment be reviewed by engineering and the results of this review be documented.
(13) Section (V)
Section V.1 needs to be clarified in the area of timeliness. 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.
Position:
Section V, " Procurement Control" describes the methods used for review, approval and release of procurement documents and the requirements.for review and approval of contractors' quality assurance programs. Normally, the contractors' quality assurance program is approved prior to placement of the purchase order; however, these are exceptions to this practice permitted.
Section V.l.M, page 70, address the need for emergency procurements.
In this case, the item, when received, is held as nonconforming until approvals of the pro-curement documents have been obtained, including accep-tance of. the contractors' QA program.Section V.2.R, page 79, describes an alternate method of controlling purchased materials wherein Receiving Test Inspection j
is performed before the materials are released.
(14) Section (V)
On Page 79, Item I states that contractors must be 1
evaluated at least once every five years to remain on the Contractor's Classification List. Please ' provide a commitment to meet the staff position relative to the requirements of Section 3.4.2 of ANSI N45.2.12, Draf t 3, Revision 4 (February 1974) which follows:
i 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.
In lieu of routinely conducting an annual reaudit of each active supplier, a formal evaluation of -
the supplier is performed each year after the j
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, 1
i history of performance of product and/or servica, and
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ATTACHMENT Page 6 effectiveness of implementation of the supplier's QA program.
The annual assessment shall consider the complexity of the component concerned and the degree of the quality and process control required by the supplier's effort. As a result of this evaluation, suppliers requiring a formal reaudit are identified. Regardless of the results of the evaluation, suppliers will be reaudited every three years.
Position:
Section V.2.I, Page 76, has been revised to identify the CPUN position relative to annual eva'.uations and auditing of contractors.
(15) Seccion (VIII)
Describe measures which cssure that correct item identification is verified and documented prior to release for fabrication, assembling, shipping, and installation.
Position:
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 fo. verification and documentation of the item identification prior. co release.
(16) Section (VII)
Describe measures which assure that special processes are performed using written process sheets (or equivalent) with recorded evidence of verification.
Position:
Section VII C requires that special processes be performed in accordance with qualified written procedures by qualified personnel.Section VII I requires that when.special processes are performed, they be performed using written and qualified procedures, they be performed by qualified personnel and records be maintained to demonstrate that the qualifications and certifications are current.Section IV.l.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.
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At tachment Page 7 (17) Section (VI)
Please clarify item I on Page. 84 as to the prerequisites for an inspector to sign and date the authorization for work to proceed beyond a hold point.
Position:
Item I, Page 83, has been revised to provide the requested clarification.
(18) Section (VI)
Please clarify the last sentence in item J on Page 84 to indicate that the " pre-established requirements" are the original design and inspection requirements or acceptable alternatives.
Position:
Item J Page 83 has been revised to provide the requested clarification.
(19) Section (VI)
Describe measures which assure that provisions are established for indirect control by monitering, processing methods, equipment, and-personnel if direct inspection is not possible.
Position:
The following sentence has been added - to iten C, Page 82:
"In the event direct inspection is not possible or prsetical, surveillance of the activity will be performed by means of monitoring processing' methods, equip-ment and personnel."
(20) (App. B)
Item VI B on Page 126 indicates that the Nbnager-Operational Quality Assurance concurs with maintenance, modification, replacement and repair procedures "on a sarpling basis".
Please identify what personnel, knowledgeable in QA, reviews all of these procedures to determine the need for: (a) inspection; (b) identi-i fication of inspection personnel; and, (c) documenting j
inspection results. This review should not be made on a sampling basis.
l Position:
Page 6 of Appendix B has been revised to delete 4
"on a sampling basis".
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Attachment-Page 8 (21) Section (VI)
Please provide Jersey Central Power & Light Company's position on the attached "QA Branch Interpretation on Calibration Accuracy Requirements".
Position:
Section VI.4.B (page 88) has been revised to incorporate requirements consist with "QA Branch Interpretation on Calibration Accuracy Requirements".
3 (22) Section (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.
o Position:
Sections IX. A and ;IX.C, Page 96, have been revised to -
require that handling, storage, shipping,. cleaning,.
packaging,' and -preservation of materials be performed by suitably trained individuals.
(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; and (5) includes signature approval of the disposition.
