ML20065G218

Rev 7 to Gpu Nuclear Operational QA Plan

ML20065G218
Person / Time
Site:	Oyster Creek, Three Mile Island
Issue date:	04/30/1994
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20065G207	List: ML20065G200 ML20065G218
References
1000-PLN-7200.0, NUDOCS 9404120225
Download: ML20065G218 (95)

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GPU NUCLEAR OPERATIONAL Numbsr Nuciocr QUAR.zTr xSSuRxNCE PtxN 1000-PtN-72OO.01

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

7 Applicability / Scope This Plan Has GPUNC-Wide Applicability Responsible Office Except TMI-2 6160

'This Document is within QA Scope I YES NO Effective Date Safety Reviews Required I YES NO 4/30/94 List of Effective Pages Page Rev. Page Rev. Page Rev. Page Rev. Page Rev.

No. No. No. No. No. No. _E2A No. No. No.

1.0 7 21.0 7 41.0 7 61.0 7 81.0 7 2.0 7 22.0 7 42.0 7 62.0 7 82.0 7 3.0 7 23.0 7 43.0 7 63.0 7 83.0 7 4.0 7 24.0 7 44.0 7 64.0 7 84.0 7 5.0 7 25.0 7 45.0 7 65.0 7 85.0 7 6.0 7 26.0 7 46.0 7 66.0 7 86.0 7 7.0 7 27.0 7 47.0 7 67.0 7 87.0 7 8.0 7 20.0 7 48.0 7 68.0 7 88.0 7 9.0 7 29.0 7 49.0 7 69.0 7 89.0 7 10.0 7 30.0 7 50.0 7 70.0 7 90.0 7 11.0 7 31.0 7 51.0 7 71.0 7 91.0 7 12.0 7 32.0 7 52.0 7 72.0 7 92.0 7  ;

13.0 7 33.0 7 53.0 7 73.0 7 93.0 7 '

14.0 7 34.0 7 54.0 7 74.0 7 94.0 7 15.0 7 35.0 7 55.0 7 75.0 7 95.0 7  !

16.0 7 36.0 7 56.0 7 76.0 7 l 17.0 7 37.0 7 57.0 7 77.0 7 18.0 7 38.0 7 58.0 7 78.0 7 19.0 7 39.0 7 59.0 7 79.0 7 20.0 7 40.0 7 60.0 7 80.0 7 Signature Concurring Organizational Element Date originator /s/ Director, Nuclear Safety Assessment 4/6/94 Concurred By /s/ Dir-Services 4/6/94

/s/ Dir-Nuclear Assurance 4/5/94

/s/ Dir-OCNGS 4/7/94 l Dir-TMI

/s/ Dir-Technical Functions 4/6/94 l /s/ Corporate Counsel & Secretary 4/5/94

/s/ Corporate Procedure Administrator 4/5/94

/s/ _

Responsible Technical Reviewer 4/4/94 Approved By (( [h2 G4f fice of the President-

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i GPU NUCLEAR OPERATIONAL QUALITY Numb 2r Nucbcr ASSURANCE PtAN 1000-PtN-7200.01 Title GPU Nuclear Operational Quality Assurance Revision No.

Plan 7 TABLE OF CONTENTS Pace TABLE OF CONTENTS 2.0 DOCUMENT HISTORY

4.0 INTRODUCTION

6.0 ,

1.0 ORGANIZATION 1.1 Office of the President 7.0 1.2 Directors THI and Oyster Creek 7.0 1.3 Director Technical. Functions 8.0 1.4 Director Administration and Finance 8.0 1.5 Director Nuclear Safety Assessment 9.0 1.6 Director Nuclear Assurance 10.0 1.7 Director Services 10.0 1.8 Corporate Counsel and Secretary 10.0 1.9 Minimum Qualifications of Assessment and Inspection Personnel 11.0 2.0 QUALITY ASSURANCE PROGRAM 2.1 General 12.0 2.2 Scope 12.0 2.3 Graded Approach 14.0 2.4 Three-Level Assurance 14.0 2.5 Operational QA Plan Control 16.0 2.6 Quality Assurance Program Review 17.0 2.7 Indoctrination and Training 18.0 2.8 Classification Process 18.0 2.9 Regulatory Commitments 19.0 2.10 Safety Reviews 19.0 2.11 Responsibilities 20.0 3.0 CONTROL OF DOCUMENTS AND RECORDS 3.1 Policies, Plans, Instructions, Drawings, Specifications 23.0 3.2 Document Control 25.0 3.3 Records 27.0 4.0 DESIGN CONTROL 4.1 General 30.0 4.2 Requirements 30.0 4.3 Responsibilities 31.0 ,

5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement 33.0 5.2 Identification and Control of Materials, Parts and Components 38.0 F

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GPU NUCLEAR OPERATIONAL QUALITY Numb;r Nuclecr ASSURANCE PtAN 1000-PtN-7200.01

l Titler GPU Nuclear Operational Quality Assurance Revision No.

j Plan 7 5 TARLE OF CONTENTS PJL92 4

l 6.0 CONTROL OF STATION ACTIVITIES i

i 6.1 General 41.0 6.2 Control of Inspections 41.0

6.3 Control of Special Processes 44.0 4

6.4 Test control 45.0 6.5 Control of Measuring and Test Equipment (M&TE) 47.0 6.6 Handling, Storage and Shipping 49.0 6.7 Inspection, Test and Operating Status 51.0 6.8 Housekeeping and Cleanliness 52.0

, 6.9 Equipment Control 53.0 6.10 Control of Construction, Maintenance 54.0 (Preventive / Corrective) and Modifications 6.11 Control of Surveillance Testing and Inspection 57.0 j 6.12 Radiological Control 58.0 7.0 CONTROL OF RADIOACTIVE WASTES OR MATERIALS 7.1 General 60.0 7.2 Requirements 60.0 7.3 Responsibilities 61.0 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 2 8.1 General 63.0 1 8.2 Requirements 63.0

, 8.3 Responsibilities 65.0 ,

j 9.0 CONTROL OF TRAINING 4 I 9.1 General 67.0 i

9.2 Requirements 67.0 3 9.3 Responsibilities 68.0 l

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10.0 ASSESSMENT 10.1 General 69.0 10.2 Audits 69.0 10.3 Requirements 69.0 10.4 Monitoring 71.0 10.5 Responcibilities 72.0 APPENDICES: 73.0 Appendix A - Comparison Chart of Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards 74.0 Appendix B- Nuclear Safety Assessment Department Document Review Requirements 75'.0 Appendix C - NRC Regulatory Guide Commitments and Exceptions 79.0 Appendix L - Terms and Definitions 91.0 I

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l GPU NUCLEAR OPERATIONAL QUALITY Numbar l hhEI2k3[2I ASSURANCE PLAN 1000-PLN-7200.01 l i

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Title GPU Nuclear Operational Quality Assurance Revision No. 1 Plan 7 DOCUMENT HISTORY PREPARED BY EFFECTIVE REVIEWED BY:

REVISION DATE DESCRIPTION OF CHANGE APPROVED BY 4 07/18/90 Section 1.0 was revised as a result of R. S. Markowski corporate and QA Department reorgani- J. P. Heil zations and; to reduce the level of P. R. Clark organizational detail; the activities of " security screening" and " fitness-for-duty" were identified as activi- J ties within the scope of the Plan in I Section 2.2.2; Sections 6.5, 6.5.2.1, 6.5.2.3, and 6.11.2 were changed to clarify the post-maintenance and in- ,

stallation testing responsibilities of l the Site Services Division; editorial j changes were made to Sections 6.6 and 7.2.1; Section 6.11.2.1(a) has been revised to indicate that the Oyster Creek and TMI Divisions are respons- 4 ible for the technical as well as the administrative procedures associated with maintenance; the commitment to Regulatory Guide 1.8 has been modified to establish experience requiremer.ts j needed for eligibility for the NRC i licensed reactor and senior reactor operator positions; all affected see-tions have been revised to incorporate the revised Divisional titles to be consistent with Section 1.0; from Section 7.0 text was advanced one page due to changes in Section 6.0.

5 01/21/91 The purpose of this revision was to M. Heller further clarify the text associated J. P. Heil with Reg. Guide 1.8 that was inserted P. h. Clark by Rev. 4 (i.e. item 2 in Appendix C, .

Part 2). The commitment relies on the l text of 10CFR55.

6 The option of GPUN to design, fabri- R. S. Markowski cate, assemble, test and modify the G. Boyle packaging used for the transport of P. R. Clark radioactive waste which exceeds the limits specified by 10CFR71.10 was deleted (Section 7.2.1.f and g).

The phrase " radioactive waste" and term "radwaste" were replaced with the phrase " radioactive waste or material", where it makes editorial sense to do so, throughout the text of 7.0 - 7.1.3, 7.2.1.h, 7.2.3 and 7.3.1.a were editorially changed to be consistent with the new phrase. The phrase "...of packaging to be utilized to ship..." has been inserted in 7.1.2.

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GPU NUCLEAR OPERATIONAL QUALITY Numbar Nuciocr ASSURANCE pun 1ooo-PLN-noo.01

Title:

GPU Nuclear Operational Quality Assurance Revision No.

Plan 7 DOCUMENT Fi; TORY PREPARED BY:

EFFECTIVE REVIEWED BY:

REVISION DATE DESCRIPTION OF CHANGE APPROVED BY:

7 4/30/94 The purpose of this revision is to reflect the changes of a GPUN reorganization of Assessment / Oversight functions. Some editorial changes of wording and correction of typographical errors were also included. The major organizational changes consist of combining QA Audits and Monitoring with Independent Safety Review to create a new Nuclear Safety Assessment organization. Procurement QA is combined with the Procurement Engineering funtion and is part of the Plant Engineering organizations.

Quality Control is being renamed Quality Verification and reassigned to the Maintenance organizations.

NDE/ISI Services is being reassigned to the Technical Functions -

organization.

Appendix B " Nuclear Safety Assessment Department Document Review Requirements" was changed to clarify the wording and more accurately describe the document review program implemented.

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GPU NUCLEAR OPERATIONAL QUALITY Number Nucbcr ASSURANCm PtAN 1000-PtN-7200.01

Title:

GPU Nuclear Operational Quality Assurance Revision No.

Plan 7 INTRODUCTION GPU Nuclear (GPUN) is responsible for the operation and maintenance of TMI and Oyster Creek Nuclear Generating Stations. The Quality Assurance Plan contained herein describes the formal and comprehensive plan which has been established to ensure compliance with 10CFR20; 10CFR50, Appendix B; 10CFR71, Subpart H; and applicable Regulatory Guides during the operation of TMI and Oyster Creek. Activities related to TMI Unit 2 PDMS are addressed in the PDMS Quality Assurance Plan.

This Operational Quality Assurance Plan is formatted in such a manner as to provide all users with a functionally useable document. It describes how this Plan is to be functionally implemented with due regard to the safety and health of the public and the personnel on site. This Plan identifies organizations responsible for the implementation of the Quality Assurance Program (Section 1.0) and an overall description of the Program (Section 2.0). The remaining sections are structured in a functional manner. The requirements for administrative controls are generic and apply to all subsequent sections. Sections 8.0, 9.0 and 10.0 again apply to all activities within the scope of this plan.

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ENucirr GPU Nuctran OPenATIONAt QUALITY ASSURANCE PLAN Number 1000-PLN-7200.01

Title:

1.0 Organization Revision No.

7 1.0 ORGANIZATION l

The GPUN Organi stion Plan is the highest tiered document that assigns l major functional responsibilities. Implementing documents ansign more l specific responsibilities and tasks and define the organizational inter-face (s) involved in conducting activities and tasks within the scope of this Plan. The requirements of this Operational Quality Assurance Plan apply to those organizations and positions which manage and perform activities within the scope of this plan. This section provides a summary of the organizational units and functions which perform activities within I the scope of this plan.

l The GPUN organization is structured on the basis that the attainment of l the objectives of this plan relies on those who manage, perform, and l support the performance of activities within the scope of this plan; and, i assurance of this attainment relies on those who have no direct responsi- l bility for managing or performing the activity. '

The organizations responsible for the conduct, support and assurance of operation, maintenance, modification, repair, in-service inspection and refueling of the nuclear generating stations are illustrated in the following controlled documents: the GPUN Organization Plan (1000-PLN-1000.01) and the applicable technical specifications. The GPUN organization Plan sets forth specific responsibilities with regard to the requirements of this Plan and implementing procedures.

1.1 Office of the President The Office of the President-GPUN has the overall responsibility for the establishment, implementation and evaluation of the effectiveness of the Quality Assurance Program applicable to THI, and Oyster Creek. This responsibility is administered through his management staff, including:

Director - TMI Director - OCNGS Director - Technical Functions Director - Administration and Finance Director - Nuclear Safety Assessment Director - Nuclear Assurance Director - Services Corporate Counsel and Secretary  ;

These OP management staff members give their full support to the require-ments set forth in this plan ensuring full compliance by their respective staffs.

1.2 Director-THI and Ovster Creek Each of the Directors of the nuclear generating stations reports to the l Office of the President. They are each responsible to operate, maintain, and refuel their respective generating station in a safe, reliable and efficient manner in accordance with corporate policies and all applicable laws, regulations, licenses and technical requirements. The Divition Director-TMI and Oyster Creek are the senior GPUN representative at their attes and as such assure consistent implementation of policies and procedures at the plant and off-site facilities in their respective area.

The Directors through the applicable Maintenance Directors have responsi-btitty for Anspection activities (excluding NDE) related to maintenance l and modtiteation activities. The Directors through the Plant Engineering l Directors also have responsibility for procurement activities as specified in Section 5.0.

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I Mkf GPU NUCLEAR OPERATIONAL QUALITY ASSURANCE PLAN Numbar 1000-PLN-7200.01 Titles 1.0 Organization Revision No.

7 1.2.1 Maintenance Director The Maintenance Director through the Quality Verification Manager at each site is responsible fort

a. Taking appropriate action when warranted to control and prevent the use of nonconforming materials or the continuance of nonconforming activities. This action will include as necessary stopping work, further processing, delivery or installation.

b. Providing for review of selected design and engineering documents within the scope of this Plan for inclusion of appropriate hold and witness points and quality requirements.

c. Providing and implementing an inspection program (excluding receipt inspection and NDE) to assure maintenance and modification activities are carried out consistent with all applicable laws, regulations, regulatory commitments, licenses, corporate policies, and other requirements.

d. Other responsibilities as detailed in this Plan.

1.2.2 Plant Encineerino Director The Plant Engineering Director is responsible fort

a. Providing and implementing a receipt inspection program to assure that incoming materials, parts, and components are of sufficient quality to meet all applicable requirements.

b. Providing for selected review of procurement documents within the scope of this Plan.

c. Other responsibilities as detailed _in this Plan.

1.3 Director - Technical Functions The Director-Technical Functions reports directly to the Office of the President. The Director's Quality Assurance plan responsibilities consist of providing the requisite engineering and technical support to: maintain the design basis of the nuclear plant; maintain the configuration control documents; conduct operating experience assessment; provide nuclear fuel management; provide core performance monitoring; staff.and direct shift technical advisors; monitor and analyze the technical performance and reliability of systems and components; provide selective review of plant operations and testing procedures, and associated training; provide technical control and coordination of plant modifications; conduct startup testing; coordinate and implement In-Service Inspection and Non-Destructive Examination services; and provide a weld program and repair program.