Position:
Section XI of the OQA Plan has been revised to delete the use of Job Orders for identification and control of nonconformances. This section of the Plan now identifies that the methods utilized for identifica-r' tion and control of nonconformances include: (1) Non-l conformance and Corrective Action Reports; (2) Audit Findings; and, (3) Reportable Occurrences.Section XI.C identifies that each of these methods is managed -
j by means of administrative control procedures and that each of these procedures includes the specific requirements for: (1) identification and documentation of the noncompliance, etc. through (7) preparatian of records.
Each of these administrative procedures.also contain the specific requirements for signature approval of the disposition, corrective action and followup.
Further, Section Xl.J and Appendix B further clarifies the responsibilities for control of nonconformances.
(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 limiting in that all nonconformances should be prope,rly documented in accordance with appropriate procedures,.
Please clarify. Also, for off-site ~ work, describe p
T Attichment P:ga 9 measures which assure that nonconformance reports dispositioned " accept as is" or " repair" are made part of the inspection records, forwarded with the hardware, and reviewed by Jersey Central Power & Light Company.
Position:
Section XI M, Page 106, has been revised to clarify this position.
(25) Section (XI)
Describe measures'which assure that conditions adverse to quality (such as nonconformances, failures, malfunctions, deficiences, deviations, and defective.
material and equipment) are evaluated to determine the need for corrective action to preclude repetition.
Position:
The measures, which assure that conditions adverse to quality are evaluated, are addressed in Section XI H.
(26) Section (X)
Describe measures which assure that sufficient records are maintained to provide documentary evidence of the quality of items and of the activities affecting quality.
Position:
This item is addressed in our commitment to ANSI N45.2.9, Page 54.
(27) Section (XII)
Part B of Section XII states that external audits are controlled by the procurement control section of the Operational Quality Assurance _ Plan. This implies that the commitments of Section XII of 'the Plan do not apply to external audits. Please clarify.
Position:
The last sentence of Section XII B, Page 107, has been deleted to clarify the requirements.
i (28)~Section (XII)
Describe measures which assure that audits are regularly sche'duled on the basis of the status and safety importance of the activities being performed, that audits are performed in the areas where the requirements of Appendix B to 10CFR Part 50 are being implemented, and that audits include the safety-related activities associated with:
a.
Operation, maintenance and modification.
b.
The preparation, review, approval, and control of designs, specifications, procurement documents, instructions, procedures, and drawings.
c.
Receiving and plant inspections.
d.
Indoctrination and trcining progrars.
e.
The implementation of operating and test-procedures.
f.
Calibration of measuring and testing equipment.
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Attachment Page 10 Position:
Please refer to Pages 107 and 108, Items A,C,D,F, and G.
These items address the scheduling or audits.
Item A also requires that each element of the Operational Quality Assurance Program be audited at least once every two years. These elements include, among other things, maintenance and nodifi-cation,Section IV of the QA Plan; preparation review, approval, and control design specifications,Section IV of the QA Plan; the preparation, review, approval, and control of procurement -documents,Section V of.the QA Plan; instructions, procedures, and drawings, in various sections of the QA Plan; receiving inspection,Section V of the QA Plan; plant inspection,Section VI of the QA Plan; indoctrination and training programs,Section III of the QA Plan the implementation of test procedures,Section VI of the QA Plan; and calibration of measuring and test equipment,Section VI.4 of the QA Plan. The other areas you mentioned, operation and indoctrination and training programs, are audited in accordance with our commitments in Chapter 6 of the Operating Technical Specifications. See Section XII.M of the QA Plan, Page 109.
(29)Section XII)
Describe measures which assure that audit data are analyzed and the results, which indicate quality trends and the effectiveness of the QA program, are reported to management for review and assesscent.
Position:
Please refer to Section XII.D, Page 107 of the QA Plan for clarification.
(30) Section (IV)
Describe measures which assure that plant modifications are reviewed by qualified personnel to assure inclusion
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of appropriate fire protection requirements. These reviews should include items such as:
Verifying adequacy of wiring isolation and a.
cable separation criteria, b.
Verifying appropriate requirements for room isolation (sealing penetrations, floors, and i
other fire barriers).