1.4 Director - Administration and Finance The Director-Administration and Finance reports directly to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of establishing, maintaining, and implementing procurement and warehousing plans and/or procedures.

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l ENucle r GPU NUCtzAn orraATzoNAL QUALITY ASSURANCr PLAN Nu b=r 1000-PLN-7200.01 Title 1.0 organization Revision No.

7 1.5 Director - Nuclear Safety Assessment The Director-Nuclear Safety Assessment has the functional authority, independence and responsibility to assure the effective implementation of i and compliance to the Quality Assurance Program. Consistent with this I responsibility is the authority to render interpretations in writing on l those activities to which this plan applies and the extent to which the plan applies to those activities.

I The Director-Nuclear Safety Assessment reports directly to the office of l the President and has direct unencumbered access to the Directors of each j of the nuclear stations with regard to activities affecting quality. This i reporting relationship has been established to provide sufficient i independence from the influence of costs and schedules to be able to effectively assure conformance to Quality Assurance Program requirements.

The Director-Nuclear Safety Assessment has no duties or responsibilities unrelated to the responsibilities contained in this document that would prevent the required attention to quality assurance matters. The Director-Nuclear Safety Assessment has the authority and responsibility l to:

a. Develop and administer the maintenance of the operational Quality Assurance Plan and the Nuclear Safety Assessment Department l procedures required to assure that all GPUN activities provide the required high degree of safety and reliability,

b. Assess, audit, and monitor the conduct of GPUN activities to assure l that they provide the required high degree of safety and reliability and are carried out consistent with all applicable laws, regu-i lations, regulatory commitments, licenses, corporate policies and l l other requirements. I

c. The establishment and conduct of nuclear safety review and assess-ment activities which include those of the nuclear stations' Independent on-site Safety Review Group and the General office l Review Board. '

d. Identify and report nonconformances as they may exist. Initiate, recommend or provide solutions through designated channels. Verify implementation of resolutions as required.

e. Initiate stop work or unit shutdown recommendations when warranted by a safety concern and obtain unit shutdown with appropriate upper-management concurrence,

f. Provide for a review of selected documents which prescribe methods l for activities and quality requirenents for items, parts and '

materials within the scope of thir Plan.

g. Provide for a review for concurrersee of Contractor and Vendor Quality Assurance Programs as specified in Section 5.1.2.3.

h. Direct and manage the Nuclear Safety Assessment Department.

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i. Provide a working interface and line of communication with other divisions and other appropriate industry and regulatory. groups for all program matters.

j. Provide indoctrination, certification, and/or training programs for the Nuclear Safety Assessment Department.

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E Nuclecr CPU NUCtzAa OPsaATzONAL QUALITY ASSURANCs PLAN N=wr 1000-PLN-7200.01

Title:

1.0 Organization Revision No. ,

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k. Assure QA program indoctrination of appropriate personnel outside of ,

the Nuclear Safety Assessment Department is provided.

1. Immediately notify the Office of the President and appropriate Unit I Director of any significant quality related problem or deficiency.

m. Perform assessments on a planned and periodic basis to compre- )

hensively determine the effectiveness of the program anc'its  !

in.plementation; and, detect adverse trends that may be present.  !

n. Issue periodic reports to the Office of the President and Division Directors on the effectiveness of implementation of activities  ;

within the scope of this plan. j l

o. Provide for and maintain records generated by the Nuclear Safety l Assessment Department until turnover to the record storage facility (s) for storage.

1.6 Director - Nuclear Assurance The Director-Nuclear Assurance reports directly to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of establishing, maintaining and delivering training and education programs sufficient to assure iafe, reliable and efficient operation; establishing, implementing and maintaining radiological controls, radio-logical environmental monitoring, emergency preparedness, medical exami-nation, and fitness for duty testing plans and procedures consistent with Corporate Policies and all applicable laws, regulations and licenses.

1.7 Director - Services The Director-Services reports directly to the Office of the President.

The Director's Quality Assurance Plan responsibilities consist of estab-lashing, maintaining and implementing plans and procedures for managing, planning and conducting maintenance, repair and construction activities; constructing plant modifications as assigned, and conducting maintenance, repair, and construction activities as assigned in accordance with Corporate Policies and all applicable laws, regulations, licenses and technical requirements; the establishment, maintenance, and implementation of plans and procedures for nuclear plant security, security screening, safeguard contingencies and plant security guard force training and qualification consistent with Corporate Policies and all applicable laws, regulations, licenses and technical requirements; the maintenance of the nuclear plants' operating licenses and the establishment, maintenance, and implementation of fitness for duty plans and procedures consistent with Corporate Policies and all applicable laws, regulations and licenses; coordination of the safety review process.

1.8 G2rporate Counsel and Secretary The Corporate Counsel and Secretary reports directly to the Office of the President. The Corporate Counsel and Secretary's Quality Assurance Plan responsibilities consist of establishing, implementing and maintaining document distribution and record retention programs and facilities; records management, coordinate administration of the GPUN policy and procedure system.

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Nucle r cpu NuctEAR oPEaATIoNAL Nu bor 1000-PLN-7200.01 QUALITY ASSURANCE PLAN

Title:

1.0 organization Revision No.

7 1.9 Minimum Oualifications of Assessment and Insoection Personnel The Director-Nuclear Safety Assessment shall have, as a minimum a baccalaureate degree in Engineering or Science, with at least fifteen (15) years of technical experience including ten years of managerial /

supervisory experience in operational, technical support and/or quality assurance activities associated with nuclear power plants. At least one year of this experience shall be in a Nuclear Assessment / Oversight .

organization or a special training program approved by the office of the President will be completed within six months of assuming the position.

Additionally, the Director-Nuclear Safety Assessment must be knowledgeable i in operating license conditions, other regulatory requirements and I commitments, plans, procedures and quality and technical standards.

Each Manager, Nuclear Safety Assessment who reports to the Director-  ;

Nuclear Safety Assessment shall have an academic degree in engineering or l a physical science field and 5 years of professional level experience in '

the nuclear power field-including technical supporting functions or 10 )

years of appropriate experience.

Nuclear Safety Assessment Department Assessment Managers are required to have a degree in Engineering or Science and 3 years experience in a position (s) having responsibility for the supervision and performance of operational, technical and/or assessment / oversight activities. The degree requirement associated with these management positions may be waived for personnel with demonstrated exceptional capability and a minimum of ten (10) years of equivalent experience.

For personnel performing inspection, examination, and special processes, the qualification criteria shall be delineated to the techniques of inspection or items being inspected and the technical abilities of the person being certified will be consistent with the assigned tasks (e.g.,

electrical inspection, mechanical inspection, etc.).

The qualification requirements and experience levels for other key Nuclear Safety' Assessment Department personnel are such as to assure competence commensurate with the responsibilities of and the Regulatory Guides associated with the activities performed by the position.

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E Nuslocr GPU NuCtr^R OPraATIONAt QUALITY ASSURANCE PLAN Numdar 1000-PLN-72OO.01

Title:

2.0 Quality Assurance Program Revision No.

7 2.0 OUALITY ASSURANCE PROGRAM 2.1 General This Operational Quality Assurance Plan is the highest GPUN document which provides the generic and some specific requirements and methods to control activities. The term " Program" as used herein includes this Plan and the approved documents which are used to implement this Plan. This Plan is implemented through such approved documents.

The GPUN Quality Assurance Program has been established to control the activities performed by GPU Nuclear within the scope of this Plan. This

, control is exerted primarily through the provision of and ccapliance with implementing documents and assurance that such documents are adequate and consistently used.

Adherence to the requirements of this Plan is mandatory for all GPUN organizations and for all external organizations providing items, parts, materials or conducting activities which are within the scope of this Plan.

The purpose and intent of this Plan is to establish the principles which, when implemented, will provide the level of management control and assurance which is appropriate for each item, part, material or activity within the scope of this Plan. It is recognized that the extent of management control and assurance to be applied varies with different items and activities, and the extent of applicability of this Plan will differ from item to item and activity to activity.

The Director - Nuclear Safety Assessment is authorized and responsible for l determining if and to what degree this Plan applies to a given activity I and/or task. In those situations where interpretation of the Plan is required to provide clarity or resolve disagreements, such interpretations shall be documented and approved by the Director - Nuclear Safety Assessment.

2.2 Scone The scope of the GPUN Operational Quality Assurance Plan includes but is not limited to items and activities related to safe nuclear plant operation, protection of personnel and protection of the public. To ensure consistency in identifying those items, parts, materials and activities within the scope of this Plan, a classification process has been developed and documented. This process relies on the use of the terms " nuclear safety related," " regulatory required," and "QA Plan Scope."

2.2.1 Items within the scope of this plan are designated as " nuclear safety related" or " regulatory required." The definitions of these terms are provided in Appendix D of this Plan. A Quality Classification process for items has been developed. This classification process oroduces a Quality Classification List which identifies the permanent plar.t structures, systems, and components that are within the scope of this Plan and their specific classification. New items to which this Plan applies shall be added to the Quality Classification List subsequent to their installation.

The classification of parts, materials and consumable items (such as chemicals, radwaste liners, diesel fuel, etc.) and the technical and quality requirements will be specified, documented and approved as part of ,

the procurement process. l 1

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t Title 2.0 Quality Assurance Program Revision No.

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{ This Plun may be applied to items, parts, and materials other than those designated as " nuclear safety related" or " regulatory required" as specified by GPUN management.

l 2.2.2 Activities within the scope of this plan are designated as within "QA Plan ,

r scope." Activities that are within the scope of this Plan are those J l directly related to nuclear and radiological safety and protection of the public and are delineated below.

1 Support activities within the scope of this Plan are system / component /part l classification, operating experience assessment, design, maintenance of j environmental and fire protection qualification, nuclear fuel management,  !

procurement, fabrication, handling, shipping, storage, cleaning, electing, l Installing, testing, repairing, training, welding, in-service inspection, I heat treatment, document control, records management, security screening  !

and fitness for duty.

1 Operational activities within the scope of this Plan are normal, abnormal l and emergency operation, chemistry control, core performance monitoring, i shift technical advice, equipment control, surveillance testing, in-  !

service testing, maintenance, housekeeping, fire protection, security, l radiological controls, radiological environmental monitoring, radwaste I preparation for shipment, radwaste shipment, fuel handling / refueling, technical specification compliance, and emergency preparedness.

Assurance activities within the scope of this Plan are audit, document review, inspection, non-destructive examination, monitoring, surveillance, and safety review. Assurance activities are performed by individuals who are not directly responsible for managing or performing the work or activity. Nuclear Safety Assessment Department personnel, who are independent of the organizations performing the work or activity, perform periodic assessments of the assurance activities not performed by the Nuclear Safety Assessment Department to assure effectiveness and adequacy.

The term document review as used in this document pertains to reviews l conducted by the Nuclear Safety Assessment Department as detailed in Appendix B.

The above activities are controlled through the use of approved documents which are, as a minimum, consistent utth the requirements of this Plan, the unit Operating License, specific Regulatory Guides to the extent lasted and committed to in Appendix C of this Plan, the Final Safety Analysis Report, and other regulatory requirements and commitments. Those approved documents which spectitcally prescribe the methods to implement this Plan will be identified as prescribed by 3.2.2.2 of this Plan.

A specific task (s) associated with the above activities will be classified as within scope of this Plan or not depending upon:

a. Statements within the text and the regulatory guides identified in Appendix C of this Plan;

b. The relationship of the task (s) to the safe operation of the nuclear plant;

c. The relationship of the task (s) to the protection of personnel from the effects of radiation;

d. The relationship of the task (s) to protection of the health and safety of the public; reartAttp7 13.0

ENusirr GPu nuCtEAa cPraAT2ONAt QUALITY ASSURANCE PLAN Number lOOO-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No.

7

e. The relationship of the task (s) to regulatory requirements and commitments, and;

f. Other factors as may be specified by GPUN management.

2.3 Graded Approach The extent to which the requirements of this Plan and its implementing documents are applied to an item will be based upon the following:

a. The effect of a malfunction or failure of the item on nuclear safety or safe plant operation.

b. The design and fabrication complexity or uniqueness of the item.

c. The need for special controls, and surveillance or monitoring of processes, equipment and operational activities.

d. The degree to which functionality can be demonstrated by inspection or test.

e. The quality history and degree of standardization of the item.

The quality requirements for items within the scope of this plan shall be established using approved procedures based on the " General Logic Considerations" listed in the Appendix to ANSI N45.2.13-1976. Quality requirements will be established by the responsible department and subject to audit / review by the Nuclear Safety Assessment Department consistent with Appendix B of this plan.

The extent to which the requirements of this plan apply to activities will be based as a minimum on operating license conditions and other plans previously submitted to the NRC for approval, other regulatory commitments as may have been made associated with activities, the text of this Plan, the unit's technical specifications, and Appendix C of this Plan. Such other plans or regulatory commitments include but are not limited to those associated with emergency planning, physical plant security, safeguard contingency planning, radiological controls, radiological environmental controls, fire protection, in-service inspection, in-service testing, licensed operator qualification and requalification, process control, off-site dose calculation, shift technical advisor training, environmental qualification of electrica: equipment, security guard training and qualification, etc.

2.4 Three Level Approach GPUN is committed to a comprehensive assurance process consisting of a three level approach to assure satisfactory, consistent and complete implementation of this Plan.

2.4.1 Level I - Activities at this level include inspections, checks, or tests performed for the purpose of establishing acceptance and/or verification of items parts, materials and activities within the scope of this Plan.

Level I activities are performed by the Operations, Plant Maintenance, Radiological Controls, Site Services, Technical Functions, and contractor personnel. Examples of Level I activities include:

Ope r a t ion s . Plant Maintenance, Site Services, Radiological Controls, and Startup and Test personnel perform activities such as tests, calibration of instruments, radiation surveys,. analyses of samples, valve line-ups, etc.

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Nuabcr oPu NuCtEAa oPERATIoNAt QUALITY ASSURANCE PLAN Number 1000-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No.  !

7 Site Services; and, Plant Maintenance / Material personnel perform checks, inspections and/or tests of modification, replacement, repair  !

and/or overhaul activities.

Quality Verification personnel performing inspections of modifications and maintenance activities. -l l

i Engineering personnel conducting receipt inspections of incoming '

. materials / items.

• Contractors performing inspections as applicable to their scope of work.

Engineering personnel periodically performing walkdowns, observations, measurements, etc. to revalidate the physical or functional configuration or condition of plant systems or components.

Technical Functions Personnel performing NDE on components after repairs or modifications.

In all cases, the inspection, checkLand testing activities are performed I by individuals who are knowledgeable of the activity being performed and are qualified to perform the work (refer to Section 6.2). ' Checklists, weld history records, travelers, reports, etc., are used for documenting the results of the activity and for providing a record of the performance of the activity.

2.4.2 Level II - The activities at this level are primarily those of survey, surveillance, monitoring, and document review and are performed as deemed necessary by the Nuclear Safety Assessment Department. The level of surveillance or monitoring applied is consistent with the importance of the item to safety and the extent of administrative controls utilized for the Level I activity.

At this level, procedures and instructions are established and' surveillance and/or monitoring records will be completed and maintained. .

Such surveillance / monitoring normally includes observation of tests and l inspections, 6bservation of-selected operations,-review of records, verifications of test reports, and direct inspection on a spot-check basis. The organizations performing this activity have the levels of I authority, the lines of internal and external communication for management i direction, and properly trained personnel for implementation of these '

activities. l

~

2.4.3 Level III - The purpose of this level of activity is to assure, through a l l

comprehensive program of review, assessment and audit, that all l organizations conducting activities and/or tasks within the scope of this plan are properly satisfying all the requirements of the operational <

Quality Assurance Program.

l At this level, procedures and instructions are established, including the use of comprehensive checklists or detailed reports for documentation of ,

the third-level activity.

OCAP1,AU.P7 15.0

Nusbcr GPU NucttAR OPzRATIONAt QUALITY ASSURANCE PLAN Numb =r 1000-PLN-7200.01 l

Title:

2.0 Quality Assurance Program Revision No. )

7 i l

l For audits, the program requirements of ANSI N45.2.12 shall be satisfied.

Lead auditors shall be utilized who are qualified to the requirements of ANSI N45.2.23. Additional technical support personnel, from areas with administrative reporting outside the function that is being audited, will be utilized as Audit Program Management deems necessary. The organization performing this audit activity has sufficient authority, independence and lines of internal and ex* rnal communications to obtain the necessary access to management to etaduct the review and audit, resolve any issues which may arise from the review and audit and secure additional technical support for the performance of audits as may be required.

2.5 Operational Ouality Assurance Plan Control 1

This Plan is authorized by the Office of the President and requires tha't  ;

the appropriate levels of management, as designated herein, implement the Program. This Plan is controlled to ensure that only the latest approved revision is implemented. This Plan is implemented through approved documents (refer to'Section 3.0).

Appendix A provides a correlation of the sections of this Plan with the requirements of 10CFR50 Appendix B; 10CFR71, Subpart H; ANSI N45.2; and ANSI N18.7.

)

1 With the exception of Organization, Section 1.0 and QA Program, )

Section 2.0, each section of this Plan contains three major subsections: l 1

General - A summary description of the general approach of GPUN with l regard to controlling the specific subject (s) of the section. It I characterizes the intent of the section by stating the overall objectives  !

to be met and/or the results to be achieved.

Peauirements - A description of the requirements applicable to the specifte sub]ect of the section.

Responsibilities - Identification of those organizations and their responsibilities relative to the specific subject of the section.

2.5.1 Acoroval This Plan shall be originated by the Director-Nuclear Safety Assessment and be approved by the Office of the President after being reviewed for concurrence by the following:

Corporate Counsel and Secretary Director - Administration and Finance Director - Services Director - Nuclear Assurance Director - OCNGS Director - TMI Director - Technical Functions Corporate Procedure Administrator 2.5.2 Pevisions The Director - Nuclear Safety Assessment, with the assistance of the L& censing and Regulatory Affairs Director, shall, for each revision to this Quality Assurance Plan, determine if the changes reduce or do not reduce the commitments in this plan previously accepted by the NRC.

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c

Nusbcr GPu NUCtrAR OPzRATIONAt QUALITY ASSURANCE PLAN Numb.r 1000-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No.

7 Revisions to this Quality Assurance Plan that do not reduce the commitments in this Quality Assurance Plan previously accepted by the NRC shall be originated by the Director - Nuclear Safety Assessment and l approved by the Office of the President with the concurrence of any  !

Division Director affected. The Cover Page containing the approval and concurrence signatures of the Office of the President and the Division I i Directors shall be retained. Revisions of this type do not require approval by the NRC prior to implementation, but must be submitted to the .

NRC at least annually. The Document History page will be utilized to identify such changes. ,

Revisions of this Quality Assurance Plan that reduce the commitments in this Quality Assurance Plan previously-accepted by the NRC shall be submitted to the NRC and receive NRC approval prior.to implementation. i Such revisions shall be regarded as approved by the NRC upon receipt of a letter to this effect from the appropriate reviewing office or 60 days after submittal to the NRC whichever comes first. The submittal of the  !

revision to the Quality Assurance Plan must' include all pages affected by that change and must be accompanied by a transmittal letter ider.tifying the change, the reason for the change, and the. basis for concluding that the revision continues to satisfy 10CFR50,. Appendix B and to provide a suitable level'of control. The letter need not provide the basis for changes that correct spelling, punctuation, or editorial items. A copy of this letter must be maintained as a facility record for three years.

Revisions of this type shall be originated by the Director - Nuclear Safety Assessment, approved by the Office of the President with the concurrence of the Division Directors as indicated by their signatures on a revised Cover Page.

2.5.3 Distribution copies of the Operational Quality Assurance Plan may-be distributed as

" Controlled" or " Uncontrolled" in accordance with the requirements established in Section 3.

2.5.4 Effective Date of Imolementation Changes to this Plan shall be incorporated in the implementing documents witnin 60 days of the issuance date of the Plan unless an interim action plan is defined and approved-by the Director - Nuclear Safety Assessment.

l 2.6 Ouality Assurance Proaram Review The effectiveness of the QA Program and its implementation is periodically reviewed by various organizations at various levels and the results of i these reviews are documented in reports to the Division Directors and the Office of the President for evaluation'and corrective action as required.

The effectiveness of the QA Program is evaluated and reported by the Nuclear Safety Assessment Department through the surveillance, monitoring and auditing functions. Other divisions provide additional information/

evaluations as requested.

In addition to the reviews and evaluation performed by the Nuclear Safety l Assessment Department, the Office of the President shall have, at least once per year, an independent assessment performed of the QA Program implementation to ensure that the QA Program is effective in ensuring that regulatory requirements and commitments; and, GPUN policies are met. This assessment may be performed utilizing an safety review group, an independent consultant, representatives of other utilities and/or his own staff. Ary corrective action which may be deemed.necessary as a result of these assessments shall be formally identified and tracked through ,.

resolution.

}j 3I ec AptArt n > 17.0 'i

l I

Nu3bcr GPu suCttha oerRhTIoNat QUALITY ASb?RANCE PLAN Numb =r 1000-PLN-7200.01 l

l

Title:

2.0 Quality Assurance Program Revision No.

l l

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2.7 Indoctrination and Training Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are required to be j established and maintained. A Training department is established and l

staffed and is responsible for planning, scheduling, developing and providing training to GPUN personnel. The indoctrination and training programs are established by on-site and by off-site organizational units responsible for the performance or verification of activities within the scope of this Plan. These training programs are developed, implemented and maintained as delineated in Section 9.0 of this Plan.

The proficiency of personnel shall be evaluated; and, measures to maintain proficiency shall be implementea through either retraining, reexamining and/or recertifying.

When certification is required, a certificate (s) shall delineate the specific function (s) the indi'ridual is certified to be able to perform and the criteria used to certify the individual for that function (s).

l 2.8 Classification Process Activities that are within the scope of this Plan and general criteria for further classification of tasks associated with these activities are identified in Subsection 2.2.2 of this Plan. Subsection 2.3 provides further basis for grading the extent of application of the requirements of this Plan to activities. Documents that prescribe methods for implementing the requirements of this Plan shall be marked as specified by 3.2.2.2.b of this Plan.

l Items within the scope of this Plan shall be classified and identified as

" Nuclear Safety Related" or " Regulatory Required." A procedure (s) shall be prepared to establish, implement and maintain a classification process for items. This procedure (s) and changes thereto shall be reviewed for concurrence by the Director - Nuclear Safety Assessment or designee prior to issuance. l Structures, systems and components, but not parts thereof, shall be identified on a Quality Classification List (QCL). A QCL shall be established and maintained, by Technical Functions, for each plant. The classification of structures, systems and components will be subject to independent design review as part of the classification process.

Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts and materials that perform or contribute to the performance of a nuclear safety-related or regulatory required function are within the scope of this Plan and classified similarly as the component of which it is a part.

For procurement of spare or replacement parts which are of a different classification, the classification will be determined by Plant Engineering or Technical Functions. The determinations will be documented, retained and subject to review and audit by the Nuclear Safety Assessment Department. Refer to section 5.0 for specific requirements.

l OCAPLA!1.P7 18.O l

Nuslocr GPU NUCotAR OPcRATroNAt QUALITY ASSURANCE PLAN Number-1000-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No.

7 2.9 Reaulatory Commitments Records of regulatory requirements and commitments are maintained by Licensing-and Regulatory Affairs. Appendix C herein lists those Regulatory Guides which contain specific quality assurance requirements with the stated GPUN position, exceptions and/or clarifications provided.

These must be complied with in conjunction with this QA plan. Appendix C will be revised, as necessary, to reflect any change in the.GPUN commitment to the Regulatory Guides.

2.10 Safety Reviews The safety review program involves four major elements:

2.10.1 The first element of the safety review program consists of technical review and, as necessary, an independent safety review.

The technical review is a thorough review conducted by someone other than the individual who prepared the work. This review is performed by a qualified Responsible Technical Reviewer on documents and substantive revisions of documents as specified by the GPUN Review and Approval Matrix.

The independent safety review is an independent review of documents and substantive revisions of documents as specified by the GPUN Review and Approval Matrix. It-includes a review of a safety evaluation. This review is conducted by a qualified Independent Safety Reviewer (ISR) on safety evaluations associated with documents and substantive revisions-to documents as specified by the GPUN Review and Approval Matrix. The ISR shall not have direct responsibility for the activity reviewed.

2.lC ~. The second element of the safety review program is the Independent On-Site Safety Review Group (IOSRG). An IOSRG shall be located at each generating

-station. The IOSRG has no-line responsibilities or line_ functions and is devoted solely to safety matters. It is independent of the plant staff and reports off-site to the Director-Nuclear Safety Assessment. Each IOSRG will consist of a Manager, Nuclear Safety Assessment who reports to the Director-Nuclear Safety Assessment'and a minimum staff of three members, each of whom shall have an academic degree in engineering or a physical science field and 3 years of professional level experience in the nuclear power field including technical supporting functions or 8 years of appropriate experience. Credit toward experience will be given for-advanced degrees on a one-to-one basis up to a maximum of two years. The educational and experience requirements for the Manager-Nuclear Safety Assessment are contained in Section 1.9.

Each IOSRG shall have access to the unit and unit records as necessary to perform its evaluations and assessments. Based on its reviews, the IOSRG shall provide recommendations to the management positions responsible for the areas reviewed. IOSRG reports of evaluations and assessments shall be prepared, approved, and transmitted to the Director-Nuclear Safety Assessment and the management positions responsible for the areas l reviewed.

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l hlLl3k)((f GPU NUCLEAR OPERATIONAL Numbar l QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No. 1 7 )

1 2.10.3 The third element of the Safety Review Program is the Nuclear Safety Assessment Department headquarters staff, in conjunction with the site l based Nuclear Safety Assessment Department personnel, who assess all aspects of GPUN activities as well as developments elsewhere in the nuclear industry. This provides for an overview of activities affecting or potentially affecting safety. This is a broadly defined responsibility which involves no specific tasks thus making it possible to assess the adequacy of the entire Safety Review Program and identify areas for improvement.

2.10.4 The fourth element of the safety review program is the General Office Review Board. This is a group of senior level individuals with diverse backgrounds and extensive nuclear experience. The Board reports to and takes general direction from the Office of the President but has direct access to the Chairman of the Board and the Board of Directors. Its charter is broadly defined to encompass all matters potentially affecting nuclear safety (including management related aspects) so as to foresee potentially significant nuclear safety and radiation problems. The i Nuclear Safety Assessment Department provides staff support to the General i Office Review Board.

2.10.5 An Ombudsman is provided by the Nuclear Safety Assessment Department at each site. This individual is accessible on a confidential basis to anyone in the company having a nuclear or radiation safety concern he or she considers is not being adequately addressed. The Ombudsman is I empowered to investigate such matters, identify any needed action and seek its resolution. The Ombudsman will reply to the individual who raised the ,

matter.

J 2.11 Pesponsibilities 2.11.1 Office of the President The Office of the President - GPUN is responsible to regularly ascess the scope, status, adequacy and compliance of the Quality Assurance Program to the requirements of 10CFR50, Appendix B, 10CFR20, and 10CFR71, Subpart H.

This assessment shall be the combined result oft j

a. Review of audit reports, periodic status reports, etc. on the effectiveness and implementation of the Quality Assurance Program. I 1

b. Performance at least once a year of an independent assessment of the effectiveness of the Quality Assurance Program as specified in Section 2.6.

2.11.2 Director - Nuclear safety Assessment The Director-Nuclear Safety Assessment has overall responsibility for establishment and content of the CPUN Operational Quality Assurance Plan; providing periodic status reports to the Office of the President on the effectiveness and implementation of the Quality Assurance Program; verifying through assessment, monitoring, audit and document review that adequate implementation of the QA program occurs and when needed effective corrective action is taken to resolve deficiencies.

Procedures will contain requirements for when independent concurrence with the cicsecut cf corrective actionc is required. Refer to Section 8.0 of this Plan.

e c o un . " 20.0 ,

Nu bcr GPU NuCtEAR oPERATzoNAL QUALITY ASSURANCE PLAN Numbar 1000-PLN-7200.01

Title:

2.0 Quality Assurance Program Revision No.

7 The Director-Nuclear Safety Assessment is responsible for ensuring that this Plan is modified and updated as standards, regulations, requirements, and experience dictate. Proposed' revisions to this Plan may be suggested by GPUN personnel by submitting the request, in writing, to the Director-Nuclear Safety Assessment for review and action.

2.11.3 Director - Technical Functions The Director-Technical Functions is responsible for development and j maintenance of the Quality Classification List.

2.11.4 Director - Services The Director-Services through Licensing and Regulatory Affairs is responsible for providing GPUN documented positions and interpretations on all other regulatory guides not contained in Appendix C of this. Plan as ,

may be required.

2.11.5 GPUN - Manacement Management personnel in each division are responsible for the .

j implementation of the Quality Assurance Program by their division, I

department or group, including the development and implementation of approved documents; and, the training.and indoctrination of their

. personnel associated with those of their activities within the scope of j this plan.

Management. personnel in each division are responsible for the conduct of the technical and independent safety reviews within their division, department or group. This includes the identification and qualification of personnel as Responsible Technical Reviewers and Independent Safety Reviewers; the review and approval of documents within their functional area of responsibility as assigned by the GPUN Review and Approval Matrix and other activity as may.be required to implement Technical Specifications Appendix A, Section 6.5, requirements.

Management personnel in each division are responsible to take positive action to evaluate and correct nonconformances identified in the conduct of those of their activities within the scope of this Plan. This responsibility to correct includes adverse trends as may be identified by appropriate analysis.

2.11.6 External oraanizations Suppliers who provide items, parts, materials, consumables, and/or services which are within the scope of this Plan shall have a QA Plan and implementing procedures appropriate for the items, parts, materials, consumables, and/or services. The supplier's QA program shall be subject i.

to review for concurrence by the Director-Nuclear Safety Assessment or his l designee. The extent to which the supplier's QA program will be applied will be specified by procurement documents.

2.11.7 Resolution of Discutes and Escalations Disputes involving quality arising from a difference of opinion shall, if possible, be resolved at the level at which such disputes occur. If this is not possible, the difference of opinion shall be escalated through su pervi sory/ management levels until resolution is achieved.