Position:
Section IV F Pages 60 and 61, has been revised to incorporate the following requirement:
"Among other things, satisfactory. design control, requires that -fire protection design criteria be included in the design and a design verificatice be perforned. This is factored into the design like all other design considerations."
Attachment Page 11 (31) Section (X)-
Describe measures which assure that instructions and procedures for design, installation, inspection, test, maintenance, modification and administrative controls are reviewed te assure the proper inclusion of fire protection requirements such as precautions, control of ignition sources and combustibles, provisions for backup fire portection of the activity requires disabling a fire protection system, and restriction on material substitution unless specifically permitted to design and confirmed by design review.
Position:
The Operational Quality Assurance Plan covers this subject by virtue of the fact that we have administrative controls which include fire protection. The specific requirements regarding ignition sources, etc., are.
considered in the procedures. Fire protection precautions ara covered in Installation Specifications; if fire protection retardant or special material is 'specified substitutes are not permitted without engineering review.
Plant installation and construction procedures are written and reviewed with fire protection requirements in mind.
(32) Section &I)
Describe measures which assure that penetration seals are installed and fire retardant coatings are applied by trained personnel using approved procedures.
Position:
This. item has been covered by the addition of Section-X.1.R, Page 100 (Note: Section X.1.R of Revision 3 has been deleted and replaced by the new section).
(33) Section (VI)
Describe measures which assure that QA/QC verifies testing of fire protection systems and verifies that test personnel are effectively trained.
Position:
The requirement for inspection and surveillance of activities associated with Fire Protection Systems are controlled by Sections VI and X.1.0 and in the detailed implementing procedure and instructions.
In addition,Section III requires that each Director mantain a training program to ensure proper training and qualifica-tions of their personnel. This includes the QA/QC p.
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Attachment Page 12 (34) Section (IV)
Part 6 of Regulatory Guide 1.143 of July 1978 concerns independent verification of design and procurement documents.
Item L on Page 64 of the Operational Quality Assurance Plan indicates that an independent design review or design verification is not required for the Quality Group D Augmented portion of the Plan. Please make this item appli-cable to Group D or justify not doing so.
Position:
The letter "D" designating the ' applicability to Quality Group D Augmented has been added to Section IV.1.L (Page 61).
(35)
The QA program requirements of 10CFR Part.71
" Packaging of Radioactive Material for Transport and Transportation of Radioactive Material under Certain Conditions" applies to each person authorized by the Commission to receive,-possess, use or trans-fer licensed materials if he delivers such materials in accordance with 10CFR 71.12 to a carrier for transport or transports such materials outside the 4
confines of his plant or other place of use.
Pursuant to 10CFR 71.51, the licensee must establish, maintain and execute a QA program for its shipping.
activities. This QA program applies to the design, f abrication, assembly, testing, use (preparation ' of packages for shipment) and maintenance, and is to satisfy each of the applicable criteria specified in Appendix E "QA Criteria for Shipping Packages of
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Radioactive Material" to Part 71.
Since Appendix E of Part 71 is substantively the same as Appendix B to Part 50, Paragraph 71.51(d) allows use of a Commission approved QA program based upon applicable criteria of 10CFR Part 50 Appendix B with regard to transport packa ge s.
Although the regulations provide for acceptability of tae Part 50 QA program, an application must be filed with the Transportation Branch, NMSS, committing the applicant to apply the previously approved Appendix B QA program to the applicable transportation activities of the licensee.
With regard to activities related to packaging and transport of radioactive materials at the Generation Division of JCP&L, as described in your Operational QA Plan, control of the radioactive material is not ef fectively transferred to another licensee (the packages are loaded by JCP&L under their facility licenses).
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Attachment Page.13 Thus, deliverirg the material to a carrier for transport remains the responsibility of JCP&L.
JCP&L' then must conduct their activities in accordance with Part 71.
The proposed _limita-tions as described by JCP&L for their transpor-tation activities (last paragraph, page 4,-Rev. 2) in the QA Plan eliminate most, if not all, of the 18 criteria of Appendix B of 10CFR Part 50 or Appendix E of 10CFR Page 71 and are, thus, not acceptable.
Position:
The porti:n of the OQA Plan " Scope", which discusses the program requirements applicable i
to packaging, handling, and transportation of radioactive materials (pages 4 and 5), have been revised :o clarify our position on this subject.