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3 ccan.m . o 21.0 r

.n __ 4 .,, ., _ , _----M' "-T f

ENuslocr cru NuCtran oera^TIoNAL QUALITY ASSURANCE PLAN Numbar lOOO-PLN-72OO.Ol

Title:

2.0 Quality Assurance Program Revision No.

7 The Director-Nuclear Safety Assessment shall make the decision on matters l related to if and to what degree this Plan applies to activities, quality requirements, and verification and acceptance to established requirements.

The Director-Technical Functions shall make the decision on matters related to classification of items, parts, materials, and technical requirements or design changes.

The Director-Nuclear Safety Assessment shall be responsible for evaluating deficiencies noted by the Nuclear Safety Assessment Department for trends.

Significant or repetitive failures to comply with administrative, technical, operational or this Plan's requirements will be further evaluated to determine the safety significance of the condition. In these cases, management of the organization shall be notified of the condition and shall be afforded an opportunity to take appropriate corrective action. If this action is not taken, a Stop Work Notification will be issued.

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CW W'*7 22.0 w

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NbI' l'N" A~ GPU NUCLEAR OPERATIONAL ggALITY ASSURANCE PLAN Numbar 1000-PLN-7200.01

Title:

3.0 Control of Documents and Records Revision No.

7 3.0 CONTROL OF DOCUMENTS AND RECORDS 3.1 Plans, Procedures, Instructions, Drawinas, specifications 3.1.1 General Activities which are within the scope of this Plan shall be prescribed by approved documents of a type appropriate to the circumstances. These documents shall be complied with in the performance of the activity or changed prior to proceeding with the activity. These documents typically include but are not limited to those termed plans, procedures, instructions, directives, drawings and specifications. All personnel shall be indoctrinated in the use or content of such documents prior to commencement of the activity.

3.1.2 Pecairements Documents which prescribe the methods for the performance of activities and/or tasks within the scope of this Plan shall be consistent with the requirements of this Plan. These Plan requirements include compliance with the text of this Plan and the Regulatory Guides and ANSI standards to the extent delineated in Appendix C. To accomplish this, these documents shall:

a. Define the responsibilities and authorities of personnel performing the activity.

b. Describe interfaces between GPUN organizational units and/or external organizations that participate in or are affected by the conduct of the ar.tivity.

c. Prescribe actions to be taken or the results to be achieved which are consistent with the requirements of this Plan,

d. Include quantitative (such as dimensions, tolerances, and operating limits) and/or qualitative (such as workmanship) acceptance criteria sufficient for determining that such activities have been satisfactorily accomplished.

e. Identify and specify the content of records to be generated in conducting the activity.

f. Include references as needed to implement the activity. When such references are utilized, the specific requirements of the references which are applicable shall be toentified or incorporated into the document.

g. De approved and concurred with by responsible personnel prior to the initiation of the activity.

1

h. Be distributed in a controlled manner to preclude the use of obsolete  ;

documents and with sufficient number of copies to assure availability '

to responsible personnel.

OCAPLAI.R7 23.0

Nusbcr cpu NuCtsAR oPrRATloNAt QUALITY ASSURANCE PLAN Number lOOO-PLN-7200.01 .

l

Title:

3.0 Control of Documents and Records Revision No.

7 ,

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Reviews of such documents shall be conducted by the Nuclear Safety Assessment Department. The timing and scope of document reviews shall be ,

as detailed in Appendix B. These reviews are conducted to independently verify that the document is/was appropriate for use. .These reviews i assure, as a minimum, that the reviewed document.is consistent with the pertinent QA Plan requirements; contain inspection and verification requirements where applicable; contain quantitative and/or qualitative ,

acceptance criteria; contain clear definition of the extent of documenting l results of completed actions when required; and, has been (after j implementing approval) prepared and reviewed consistent with QA Plan 4 requirements.

Other organizations (such as Quality Verification) review selected l documents for the opportunity to include inspection points and proper .

inclusion of QA requirements.

Documents which prescribe methods for implementing this Plan shall be I followed as written or changed. The requirements for use of such documents and how to proceed if such documents cannot be complied with as written shall be prescribed by procedure (s).

Plans, procedures, and instructions shall be revised as needed to ensure that such documents can be implemented as written. Appropriate documents shall be thoroughly reviewed following plant transients,' incidents, and/or events and revised as needed. Such documents shall be reviewed by an individual knowledgeable in the area affected by the document (s) no less frequently than every two years to determine if changes are necessary or desirable. A revision of the document (s) may constitute the above review provided the results of the review are documented. I 3.1.3 Pesponsibilities  ;

t 3.1.3.1 Department Manacers t

The Director or Manager of each department performing activities within i the scope of this Plan is responsible for the preparation, approval and l implementation of documents which prescribe activities and/or tasks  :

necessary to effectively implement this Plan. This responsibility I includes ensuring that provisions-are made for interface controls for internal and external lines of communications among participating organizations and technical disciplines.

3.1.3.2 Nuclear Safety Assessment Department Nuclear Safety Assessment Department shall review those approved documents which prescribe the methods of complying with the requirements of this l Plan. Methodology for how the Nuclear Safety Assessment Department selects and conducts reviews is contained in Appendix B of this Plan.

Review requirements for procurement documents are contained in Section 5.

3.1.3.3 External oraanizations Those activities within the scope of this Plan which are performed by an external organization (s) shall be prescribed by approved documents (s).

The extent and type of such approved documents to be. utilized by the external organization shall be prescribed within approved procurement documents. Compliance shall be verified through the audit, source  !

surveillance, source inspection, monitoring and inspection programs. l 9

OCAPLAN.R7 24.O l

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E Nu310cr GPU uUCtEAR oPERAT2OnAt OUALITY ASSURANCE PLAN Nu m r 10cO-PLN-7200.01

Title:

3.0 Control of Documents and Records Revision No.

7 3.2 Document Control 3.2.1 General Document control procedures shall be established to control and coordinate the classification, review, approval, issuance, revision, and enange of approved documents which prescribe methods or provide the technical and/or cuality requirements for activities and items within the scope of this plan. These document control procedures shall ensure that such documents are reviewed for adequacy, approved for release and use, and distributed to the location where the activity is performed.

3.2.2 Recuirements 3.2.2.1 Written document control procedures shall be established to provide for the control of the following types of approved documents:

a. Operational Quality Assurance Plan, GPUN Organization Plan, GPUN Review and Approval Matrix, Quality Classification List, Environmental Qualification Master List (s), and Supplier Quality Classification List (s).

b. Plans, procedures, directives, and/or instructions as required to implement the provisions of this Plan and the Regulatory Guides to the extent delineated in Appendix C.

c. Nuclear Safety Assessment Department Plans, Procedures, and Standards,

d. Operating, Surveillance Testing, Refueling and Equipment Control Procedures and Instructions,

e. Maintenance Work Authorizing Documents, Procedures, Instructions, Vendor Manuals and Vendor Information.

f. Engineering Configuration Control documents which include safety analysis, safety evaluations, calculations, standards, <

specifications, system / modification design descriptions, design l reviews and/or verifications, drawings and lists. l l

g. Computer codes utilized for calculational tasks associated with activities within the scope of this Plan.

h. Engineering, Manufacturing, Construction, Modification, Installation, Welding, Test, Inspection and Nondestructive Examination Procedures, Instructions, Standards, and Specifications.

1. Procurement Documents, Specifications, and Contracts.

3 Final Safety Analysis Report (s), Pire Protection Plan (s), Fire Hazards Analysis Report (s), Emergency Plan (s), Security Plan (s),

Safeguard Contingency Plan (s), Guard Force Training and Qualification Plants) and Off-site Dose Calculation Manual (s).

k. Nonconformance, Deficiency and Deviation Reports or Requests.

1. Operat.n; and Special Orders.

m. Procurerent and Material Control Procedures and Instructions.

ccaptAri.r? 25.0 ,

NL8 h'>7"

' GPU NUCLEAR OPERATIONAL Numbar QUALITY ASSURANCE PLAN 2000-PLN-7200.01 Titles 3.0 Control of Documents and Records Revision No.

7

n. Radiological Control, Process Control, Radiological Environmental Monitoring, Radwaste Shipping and Chemistry Control Plans, Procedures, Instructions, Standards, and Specifications.

3.2.2.2 Procedures established for document control shall prescribe the following requirements:

a. Drawings, derign descriptions and specifications for items, parts, and materials designated as Nuclear Safety Related shall be marked as such.

b. Documents which prescribe how to perform activities within the scope of this Plan shall be marked as within "QA Plan Scope". These documents typically will be those termed plans, procedures, instructions, and directives. Specifications and drawings will be marked as stated in 3.2.2.2.a above,

c. Review and approval requirements for documents and their revisions shall be specified to ensure that adequate technical and quality requirements are incorporated prior to issue. Issuance requirements shall be specified to ensure adequate dissemination for use,

d. The organizations or positions responsible for reviewing, approving and issuing documents and their revision shall be specified.

e. Revisions shall be documented, approved, and issued prior to being implemented. Temporary changes shall be reviewed and approved consistent with Technical Specification requirements.

f. Revisions and changes shall be reviewed and approved by the same organizations that performed the original review and approval or by organizations designated by the originating organizations except for documents originated by organizations outside GPUN. In this case, GPUN may designate the review and approval organizations. Approved changes shall be promptly transmitted for incorporation into documents and obsolete or superseded documents shall be eliminated from use.

1

g. Document distribution shall be sufficient to assure that the l documents are readily available to responsible personnel prior to I commencement of work.

h. The user of approved documents is responsible for assuring that the l latest issue of the document is being used to perform work, thus i assuring that voided, superseded or cbsolete documents are not used.

Haster lists or indices which identify current revision status of approved documents will be maintained to assist users. In addition to master lists or indices, documents may be stamped " Controlled Copy". Holders of controlled documents or master lists are responsible for maintaining their assigned copies in a current status. Documents distributed and stamped as information only will not be considered to be current, and, as such, will not be used in performing an activity within the scope of tnis plan.

1. In the special case of documents containing information pertaining to plant security. provisions shall be made to prohibit unauthorized disclosure of certain safeguardc information. These provisions shall include adentification of the documents, restrictions on their distributton and storage in locked security storage containers.

OC A PLAll . P 7 26.0

n Nualacr GPU NuCttAR oPrRATloNAt QUALITY ASSURANCE PLAN Numbsr lOOO-PLN-72OO.01 Title 3.0 Control of Documents and Reccrds Revision No.

7 3.2.3 Responsibilities 3.2.3.1 Corporate Counsel and Secretary Responsible via the Information Resource Management Center Managers to establish and maintain approved documents to implement the GPUN Document Control Program and to develop and administer a corporate policies and procedures system.

3.2.3.2 Director - Nuclear Safety Assessment The Director-Nuclear Safety Assessment is responsible for the review of GPUN document control procedures and the evaluation of the overall document control system effectiveness through document review and audit.

3.2.3.3 All Functional Manaaers Responsible to provide specific document control procedures, as required, te implement the corporate document control policy. Responsible to enwure that documents are available when required; to properly review and approve documents such as procedures, instructions, specifications, drawings, etc.

to ensure that changes to documents are reviewed and approved by the same organization that performed the original review and approval of the document; to ensure that approved changes are promptly transmitted for incorporation into documents; to ensure that obsolete or superseded documents are eliminated from use.

3.3 Pecords 3.3.1 General Records related to items, parts, materials and activities within the scope of this plan shall be identified, reviewed, retained, and retrievable.

These requirements are imposed on all organizations performing activities within the scope of this plan. Records shall be described and controlled by approved written procedures or instructions. As a minimum, these procedures or instructions shall prescribe the method (s) for the identification, generation, collection, storage, maintenance, retention, and retrieval of such records.

3.3.2 Beauirements Approved documents shall be established for the identification, generation, collection, storage, maintenance, retention and retrieval of records and shall provide for the following minimum requirements:

a. Design specifications, procurement documents, and/or GPUN procedures shall specify the records to be generated, supplied and maintained by or for GPUN, including retention times. Typical records to be specified include operating logs, maintenance and modification procedures and related inspection results, reportable occurrences, inspection and verification procedures (excluding completed checklists when results are documented in a separate report), results of reviews, inspections, tests, audits, and material analysis; qualification of personnel, procedures, and equipment; other documentation such as calculations, computer codes, design verifications, drawings, specifications, procurement documents, calibration procedures and reports; nonconformance reports; l corrective action reports; and other records required by Technical - i s peci f ica t ion s .

i reat un P7 27.0 l

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Nuclacr GPU nuCtcAR oPERATIoNAt QUALITY ASSURANCE PLAN Nums,,

1000-PLN-7200.01 1

Title:

3.0 Control of Documents and Records Revision No.

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b. Sufficient records and documentation shall be maintained to provide evidence of the acceptability of items, parts, materials or activities within the scope of this plan. Inspection and test records shall contain the following where applicable:

1. Identification of the type of observation.

2. The date and results of the inspection or test.

3. Identification of any conditions adverse to quality.

4. Inspector or data recorder identification.

5. Evidence as to the acceptability of the results.

6. Action taken to resolve any discrepancies noted.

c. Record storage facilities shall be established and utilized to prevent destruction of quality records by fire, flooding, theft and deterioration by environmental conditions such as temperature or humidity in compliance with the standards, codes and regulatory guides endorsed in Appendix C of this Plan.

d. Interim storage provisions shall be established to properly maintain and protect records until they are permanently transferred to record storage facilities for retention.

e. All records shall be legible ir. original or reproduced form,

f. Provisions shall be provided to restore, reconstruct or replace records that are lost or destroyed.

3.3.3 Responsibilities 3.3.3.1 Director - Nuclear Safety Assessment The Director-Nuclear Safety Assessment is responsible for:

a. Reviewing procedures related to the identificatior, generation, )

collection, retention, storage, retrieval, and maintenance of I records. I

b. Establishing procedures and/or instructions for the identification, generation, collection, retention, storage, retrieval, and maintenance of records generated by the Nuclear Safety Assessment Department, until they are turned over for storage.

c. Performing planned and periodic audits to verify the adequacy and implementation of records requirements by both GPUN internal organizations and suppliers of services.

d. Performing source surveillance or source inspection when required to verify that required records have been generated and supplied with items, parts or materials.

rCAPtAM . P 7 28.0 d

l l

Nucirr ceu NUCtEAR oeERAT20 m QUALITY ASSURANCE PLAN n = *a r 1000-PLN-72OO.01 l

Title:

3.0 Control of Documents and Records Revision No.

7 l

1 3.3.3.2 GPUN Division Directors '

Each Division Director is responsible fort

a. The identification, generation, collection, maintenance, and storage of records in accordance with approved written procedures or instructions which conform to the requirements of this section until such time as they are transferred to the applicable Information Resource Management Center for storage.

b. Providing direction in approved documents to ensure the identification, generation and maintenance of records with sufficient detail to furnish objective evidence that activities within the scope

c. this Plan were conducted in compliance with this Plan and the standards, codes and regulatory guides endorsed by this plan.

3.3.3.3 Corporate Counsel and Secretary The Corporate Counsel and Secretary is responsible through the Information Resource Management Center Managers for:

a. The collection, maintenance, and storage of records in accordance with approved written procedures and instructions which conform to the requirements of this section,

b. Providing procedures and/or instructions which ensure the maintenance, storage and retrievability of records.

c. Establishing and implementing the CPUN Records Control System.

3.3.3.4 External Oraanizations Records generated by suppliers shall be controlled according to the supplier's or CPUN procedures until such time as they are turned over to GPUN for review, acceptance, and transmittal to the permanent records file. Purchased equipment records shall be retained by the supplier until the equipment is released for shipment at which time the records required by procurement documents are to be submitted to CPUN.

When required by the procurement documents, suppliers shall establish i procedures for the identification, generation, collection, storage, I maintenance, retrieval and/or transmittal of records. Implementation of l these procedures shall be assured by performance of source surveillance, l source inspection, monitoring and audits performed by the Nuclear Safety l l Assessment Department. '

l Records to be submitted with the shipment or retained by the supplier will j be specifically identified in procurement documents. If records are to be l retained by the external organization for CPUN, then the storage condition and retention period shall be specified in the procurement document (s). 1 These records will be reviewed by the Nuclear Safety Assessment Department j to provide the required degree of confidence in the adequacy of compliance of the supplier with the requirements of this section.

rearuur.n 29.0 ,.

Nu3tcr cpu NuctrAn oPEnATroNAL QUALITY ASSURANCE PLAN Numbar l IOOO-PLN-72OO.01 l

Title:

4.0 Design Control Revision No.

2  !

4.0 DESIGN CONTROL 1

4.1 General Measures shall be established and documented to assure that the applicable specified design requirements, such as design bases, regulatory requirements, codes and standards are correctly translated into l specifications, drawings, procedures or instructions. These measures I shall include provisions to assure that appropriate quality standards are I specified and included or referenced in design documents for design of systems and structures.

4.2 Eeouirements Design control measures require that:

4.2.1 The organizational structure be defined, and authority and responsibility of personnel involved in preparing, reviewing, approving and verifying design documents be delineateo.

4.2.2 The design bases, safety analysis, regulations, codes and standards and Plant Technical Specifications including all effective amendments will be utilized in, reviewed for revision, and revised, as necessary, during the design process.

4.2.3 The materials, parts and processes selected by design are reviewed to assure that they are suitable for the intended application, including compatibility of materials, accessibility for in-service inspection, maintenance and repair, ALARA considerations, personnel safety, fire hazards analysis, and quality standards. The review will also evaluate suitability with regard to human factors which may affect safe operation and the suitability of commercial grade materials, parts and equipment to the application.

4.2.4 Internal and external design interface controls, procedures, and lines of communication among participating design organizations and across technical disciplines are established and described for the preparation, tuview, approval, release, distribution, and revision of documents involving design interfaces. l I

4.2.5 l Errors and deficiencies in approved design documents, including design l methods (such as computer codes) that could adversely affect items and activities within the scope of this plan shall be documented, and action shall be taken to assure that these errors or deficiencies are corrected.

In addition, any errors or deficiencies resulting from the application or use of the design documents shall be identified and corrected. i l

4.2.6 Deviations in specified quality standards shall be identified and l procedures shall be established to assure their resolution and control.

4.2.7 Review of commercial grade items for suitability of use in structures, systems or components within the scope of this Plan shall be conducted prior to such use.

l 4.2.8 Design verification methods (design review, alternate calculations or qualification testing) shall be established and completed prior to turnover for operation.

1 f

ecsnsu.n 30.0 .

Nusber CPU NUCtraa oPrRATIoNat QUALITY ASSURANCE PLAN numbe r-lOOO-PLN-7200.01 l

Titles 4.0 Design Control Revision No.

7 l

4.2.9 Design verification procedures shall be established which assure the <

following: '

a. The verifier is qualified and is not directly responsible for the design.

b. Verification, including approved field changes, shall be complete prior to turnover of the component or system to operations.

c. The responsibilities of the verifier, the areas and features to be verified, and the extent of documentation'of the verification shall be specified.

4.2.10 When verifications are to be accomplished solely by tests

a. Prototype, component or f eature testing shall be performed prior to installation of the equipment, or prior to the point when the installation would become irreversible.

b. Verification by test shall be performed under conditions that simulate the most adverse design conditions as determined by analysis.

4.2.11 Procedures shall be established to ascure that computer codes, and changes thereto, are verified, certified and controlled to prevent unauthorized changes.

4.2.12 Changes to approved engineering documents, including field changes, will be subject to design control measures. Design changes shall be reviewed and approved by the organization responsible for the original design or by another organization with comparable expertise designated to review and approve changes.

4.2.13 Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, design '

descriptions, and drawings, including flow diagrams, piping and instrument diagrams, system diagrams, facility drawings showing equipment locations and site arrangements.

4.2.14 Measures, which include procedure changes, shall be provided to assure that responsible plant personnel are made aware of design changes and/or modifications, which may affect the performance of their duties. l 4.3 Pespons ibil it ies 4.3.1 Director-TM!, and Ovster Creek The Directors-TMI, and Oyster Creek are each responsible through their respective Plant Engineering Directors for the implementation of design control measures in accordance with approved Technical Functions j procedures.

l 4.3.1.1 Maintenance Director The applicable Maintenance Director through the Quality Verification l Manager is responsible for providing review of design and engineering cocu.wents te assure that appropriate quality requirements have been included, k

OCAPLAI3.P7 31.0

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l l

Nucirr cpu NuCLEAn oPEaATzoNAL Nu-b=r QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Titles 4.0 Design Control Revision No.

7 4.3.2 Director-Technical Functions The Director-Technical Functions is responsible for the development and implementation of the design control measures utilized by Technical Functions and Plant Engineering departments.

4.3.2.1 The Director-Technical Functions is responsible through the Director-Engineering Projects and the Director Engineering and Design for coordination and direction of plant modification projects which are outside of the scope of Plant Engineering. To fulfill these responsibilities, the Director-Engineering Projects and/or the Director-Engineering and Design will:

a. Control and coordinate the activities of all contractors with design responsibility.

b. Coordinate the efforts of the System Engineering Department as may be needed to support design related projects.

c. Provide for the review and approval, as appropriate, of baseline design documents such as selected design criteria, flow diagrams, system descriptions, arrangement drawings, one-line diagrams and logic diagrams.

d. Ensure that applicable design criteria documents and specifications, and changes thereto are reviewed for inclusion of quality requirements.

4.3.2.2 The Director-Technical Functions, through the Director-Nuclear Analysis and Fuels, is responsible for:

a. Providing conceptual and analytical engineering service to other engineering groups as required.

b. Providing technical administration of nuclear fuel-related engineering activities,

c. Providing direct technical support to the Plant operating staff by providing Shift Technical Advisors.

4.3.2.3 The Director-Technical Functions is responsible for providing detailed design and drafting services and for the preparation and maintenance of the Quality Classification List (QCL).

4.3.2.4 The Director-Technical Functions is responsible through the Director-Engineering and Design for providing centralized technical capabilities in conventional engineering disciplines as required to produce engineering documents for plant modifications and for the technical performance of components and systems within the nuclear plants.

4.3.3 Director-Nuclear Safety Assessment The Director-Nuclear Safety Assessment is responsible to perform planned and periodic audits of responsible design organizations to verify the effective implementation of design control measures and the technical adequacy of engineering results produced.

ocAPLE.R7 32.0

.. = _ . _ - . .- _ ~ - - -. .

Nusbcr GeU NUCtEAR OPEaATzONAt QUALITY ASSURANCE PLAN Nu-bsr lOOO-PLN-72OO.01

Title:

5.0 Procurement and Material Control Revision No.

7 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 control of Procurement 5.1.1 General 5.1.1.1 Procurement of items, materials, parts,.consumables, equipment, and services which are within the scope of this plan shall be performed in accordance with approved documents which shall establish methods for preparation, review, approval, and control of procurement documents.

These methods shall ensure that technical, quality and regulatory requirements and regulatory commitments applicable to the procurement are met as.a minimum. These methods shall ensure that procurement sources are evaluated and confirm that the activities of consultants, vendors and contractors, and purchased items conform to procurement document requirements. The programs of all participants shall be in accordance and/or compatible with the applicable requirements of this GPUN Operational Quality Assurance Plan.

5.1.1.2 The general and specific requirements for.the Quality Assurance Program of all suppliers including their subsuppliers supplying items, materials parts, consumables, equipment'or services, or within the scope of this plan shall be prescribed by procurement documents. These quality program, requirements shall be consistent with Section 2.3 of this Plan.

5.1.1.3 Quality Assurance Plan measures shall be applied with a graded approach to the procurement of new and spare parts, replacement parts, commercial grade items and consumables, Procurement of spare or replacement parts for structures, systems and components shall be subject to current QA program controls and to codes, standards, technical and quality ret ;raments equal to, or better than, original, as may have.been 4 superst ded or upgraded by regulatory requirements or commitments. As a '

minimum, when documented quality and technical requirements are not available, then the procurement of spare parts, replacement parts, and consumables within the scope of this Plan shall be in accordance with an approved specification or the use justified by a documented engineering determination. The.use of commercial. grade items in nuclear safety-related applications shall'be controlled as specified by Section 5.1.2.4 of this Plan.

5.1.2 Pecuirements 5.1.2.1 Procurement Documents The requirements for the preparation, review, approval and control of procurement documents shall be prescribed in detailed procedures. These procedures shall prescribe requirements to ensure-that procurement documents:

a. Specify the technical and quality assurance requirements commensurate with regulatory requirements and commitments and this Plan.

b. Require applicable quality assurance requirements to be imposed on subvendors and subcontractors.

c. Specify or reference design basis technical requirements, including applicable regulatory requirements and commitments, material and component identification requirements, drawings, specifications, codes and standards, test, calibration, and inspection requirements, handling, storage and shipping requirements, and special process instructions. '

etapt.Am it 7 33.0

1 a

Nucbcr GPu uUCtEAR oeERArzoNAL QUALITY ASSURANCE PLAN wumber 1000-PLN-7200.01 Title 5.0 Procurement and Material Control Revision No.

7 i

d. Identify the documentation to be prepared, maintained, and submitted for review, approval and record information as applicable.

4

e. Include an identification of those items and activities within the scope of this plan.

5 f. Identify those records which vendors or contractors shall retain, i maintain, and control; and those which vendors or contractors shall i deliver prior to use or installation of the item.

. g. Include right of access to vendors or contractors and subtier vendor 4

and contractor facilities and records when required for source inspection and/or audit.

i

h. For spare or replacement parts, contain technical requirements at least equivalent to those used for the original procurement.

i. Include the provision that suppliers shall refrain from implementing

, procedures which require owner approval prior to obtaining such approval.

). Require design organizations performing design activities for GPUN to have and implement quality programs which include design control provisions equivalent to those provided in this plan.

k. Identify the programs, procedures, activities or conditions that '

require GPUN approval and/or release.

i Measures shall be established for the review, approval,-and release of

'J procurement documents and subsequent revisions. The reviews shall assure the inclusion of the applicable technical, quality, regulatory, and

, administrative requirements in procurement documents prior to their use.

Review of' procurement documents shall be documented to provide objective evidence of their approval prior to release.

5.1.2.2 Oualification and Selection of External Oroanizations 4

Evaluations of prospective suppliers shall be conducted and documented to t

demonstrate qualifications based upon one or more of the following j criteria

. a. Review of performance histories which provide records of the

j. supplier's previous capability to provide similar products or services.

I d

b. Review of the external organization's capability to comply with the CPUN Quality Assurance Program, as applicable to the items or

services to be supplied.

d

c. A pre-award survey of the external organization's facilities and Quality Assurance program to determine his capability to meet the technical and quality requirements of the procurement document (s).

Procedures shall be established to prescribe the evaluation and selection of external organizations. Contracts or purchase orders for items, materials, parts, consumables, equipment or services within the scope of this plan shall be awarded either to:

i e External organizations whose Quality Assurance Program has been revtewed and accepted by GPUN as being commensurate with the equipment i

, or services to be provided, or ..

- t 3

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Nu:Iscr GPU NUCtEAR oPERATIoNAt

-QUALITY ASSURANCE PLAN number

-1000-PLN-7200.01 Title 5.0 Procurement and Material Control Revision No.

7

• The external organization will be required, by procurement documents, to work under the direct control of the GPUN Quality Assurance Program. 1 In these instances, the supplier will not be required to have a (

separate quality assurance program.  !

When GPUN's acceptance of an external organization *s quality assurance program is required, it shall be reviewed for concurrence by GPUN prior to initiation of the activity affected by their program. .

In the case of " commercial. grade items" the procurement process shall be l controlled so that the' dedication process described in 5.1.2.4 shall be  ;

met. j i

5.1.2.3 Manufacturino Assurance '

Heasures shall be established to provide control of manufacturing .

activities of suppliers. These methods shall be described in detailed written procedures.

.The attributes of the manufacturing assurance program shall includes

a. Provisions for the review for concurrence of the supplier's drawings, Quality Assurance manual, manufacturing and quality ~

procedures prior to fabrication. When specified in approved i procurement documents suppliers may.not implement procedures unti) {

written notice of CPUN acceptance is received.

1

b. Established supplier inspection plans that delineate, as required, {

the hold and/or witness points in the manufacturing process for specified. review, inspection, verification and test.

c. Methods for identifying and reporting nonconformances and resolving of nonconformances where the supplier's suggested disposition is "Use-as-is" or " Repair". Such methods shall require the approval of the supplier disposition of nonconformances by the responsible engineer and approval of the Nuclear Safety Assessment Department.

GPUN Nuclear Safety Assessment Department will also verify that repairs are accomplished in accordance with the approved disposition.

d. Notification of Plant Engineering Receipt Inspection cf outstanding nonconformances and/or incomplete pre-shipment inspection prior to item shipment from the supplier.

e. Planned and systematic audit, source inspection and/or source surveillance of supplier activities or products. Scope of coverage and frequency shall be determined by the criticality.of the furnished items or services and the evaluated results of supplier qualifications, including pre-award surveys and document reviews.

Revisions to source verification plans shall be made as warranted by supplier performance. Typically, audits will be conducted on suppliers of services; and, source inspection, source surveillances, 1 I

and/or receipt inspection will be conducted on suppliers of hardware.

f. Control of supplier document package including review for t

completeneso and acceptability. Inadequate records which render the quality status of item (s) furnished indeterminate.shall be suffletent cause for rejection of this item (s).

0 OCAPLAll.a7 35.0 '

1 1

hlLj3l[}((f GPU HUCLEAR OPERATIONAL Numbar QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

5.0 Procurement and Material Control Revision No.

7

g. Assessments of supplier control of quality shall be made at a frequency and depth commensurate with the importance, complexity and quantity of the items furnished. These assessments shall utilize the qualitative and quantitative information provided by supplier noncompliance documents; surveillance, inspection and audit reports; and receiving inspection and test records.

h. Material acceptance procedures that assure:

1. The material, component, or equipment is clearly identified and that the identification and quantity correspond to the information on the shipping documents and quality records.

2. The item's handling and shipping requirements have been met by che supplier and maintained by the carrier.

3. The item's record package or compliance certificate is complete and adequate.

4. The material, component or equipment meets the technical requirements specified in the procurement documents, inspection plans, checklists or other special engineering documents.

5. Items delivered which are not in compliance with requirements are documented in accordance with the nonconformance procedure, tagged (As item configuration or storage conditions permit.

Additional administrative controls shall be used if tagging is not possible.), segregated (if possible), and prevented from being inadvertently issued for installation or use.

6. Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work.

5.1.2.4 Commercial Grade Dedication for NSP Applications The process of acceptance of commercial grade items intended for use in nuclear safety related applications shall be controlled and implemented j

l through an approved procedure (s) which includes the following:

a. An engineering evaluation to determine if the commercial grade item l performs a safety function or if its failure could compromise a l safety functions.

b. A determination that the definition of commercial grade item as provided in 10CFR21 is met,

c. A determination of the critical characteristics for acceptance which are essential for the performance of its safety function.

d. The definition of functional tests and/or inspections, including acceptance limits, to be performed to verify critical characteristics.

e. Verification that critical characteristics have been met by one of the following:

1. Performance of functional tests and/or inspections after receipt by GPUN; O CAPLAll . P 7 36.0

llLl3l?j[LF GPU NUCLEAR OPERATIONAL Numbar l QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

5.0 Procurement and Material Control Revision No.

t 7 1

l

2. Witnessing of functional test and/or inspections at the 1 4

supplier's facility.

3. Assuring through audit or surveillance that the supplier has a quality program which adequately controls the critical characteristics; performs tests and/or inspections which verify that critical characteristics have been. met; 1

4. Establishing the commercial grade part performance history concurrent with performing one of e(1), e(2) or e(3) above; or, i

5. Any combination of e(l) through e(4) above.

This dedication process shall result in the documented basis for the appropriateness of the use of the commercial grade item (s) in the specific nuclear safety related application (s).

5.1.3 Pesponsibilities 5.1.3.1 Director-Administration & Finance The Director-Administration & Finance is responsible.through the Director Materials Management for the: I

a. Administration and operation of contracting, procurement and warehousing activities of GPUN.

I

b. Assurance-that the technical and quality requirements, as '

established by requisitioners, are incorporated into contract / procurement documents without revision.

c. Assurance that bids are evaluated for conformance to technical and quality requirements by the' requisitioners.

l

d. Assurance that the contractual, legal and commercial requirements are' incorporated into the procurement documents in a manner which will enforce the technical and quality requirements.

e. Assurance that documents and records, as required by procurement documents, are submitted in a timely manner and that they are complete and legible,

f. Assurance that purchase orders and contracts for items and services within the scope of this Plan are issued to external organizations listed on the Suppliers Quality Classification List.

5.1.3.2 Director-Nuclear saf ety Asnessment The Director-Nuclear Safety Assessment is responsible for:

a. Assuring through a program of review and audit procedures for the control of purchased equipment, material and services are established, approved, implemented and effective.

b. Review of supplier Quality Assurance Programs for concurrence to the extent required by the procurement documents.

c. Revie - for concurrence supplier record packages as required by applicable procedures or procurement documents. -

>l l

C C APLAtt . P 7 37.0 ,,!

N b'^7~ GPU NUCLEAR OPERATIONAL Numbar QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title 5.0 Procurement and Material Control Revision No.

7

d. Establish and implement an adequate program of source inspection, source surveillance and audit to assure that items, parts, materials, consumables and services within the scope of this Plan comply with contract requirements.

e. Audit the adequacy of procurement documents to assure that documents are produced, reviewed, implemented and retained as required.

f. Establish and maintain a supplier Quality Classification List (SQCL) which documents the results of the evaluations of prospective suppliers.

5.1.3.3 Plant Encineerina Directors The Plant Engineering Directors are responsible for:

a. Review for concurrence, GPUN procedures necessary for the control of purchased equipment, material, and services that are within the scope of this Plan,

b. Review for concurrence supplier record packages as required by applicable procedures or procurement documents as part of receipt inspection.

l C. Establish and implement an adequate program of receipt inspection, to assure that items, parts, materials and consumables within the scope of this Plan comply with contract requirements. j i

d. Review procurement documents to assure that quality requirements are l correctly stated, inspectable and controllable; that there are '

adequate acceptance / rejection criteria; that source verification or l

receipt inspection is specified; that minimum documentation to be I supplied is specified; and that the procurement documents have been )

processed in accordance with established requirements.

e. Performing periodic evaluations of the quality of procurement documents produced. This evaluation may include a sampling review of previously approved documents or in-line reviews of selected l purchase requisitions or erders prior to placement by individuals independent from the production of the documents selected.

5.2 Identification and Control of Materials, Parts and Components 5.2.1 General Measures shall be established to provide for the identification and control of items, parts, materials, and consumables within the scope of this plan. These measures shall assure that incorrect or nonconforming items are identified and controlled in order to prevent their inadvertent installation or use. Where required cy design documents, the system established shall provide traceability of components from the receipt of material through fabrication, installation and testing. Verification shall include review of objective evidence of inspections and tests which demonstrate that product identification and control is maintained at various stages of manufacture, installation, or erection. Identification requirements shall be specified in the applicable design and procurement coruments.

OCAP1JJf . 7 7 38.0

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4

) hlLll$l')((F GPU NUCLEAR OPERATIONAL Number I j QUALITY ASSURANCE PLAN 1000-PLN-7200.01 1 Title 5.0 Procurement and Material Control Revision No.

7 1

I 5.2.2 Reauirements 5.2.2.1 Identification and traceability requirements shall be included in specifications and drawings.

t 5.2.2.2 Material, parts, and components, including partially fabricated subassemblies or subdivided materials shall be identified to preclude the

! use of incorrect or defective items.

5.2.?.3 Items, materials,. parts, consumables,'and equipment within the scope of a- this Plan shall be identified so that they can be traced to appropriate

documentation, which provides objective evidence of-the technical and

quality requirements met; such documents include but are not limited to 4

a. Specifications

! b. Drawings (including as-builts)

c. Procurement Documents j d. Physical and Chemical Test Reports l'

j e. Nonconformance Reports j f. Inspection Reports and Checklists j g. Storage Maintenance Instructions

n. Nondestructive Examination Reports i 1. Vendor Certificates of Compliance

[ The identification and/or end use of items, materials, parts, consumables,

, and equipment shall be specified in procurement-documents and work

)

authorizing documents to provide this traceability.

Traceability to heat and/or lot number shall be provided when required by code (s). Traceability is provided for parts of items within the scope of this plan. However, if the parts do not provide or contribute to the performance of a nuclear safety function, traceability will not be.

provided for those parts unless required by code (s) or regulation (s).

5.2.2.4 The location and method of identification shall be specified so as not to affect the form, fit, function or quality of the item being identified.

5.2.2.5 Correct identification of materials, parts and components shall be verified prior to release for fabrication, shipping, installation, and testing. l 5.2.2.6 Where physical identification is either impractical or insufficient, physical separation, procedural control, or other approved means may be employed.

1 5.2.2.7 A receipt inspection, when specified by procurement documents, shall be l performed at the site to verify that identification for received items is complete and accompanied by specified documentation. In the' case of )

ccmmercial grade items, rceeipt inspections shall be conducted consistent ,

with 5.1.2.4 of this plan.

4 ccAn Au.e7 39.0 , ,

1 1

ENualrr cpu NuCtExa oPEaATronAt QUALITY ASSURANCE PLAN numdor IOOO-PLN-72OO.OI

Title:

5.0 Procurement and Material Control Revision No.

7 5.2.3 Besponsibilities 5.2.3.1 Pesponsible Department Manaaer Each Department Manager is responsible for ensuring that procurement documents contair. appropriate requirements for the identification and control of materials, parts, or components and that only materials, parts or components which have been properly accepted are used.

5.2.3.2 Plant Enoineerina Directors Plant Engineering Directors are responsible for:

a. Review of procedures for maintaining identification in accordance with the requirements of this section.

b. Conducting receipt inspections.

c. Verification of material identification during receipt inspection.

5.2.3.3 Director-Administration & Finance The Director-Administration & Finance is responsible through the Director Materials Management for assuring that correct identification of materials, parts, and components are verified prior to release for fabrication, shipping, installation and testing.

5.2.3.4 Director-Nuclear Safety Assessment The Director-Nuclear Safety As.sessment is responsible for:

a. Monitoring and auditing to verify conformance to the requirements of this section.

reaPLw .p? 40.0

1 NEE' 1'^#"T GPU NUCLEAR OPERATIONAL Humbar QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7 6.0 CONTROL OF STATION ACTIVITIES 6.1 General This section provides general requirements which are applicable to the operational, support, and assurance activities which are directly related to the safe operation, maintenance and modification of the nuclear station.

6.2 Control of Insoections 6.2.1 Pecuirements 6.2.1.1 A program for performance of inspections of activities within the scope of this plan shall be established and executed by, or for, the organization performing the activity to verify conformance to the documented instructions, procedures, specifications and drawings for accomplishing the activity. Design specifications, drawings, procedures, or instructions shall include the necessary requirements for performance of inspections. These requirements include acceptance criteria and reference to codes, standards, and regulatory requirements and commitments. These requirements shall be further translated into procedures, instructions, or checklists which shall contain, as required, the following:

a. Identification of characteristics and activities to be inspected.

b. Methods to be used including necessary measuring and test equipment and the accuracy requirements.

c. Identification of organization responsible for performing the inspection.

d. Acceptance and rejection criteria.

e. Identification of required procedures, drawings and specifications, including the applicable revisions.

f. Documentation of inspection results including identification of the individual performing the inspection.

6.2.1.2 Inspectors (including MDE personnel) shall be qualified in accordance with applicable codes, standards and/or GPUN accepted qualification programs and their qualification and certification shall be kept current and documented.

6.2.1.3 Individuals performing inspections and/or examinationc shall be other than those who perform or directly supervise the activity being inspected and shall not report directly to the immediate supervisors who are responsible for the work activity being inspected. If the individuals performing the inspections and/or examinations are not part of the responsible Quality Verification or Technical Functions MDE/ISI organizations, the procedures and personnel qualification criteria shall be reviewed and concurred with by the Quality verification or Technical Functions NDE/ISI organization as appropriate prior to the initiation of the activity. Inspections may be conducted by second line supervisory personnel or by other qualified personnel not assigned first line supervisory responsibility for the conduct of work. These activities, i.e., those performed by individuals not assigned first line supervisory responsibility, are not intended to dilute or replace the clear responsibility of first line supervisors for the quality of work performed under their supervision. When inspections and/or examinations associated with normal operations of the plant (such as routine maintenance, surveillance and tests) are performed by CC APLAll R7 41.0

llLj$h)((F GPU NUCLEAR' OPERATIONAL Number QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

• 7 ,

individuals other than those who performed or directly supervised the work, but are within the same production group (reporting to different supervisors), the following controls shall'be mets

a. The quality of the work will be demonstrated through a functional test when the activity involves breaching a pressure retaining item.

b. The qualification criteria for the personnel.are reviewed and found acceptable prior to initiating the inspection / examination by the Technical Functions NDE/ISI organization or Quality Verification '

organization as appropriate.

Inspections (excluding NDE) of maintenance-activities may be conducted by individuals who directly report to a supervisor-immediately responsible for the maintenance being inspected. However in such cases the following shall be mets

a. The' qualification of individuals shall be reviewed for concurrence by the Quality Verification organization.

b. Deficiencies identified shall be handled consistent with the requirements of Section 8.0 of this plan,

c. Independent inspections and/or review of such cases of maintenance and inspection shall be conducted by the Quality Verification organization. The f requency and scope of such independent verifications shall be based on the observed quality of the inspections.

6.2.1.4 The Quality Verification organization.shall establish documented methods to review work activities prior to implementation to determine the need for inspection and the specification of the requisite hold and/or witness points.

6.2.1.5 When Inspection Points have been established, either contractually, by procurement, or internally by plant procedures, work may not proceed beyond the Inspection Point until either inspection is performed or waived by the Quality Verification organization.

6.2.1.6 Inspections of modifications, repairs, and replacements shall be by the same method and to the same criterra as the original or by a documented )

alternative approved by the Quality Verification organization. Where verification of inspection is being performed on previously accepted lots, sampling inspection shall be representative and only to the extent necessary to assure adequacy of control. The sampling plan shall be determined by the Quality Verification organization. Inspection personnel  !

shall be provided with suitable equipment and tools, which are calibrated '

as necessary, and controlled to assure that accuracy requirements are satisfied and that inspections are complete.

6.2.1.7 Inspection data and results shall be evaluated by designated personnel to assure that the objectives have been met and that items requiring action or follow-up are identified and documented.

6.2.1.8 Records shall be kept in sufficient detail to provide adequate confirmation'of an inspection program.

re m AR P7 42,O

• i hlLl3['][]f CPU NUCLEAR OPERATIONAL Numbsr 1000-PLN-7200.01 l

QUALITY ASSURANCE PLAN 1

Title:

6.0 Control of Station Activities Revision No.

i 1

Responsibilities I 6.2.2 6.2.2.1 Director-Technical Functions The Director-Technical Functions is responsible for:

a. Ensuring that requirements for inspections are included in design specifications, drawings, procedures and instructions and that these l requirements include acceptance criteria and, as applicable, I references to codes, standards and regulatory requirements and commitments.

b. NDE Support Services as required by codes, standards, and work implementing documents.

c. suring that NDE personnel are qualified in accordance with applicable codes, standards, regulatory requirements and commitments, and/or GPUN accepted qualification programs.

d. Reviewing and concurring with the personnel qualification criteria of individuals performing HDE, including those who are not part of the Technical Functions NDE/ISI organization.

6.2.2.2 Maintenance Director The Maintenance Director through the Quality Verification Manager is responsible for:

a. Assuring that inspectors (excluding NDE) are qualified in accordance with applicable codes, standards, regulatory requirements and commitments, and/or GPUN accepted qualification programs.

b. Reviewing maintenance and installation documents for inclusion of inspection and test requirements and inspection points.

c. Reviewing and concurring with the personnel qualification criteria of individuals performing inspections (excluding NDE), including those who are not part of the Quality verification organization.

d. Identification of inspection plans to be used for verification of inspections on previously accepted lots.

e. Performing inspections to assure the required level of quality is attained.  !

6.2.2.3 Pesponsible Department Manaaer Each responsible Department Manager performing work requiring inspections is responsible for: ]

a. Notifying the Quality Veriftcation organization of the work being performed as requireo.

b. Ensuring that maintenance and installation documents within the scope of this plan are transmitted to the Quality Verification organization to provide for the inclusion of inspection points prior to approving such documents for use.

c. Assuring that established Inspection Points are not bypassed without prior authorization.

OCAPLAD.P7 43.O

l l

E Nu2bcr CPU uUCtrAn oPtRan oNAt QUALITY ASSURANCE PLAN numbar lOOO-PLN-7200.01 I

Title:

6.0 Control of Station Activities Revision No.

7

d. Assuring that all information, records or copies of records associated with their work are made available to Quality Verification personnel.

tach responsible Department Manager performing inspections is responsible for:

e. Assuring that the personnel performing inspections are qualified in accordance with applicable codes, standards, regulatory requirements and commitments, and GPUN or GPUN accepted qualification program (s).

f. Assuring that the results of all inspections are properly documented and the results are evaluated by designated personnel.

6.3 Control of Special Processes 6.3.1 Recuirements 6.3.1.1 Special processes are those processes that require interim in-process controls in addition to final inspection to assure quality. Such processes include, but are not limited to, welding, heat treating, chemical cleaning, nondestructive examination, plant chemistry control, and the processing and preparation for shipment of radioactive wastes.

6.3.1.2 Measures shall be established and documented to assure that special processes are accomplished under controlled conditions in accordance with applicable codes, standards, applications criteria, regulatory requirements and commitments, and other special requirements including the use of qualified personnel and procedures.

6.3.1.3 Procedures for special processes shall be established to meet the requirements of applicable codes, standards, and regulatory requirements and commitments or to rneet the requirements of special process specifications which may be produced by or for GPUN. These procedures shall provide for recording evidence of acceptable completion of special processes. Procedures and instructions for the control of special processes shall be reviewed and approved by qualified personnel.

Procedures, equipment, and personnel performing special processes shall be qualified in accordance with applicable codes, standards, and specifications. Organt:ational responsibilities shall be delineated for the qualification of special processes, equipment and personnel.

Qualification records of persennel, equipment, and procedures associated with special processes shall be established, prepared and kept current.

For special processes not covered by the existing codes or standards, or when item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures and equipment shall be defined in the procedure.

6.3.2 E,esponsibiltttes 6.3.2.1 Director-Technical Functions l l

The Director-Technical Functions is responsible for developing procedures l j and providing support services for the special processes of welding, heat ,

i treating, and nondestructive examination. '

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l CC APLArs . R 7 44,0 ', l l

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Nuabcr Ceu NuctrAR ortRATIoNAt QUALITY ASSURANCE PLAN numb.r 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No. ,

' j l

1 6.3.2.2 Responsible Department Manaaer '

Each responsible Department Director / Manager performing special processes is responsible for  ;

a. Assuring that the established program requirements for controlling I

-and accomplishing special processes are implemented. l

b. Assuring that the procedures, including changes, are reviewed, approved and qualified prior to use,

c. Assuring that personnel and equipment used in the performance of special processes are qualified and the records of qualification are maintained.

I 6.4 Test Control '

6.4.1 Reauirements 6.4.1.1 A documented test program shall be established to assure that all testing

. required to demonstrate that the structures, systems'or components within

.the scope of this plan will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test procedures or. instructions which incorporate or reference the requirements and acceptance standards contained in the applicable design documents. The extent of testing shall be based on.the complexity of the modification, replacement, or repair. Testing, including proof tests prior to installation, hydro testing, In-service Testing (IST) and preoperational tests, necessary to demonstrate that the installed or modified structures, systems and components will perform satisfactorily in service, shall be accomplished in accordance with written approved procedures or instructions. These procedures shall be consistent with or incorporate the technical and quality requirements and acceptance limits specified by applicable design and procurement documents. These test procedures or instructions shall provide for the following as required

a. A description of the test objective,

b. Instructions for performing the test, including caution or safety notes in sufficient detail to avoid operator interpretation.

c. Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including accuracy requirements, completeness of item to be tested, suitable and controlled environmental conditions, and personnel to be provided to conduct testing under the direction of a qualified test supervisor or test engineer.

d. Provisions for data collection and storage.

e. Acceptance and rejection criteria as specified in design and procurement documents.

f. Methods of documenting or recording test data and results, in sufficient detail to prevent misinterpretation,

g. Mandatory hold or inspection points by CPUN and/or other designated personnel.

h. Provisions for control of jumpers, lifted leads and jurisdictional or safety tags.

PCAPLAli . P 7 45.0

Nu bcr- cpu nuCtexR OPra^TIonat number -

QUALITY ASSURAf!CE PLAN 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7

1. Provisions for returning a system to normal configuration upon completion _of the test, including verification.

j. Provisions for assuring test prerequisites have been met.

6.4.1.2 Test results shall be documented, evaluated, and their acceptability determined by a responsible individual or group. l l

6.4.1.3 The test program shall cover all required tests including:

a. Preoperational tests of components or~ systems to demonstrate that performance is in accordance with the design intent.

b. Tests during initial operation to demonstrate system performance (that could not be tested prior to operation) to confirm compliance to design criteria.

c. Tests during the operational. phase to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of systems within the scope ofsthis plan is maintained.

d. Tests during activities associated with plant maintenance during the operational phase and to demonstrate satisfactory performance following plant maintenance or. procedural changes.

6.4.1.4 Tests performed following plant repairs-or replacements shall be conducted in accordance with the original design and testing requirements or approved, documented alternatives. Testing shall be sufficient to confirm that the changes reasonably produce expected results and that the change-does not reduce safety of operations.

6.4.2 Respon s ib il it ies 6.4.2.1 Directors THI, and Ovster Creek The Directors of the nuclear generating stations are each responsible for assuring that testing performed at their assigned station is performed in accordance with the requirements of this Plan including, as a minimum, the following: -

a. Assuring that testing is performed in accordance with written, ,

approved and controlled procedures or instructions.

b. Prescribing, performing and/or ensuring the performance of post- r maintenance testing for the work performed by TMI or Oyster Creek. I

c. Ensuring that all post-maintenance testing performed by THI or Oyster Creek is documented and the results accepted prior to l

operation.

d. Assuring that operations personnel have the required special training and skills,

e. Assurtng that the test results are documented and are evaluated for acceptao111ty by a responsible individual or group.

f. Assuring that identified discrepancies are-addressed, resolved and ,

reported as required by the Operating License and Technical- -

Specifications of the Unit. 4 3

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Nucbcr cpu noctExa oPrRAT1onat.

QUALITY ASSURANCE PLAN numbar 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7 i

l l

r 6.4.2.2 Director-Technical Functions The Director-Technical Functions, is responsible to perform a startup and test function to assure new or substantially modified plants, facilities and systems are tested. These responsibilities shall include:

a. Preparing test plans and implementing procedures.

b. Directing testing and assuring test engineers have the required special training and skills.

c. Ennuring that test documentation is completed, as required, and reviewed prior to turnover to operations,

d. Coordinating technical assistance of testing.

6.4.2.3 Director-Services The Director-Services, through the applicable station Site Services Director, is responsible for:

i

a. Ensuring supporting personnel have the required special training and skills.

b. Prescribing, performing and/or ensuring the performance of construction or post-maintenance testing requirements for the work managed and/or performed by Site Services.

c. Ensuring that all construction or post-maintenance testing including hydrotesting, for the work managed and/or performed by Site Services is documented and the results reviewed and accepted prior to turnover.

6.5 Control of Measurina and Test Eculpment (M&TE) 6.5.1 Pecuirements 6.5.1.1 Measures shall- be established to control installed and portable equipment which are used to conduct measurements or tests related to determining the functionality or quality of structures, systems and components within the ,

scope of this Plan. Such measuring and test equipment typically includes tools, gauges, meters and other devices. l Such measurements and tests  ;

include as a minimum those associated with the activities of operation, i maintenance, modification, chemtstry, radtological and environmental I controls, nondestructive examinatior, and inspection. Such measures shall j ensure that measuring and test equipment are properly identified and l

calibrated or adjusted at spectfied periods to maintain accuracy within I specified limits. Measures shall also be established to ensure that range, type, accuracy and use of the equipment conforms to specified I requirements.

6.5.1.2 Requirements for each control program shall include inspection and l verification of accurae/ upon receipt of equipment, identification of all gauges and instruments, calibration and scheduled recall for calibration and traceability to an accepted Standard. These activities shall be suo3ect to Nuclear Safety Assessment Department monitoring and auditing. l l Procedures shall be established to implement the following requirements:

1 1

1 (C APLAll . R 7 47.0 l

.kjZf GPU NUCLEAR OPERATIONAL Numbnr QUALITY ASSURANCE PLAN 1000-PLN-7200.Cl

Title:

6.0 Control of Station Activities Revision No.

7 l

l l

a. Establish the calibration technique and frequency requirements, maintenance requirements, and controls for all M&TE which are used in the measurement, inspection, and monitoring of components, i systems, and structures within the scope of this Plan (e.g. 1 instruments, tools, gauges, fixtures, reference and transfer I standards, and nondestructive examination equipment). i l

b. The identification of MGTE traceable to the calibration test data.

( c. M&TE requiring calibration shall be identified and controlled in i

accordance with written, approved procedures to assure that approved calibration intervals are not exceeded. M&TE shall be clearly labelled to indicate the date on which the current calibration expires. M&TE that has exceeded the approved calibration interval shall not be used for measurements or tests until its calibration has been re-established.

I I d. Establish calibration frequency for M&TE based on required accuracy, purpose, degree of usage, stability characteristics, and/or any t

other condition which may affect the measurement. A calibration

! recall system shall be implemented to assure recalibration within l the required period for each piece of METE covered under the scope i of this program.

1 I

e. Establish methods for determining the validity of previous inspections performed when the M&TE is found to be out of calibration. Inspections or tests are repeated on items determined to be suspect. Such determination is to be documented in suitable form. If any calibration, testing or measuring device is consistently found to be out of calibration, it shall be repaired or replaced.

f. M&TE used to calibrate instruments and gages (e.g. flowmeters, transmitters, senscrs, pressure gauges, level indicators, etc.)

shall have been calibrated against working standards with accuracies at least four times greater than that of the equipment being calibrated. The instrument or gage calibration accuracy in reference to the M&TE shall be at least 1:1.

In cases where the instrument or gage is calibrated directly against working standards, the working standard shall have an accuracy of at least 1:1 and the secondary standards used to calibrate the working l standards shall have an accuracy of four times greater than that of the working standards. I When the above requirements cannot be met, the standards used to calibrate the MSTE shall have a precision and repeatability that j assures that the equipment being calibrated will be within the '

required tolerance. The basis of acceptance will be documented and .

authorized by the supervisor of the calibrating organization. l Some METE because of their construction (such as mechanical dial l indicators) or because they are not adjustable (such as rulers) need l not be periodically calibrated. However, their physical condition  ;

and where applicable the accuracy shall be routinely checked prior to use, I

g. The calibration status of M&TE which is used for determining the functionality or quality of structures, systems and components within the scope of this Plan shall be maintained.

(C APLAll . P 7 48.0 l

I

NLI I"' 7 cpu nuCtExa oeEnATlonut QUALITY ASSURANCE PLAM

"==har 1000-PLN-7200.01

Title:

6.0 control of Station Activities Revision No.

7

h. Utilization of reference and transfer standards traceable to ,

nationally recognized standards. Where national standards do not l exist, provisions shall be established to document the basis for the l calibration. i

i. NDE equipment shall be controlled and calibrated in accordance with i the industry code governing its use. l 6.5.2 Pesponsibilities 6.5.2.1 Responsible Degartment Manaaer Each Department Manager utilizing METE in activities affecting the function or quality of structures, systems, components and activities within the scope of this plan shall assure that such M&TE is controlled in accordance with an approved calibration control program which conforms to the requirements of this Plan.

6.6 Handlino, Storace and Shippina 6.6.1 Recuirements 6.6.1.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, packaging, and preservation of items within the scope of this plan in accordance with established instructions, procedures, and drawings to prevent damage, deterioration or loss. The requirements for handling, storage, packaging and shipping of radioactive wastes are contained in Section 7.0 of this Plan.

6.6.1.2 Procedures shall be established to control the cleaning, handling, storage, packaging, and shipping of materials, components, systems in accordance with design and procurement requirements to preclude damage loss or deterioration by environmental conditions such as temperature or humidity. These procedures shall be implemented by suitably trained individuals. The procedures shall include but not be limited to, the following:

a. Packaging and preservation procedures to provide assurance of adequate protection against corrosion, contamination, physical damage or any effect whten would lower the quality of the items or cause deterioration during shipping, handling or storage. Special protective environments, special coverings, inert gas atmospheres, moisture contents, and temperature controls shall be specified as required and their existence verified and documented.

b. Cleaning methods to provide assurance that necessary cleaning operations are carried out prior to packaging, storage or ,

installation. The level of cleanliness required, and verification l and documentation requirements shall be specified in the procedures.

! c. Detailed handling methods for all items that require special handling. Special handling tools and equipment shall be provided and controlled to ensure safe and adequate handling. These tools and equipment shall be maintained, inspected and tested in I accordance with written procedures at established intervals to ensare their reliability and availability for use.

i i

rCMUJI , P 7 49.0

$U2l3[]f GPU NUCLEAR OPERATIONAL QUALITY ASSURANCE PLAN Numbar lOOO-PLN-72OO.Ol l

l l

Title:

6.0 Control of Station Activities Revision No.

7

d. Storage practices to provide for methods of storage and the control of items in storage which will minimize the possibility of damage or deterioration during storage. Periodic inspections of storage areas shall be performed and documented to verify compliance with storage procedures. Release of items for installation shall also be procedurally controlled.

e. Provisions to assure that proper marking and labeling of items and containers is accomplished to provide identification and necessary instructions during packaging, shipment and storage.

f. Provisions for documenting and reporting nonconformance to handling, and shipping requirements.

g. Provisions for the storage of chemicals, reagents, lubricants and other consumable materials which will be used in conjunction with systems which are within the scope of this plan.

h. Provisions for " Limited Life" requirements (including " Shelf Life" and " Service Life" for applicable materials).

6.6.2 Besnonsibilities 6.6.2.1 Pesponsible Department Manaaers Each responsible Department Director / Manager is responsible for identifying in procedures, drawings, specifications or procurement documents those handling, storage and shipping requirements necessary to assure compliance with the requirements of this Plan.

6.6.2.2 Director-Administration and Finance The Director-Administration and P: nance, through the Director-Materials Management, is responsible for:

a. Providing the procedures for the receiving and storage of materials, parts and components.

b. Assuring that the personnel responsible for the handling and storage of materials, parts and components are adequately trained in the performance of their duties and that they implement the procedures properly.

c. Providing adequate storage of items, materials, components, and parts within the scope of thAE plan.

6.6.2.3 Directere TMI. and Ovster Creek The Directors of the nuclear generating stations are each responsible for assuring that the handling, cleaning and storage activities, under their direction, associated with the operation and maintenance of their assigned station are perf ormed in accordance with the requirements of this Plan.

6.6.2.4 Director-Services The Director-Services through the applicable Site Services Director is responsible fer accuring that the nandling, cleaning and storage requirements of this Plan are incorporated in the procedures and are prope r ly replemented on all maintenance and modification projects performed by Site Services at the generating stations.

cc utw .p7 50.0 .

. - - - _~ . .- . .. = ~ . - - . - ._. _ _ . . .

Nusbcr cpu nuctExa oPraATlonAt QUALITY ASSURANCE PLAN number 1000-PLN-7200.01

Title:

6.0 control of Station Activities Revision No.

7 6.7 Inspection, Test. and operatina Status 6.7.1 Fecuirements 6.7.1.1 Measures shall be established and documented to ensure that the required inspections and tests are performed and that the acceptability of items with regard to inspection and tests performed is known throughout manufacturing, installation, and operation. Status of items covered by the scope of this Plan shall be controlled in accordance with approved procedures. These procedures shall include the use of appropriate tags, markings, lists, logs, diagrams, electrical and mechanical jumpers, or other suitable means, to assure that required inspections and tests are satisfactorily completed to prevent inadvertent bypassing of required inspections and tests and to prevent inadvertent operation.

6.7.1.2 The requirements for an acceptable inspection, test and operating status program for structures, systems, and components throughout fabrication, installation, test and operation include:

a. Design and quality documents which address the requirements for the ,

identification of inspection, test, and operating status of i structures, systems and' components.

b. Procedures which include controls for the application and removal of  ;

inspection and welding stamps, and other. status indicators such as ,

tags, jumpers, markings, labels, and stamps. ,

c. Procedures for controlling the bypassing or altering of the sequence of required inspections, tests or other critical operations are s procedurally controlled with concurrence by the Nuclear Safety l Assessment Department. The procedures shall provide for the ,

identification of items which have satisfactorily passed such -

inspections and tests, where necessary to preclude inadvertent bypassing of required inspection and tests.  !

d. In cases where documentary evidence is not available to confirm that an item has passed required inspections and tests, that item shall be considered nonconforming until such evidence becomes available. '

Affected systems shall also be considered to be inoperable and  ;

reliance shall not be placed on such systems to fulfill their  ;

intended safety functions,

e. Procedures requiring identification of the operating status of systems, components, controls, or support equipment in order to prevent inadvertent or unauthorized operation. These procedures shall require control measures such as locking or tagging to secure l and identify equipment in a controlled status. Independent

. verification shall be required, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented j correctly.

f. Methods which ensure temporary modifications / variations shall be controlled by approved procedures which include a requirement for independent verification. A log shall be maintained of the current status of such temporary modifications / variations.

g.

Methods which ensure that nonconforming services and inoperative or  ;

malfunctioning structures, systems, components or materials shall be identified in accordance with the requirements of this Plan. -

4 4

OtAP LM . P 7 51.0

l l

M Nucirr cru nUCtr^a ovranTIon^t QUALITY ASSURANCr PLAN number 1000-PLN-72OO.01 l

Title:

6.0 Control of Station Activities Revision No.  !

7 i

6.7.2 Responsibilities j I

6.7.2.1 Directors TMI, and Ovster Creek l The D.irectors of the nuclear generating stations are each responsible for assuring that the appropriate requirements for controlling the inspection, test and operating status, including independent verification, are incorporated in the procedures used on all fabrication, installation, test and operation activities performed at their respective stations.

6.8 Housekeepino and Cleanliness 6.8.1 Beauirements 6.8.1.1 Good housekeeping practices shall be utilized at all times to maintain the facilities in a neat and clean condition and to assure the control of radioactive contamination areas and the control of work activities, conditions and environments that can affect the quality of parts of the nuclear plant within the scope of this plan.

6.8.1.2 Housekeeping encompasses all activities related to the control of cleanliness of facilities, materials and equipment; fire prevention and protection including disposal of combustible material and debris; control of access to areas, protection of equipment, radioactive contamination control; and, storage of solid radioactive waste.

6.8.1.3 Housekeeping practices shall assure that only proper materials, equipment, processes, and procedures are utilized and that the quality of the item is not degraded as a result of housekeeping practices or techniques. During maintenance activities, certain portions of safety-related systems or components may be subject to potential contamination with foreign materials. To prevent such contamination, control measures, including measures for access control, and tool accountability shall be established.

Additionally, immediately prior to closure of system (s) or component (s),

an inspection shall be conducted and documented to ensure cleanliness.

Special housekeeping considerations shall be made for maintenance of radioactively contaminated systems and components.

6.8.2 . Responsibilities 6.8.2.1 Directors TM! and Ovrter Creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining programs and practices for housekeeping and cleanliness control of all work activities performed by the plant site staff, support organizations and contractors in accordance with the requirements of the CPUN QA Program.

6.8.2.2 Director-Services Tne Director-Services through the applicable Site Services Director is responsible to implement housekeeping and cleanliness control plans, procedures, instructions or practicec associated with all work activities performed by their personnel and contractors.

6.8.2.3 Director-Nuclear Safety Assessment The Director-Nuclear Safety Assessment, is responsible for monitoring the housekeeping and cleanliness practices at the nuclear generating stations.

i C C APLAll . P 7 52.0

N " t'#'e r GPU NUCLEAR OPERATIONAL QUALITY ASSURANCE PLAN Number 1000-PLN-72CO.D'

Title:

6.0 Control of Station Activities Revision No.

7 6.9 Eouipment Control 6.9.1 Pecuirements l

6.9.1.1 Authorization to remove plant installed operational equipment or systems from service, for maintenance or modification, shall be granted by the on-duty Shift Supervisor.

6.9.1.2 Procedures shall be provided for control of equipment, as necessary, to maintain personnel and reactor safety, to avoid unauthorized operation of equipment, and to assure that operational equipment is in a ready status.

Work on equipment and systems, critical to the safe operation of the plant, shall not be performed while the plant is operating without specific advanced approval by the designated Operations management personnel in each instance. The procedures for controlling the removal from service and the return to service of equipment shall require:

a. Control measures such as locking or tagging to secure and identify equipment in a controlled status.

b. Independent verifications when necessary to ensure that measures, such as tagging equipment, have been implemented correctly.

c. Temporary modifications / variations, such as temporary bypass lines, blank flanges or similar mechanical inserts, electrical jumpers, lifted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include a requirement for independent verification by either a second person or by functional test which conclusively proves the proper installation and subsequent removal of the temporary modification. A log or equivalent documented evidence shall be maintained of the current status of such temporary modifications which are installed.

d. Control of inspection and test status on individual items by the use of markings such as stamps, tags, labels, routing cards or other suitable means.

e. When equipment is ready to be returned to service, operating personnel shall place the equipnient in operation and verify and document its functional acceptability.

f. The equipment shall be adequatels identified on the documentation to assure traceabillt; 6.9.2 Pesponsibilities 6.9.2.1 Qirectors TMI, and Ovster Creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining procedures and assuring implementation of the procedures for identification and control of equipment to avoid unauthorized use and to assure that operational equipment is in a ready status. These requirements shall include independent verifications to ensure proper implementation.

(C AP LAII . P 7 53.0 ,

l

l l

Nuabcr ceu nuCtrAR oesRA: Ion e QUALITY ASSURANCE PLAN numbar 1000-PLN-7200.01 I

l

Title:

6.0 Control of Station Activities Revision No. l 7 l I

6.10 Control of Construction, Maintenance (Preventive / Corrective) and Modifications 6.10.1 Decuirements 6.10.1.1 Construction, maintenance or modifications which have the potential to affect the functioning of structures, systems or components within the scope of this plan shall be performed in a manner to ensure quality at least equivalent to that specified in the original design basis and requirements, materials specifications and inspection requirements. A suitable level of confidence in structures, systems or components on which maintenance or modifications have been performed shall be attained by appropriate inspection and performance testing. Construction, maintenance or modification of equipment shall be pre-planned and performed in accordance with written procedures, instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria. In this regard, modification type work in areas and systems of a plant, critical to the safe operation of the plant, shall not be performed while the plant is operating without specific advance approval by the Plant Division Director or designee (s).

6.10.1.2 Detailed step by step procedures are not required for all maintenance and modification work. The supervisor planning the job must consider the skills required to ensure proper completion of the work and identify the procedural requirements accordingly. Work such as replacing chart or drive speed gears, replacing fuses or tightening valve packing may not require written procedures.

Whereas, work involvino inter-departmental coordination or risk of nuclear or personnel safety rei es a higher level of administrative control such as approved procedures ano sign offs to properly coordinate, direct and document the activity.

6.10.1.3 Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure but are subject to general administrative procedural controls that govern or define the following areas:

a. Methods f or obtaining pern.icsion and clearance from Operation personnel to work and for logging such work.

b. Factors to be taken into account, including the necessity of maintaining occupational radiation exposure as low as is reasonably achievable (ALARA).

c. Method for identification of what procedural coverage is necessary for the maintenance, construction and modification aefivity.

d. Considerations for system / equipment cleanliness control,

e. Method for identification of post maintenance, construction or modification, testing, including system / equipment functional capability to meet operational requirements in all respects.

f. Method for ensuring that n.atntenance, construction or modification activities, performed either on-site or off-site, are properly reviewed.

g. Considerations for other activities already taking place in the general area.

rcartAri.p) 54.0

1 hhLI3b)[lf GPU HUCLEAR OPERATIONAL Numbar ,

l QUALITY ASSURANCE PLAN 1000-PLN-7200.01 j l

Title:

6.0 Control of Station Activities Revision No.

(

r 7

l i

6.10.1.4 Means (for example, inspections, measurements, tests, welding, heat l treatment, cleaning, nondestructive examination and worker qualifications l in accordance with applicable codes and standards) for assuring quality of I maintenance, modifications or construction activities and measures to l document the performance thereof shall be established. Measures shall be j established and documented to identify the inspection and test status of items to be used in maintenance, modification, and construction activities.

6.10.1.5 A corrective maintenance program shall be developed to maintain

structures, systems and compo" ts within the scope of this plan at the quality required for them to ,rm their intended functions. Corrective

-nintenance shall be perform. ,

a timely manner to ensure that items within the scope of this plan . adequately maintained in the original, i es designed, functional status.

6.10.1.6 A preventive maintenance program including procedures as appropriate for l

structures, systems, and components within the scope of this plan shall be established which prescribes the frequency and type of maintenance to be performed. In all cases, maintenance shall be scheduled and planned so as not to compromise the safety of the plant. Planning shall consider the possible safety consequences of concurrent or sequential maintenance, l

testing or operating activities. Preventive maintenance shall be performed in a timely manner to ensure that items within the scope of this plan are adequately maintaine' in the original, as designed, functional status.

6.10.1.7 Proposed modifications shall be reviewed, approved and controlled in accordance with the applicable requirements of the Operating License and Technical Specifications and procedures governing the design, procurement, construction, testing and inspection. Modifications to structures, systems and components within QA Plan scope shall be reviewed and accepted in accordance with the requirements of Section 2.8 of this Plan.

6.10.1.E Design, procurement, construction, tecting and inspection of all modifications shall be performed in accordance with the applicable portions of this Plan.

6.10.1.9 Upon completion of the design phase of a modification, Technical Functions turns the project over to Site Services or Maintenance for installation of k the modification with an engineering document package. Procurement of the {

required materials, parts and c c:npone n t s is generally initiated by Technical Functions, but may be initiated by other organizations as necessary.

Site Services or Maintenance prepares the necessary installation

(

procedures or instructions consistent with the engineering requirements, completes the installat ion and construction testing and compiles the records which it generated for record retention. Engineering problems identified durino installation shall be identified to Technical Functions l for resolution using the appropriate documentation as identified in the implementing procedures. Site Services or Maintenance shall notify the Quality Verification organization and, where applicable, the Authorized Inspection Agency of all identified inspection hold points in sufficient l tree f or perf ormance of the inspection.

ecArtAri r7 55.0

Nuabcr GeV nUctEAn oeEaAT wN^t QUALITY ASSURA!!CE PLAN nuer lOOO-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7 6.10.2 Resoonsibilities 6.10.2.1 Directors TMI, and oyster Creek The Directors of the nuclear generating stations are each responsible for:

a. Establishing procedures for preventative and corrective maintenance consistent with the GPUN organization and maintenance plans.

b. Ensuring that maintenance and modification activities are performed in accordance with the requirements of this Plan and the applicable l

Operating License and Technical Specifications.

l

c. Planning, seneduling, performing, directing and documenting maintenance consistent with the GPUN organization and maintenance plans.

d. Establishing administrative control procedures for modification work consistent with the GPUN organization plan.

6.10.2.2 Maintenance Director l

The Maintenance Director through the Quality Verification Manager is l responsible for:

1

a. Reviewing installation and maintenance procedures or equivalent work authorizing documents to provide for the assignment of inspection

points to selected documents.

[

l

b. Performing inspections and/or examinations (excluding NDE) required j for the completion end acceptance of the installation.

c. Verify the appropriateness of quality requirements in fabrication and installattor. speci f i cat ion s:

6.10.2.3 Director-Technical Functions The Director-Technical Functions is responsible for;

a. Reviewing and apprevine tne pro.eduret which define the scope and limits of respons1Lilitter cf plant engineering with regards to modtfications.

b. Ensuring that design and procurement activities associated with plant modifications are implemented in accordance with approved procedures.

c. Controlling the drawingc and specifications used for plant modifications.

l i

d. Preparing and issuing as-built drawings of plant modifications, as appropriate.

e. Ensuring that modifications are designed, procured and installed in accordance with requirements which are either equal to or bettoi than tne original requirements. This includes the performance of required Non-Destructive Examination,

f. Preparing and filing design, engineering and Technical Functions inattated procurement records n accordance with the QA Records require. Tents of this Plan.

i t

t r( APLAll . P 7 56.0 t

Nuslacr cpu nuCtrAn oPraATronAt QUALITY ASSURANCr PLAN wu dar 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7

g. Providing the design and engineering support during installation and testing of plant modifications including the resolution of engineering problems identified during installation.

h. Maintaining control of technical configuration of the plants and maintaining the associated drawings current.

6.10.2.4 Director-services The Director-Services, through the applicable Site Services Director, is responsible fort

a. Planning, performing, directing and documenting construction, modification and maintenance consistent with the GPUN Organization and maintenance plans.

b. Providing the superv.sion and labor necessary to complete the assigned work.

c. rnsuring that installation of a modification is implemented in conformance with engineering requirements. Deviations from engineering requirements are not authorized except as specifically approved by engineering in advance. The Quality Verification organization review for concurrence is also required in advance if the deviation affects the inspectability or planned inspections of the installation (s) affected.

d. Providing Technical Functions eith the information necessary to prepare and issue as-built drawings.

e. Preparing and filing installation records in accordance with the QA Records requirements of thic Plan.

6.11 Control of Surveillance Testina and Inspection 6.11.1 Recuirements 6.11.1.1 A surveillance testing and inspection program shall be established and implemented in accordance with the Operating License and Technical j Specification requirements of the plant to ensure that structures, l systems, and components within the scope cf this plan will continue to operate, keeping paran eters within normal bounds, or will act to put the {

i plant in a safe condition af they exceed normal bounds. I 6.11.1.2 Provisions chal: '9 made for performing required surveillance testing and l tnspections, including in-service inspections. Such provisions shall  !

include the establishment of a Technical Specifications surveillance testing schedule reflecting the status of all planned in-plant surveillance tests and inspections. Frequency of surveillance tests and inspections may be related to the results of reliability analyses, the frequency and type of service, or age of the item or sys+.em, as appropriate.

ecArt.Am P 7 57.0

Nuclacr cru nuttrAR oetRATloNAt QUALITY ASSURANCE PLAN Number 1000-PLN-7200.01

Title:

6.0 Control of Station Activities Revision No.

7 6.11.1.3 . Additional control procedures shall be instituted, as necessary, to assure i timely conduct of, surveillance tests and inspections and appropriate documentation, reporting, and evaluation.of the results. Procedures shall be established to assure proper review of surveillance test data and the i I

return of systems to an operable status following the completion of testing. These procedures shall include provisions for the documentation of authority, conduct, responsibility, and verification involved in returning the system to an operable status. Such provisions shall include the use of procedures, checklists, and independent verification as appropriate, considering the degree that system status was altered during the performance of the test.

6.11.2 Desnoamihilities 6.11.2.1 Directors TMI, and Ovster Creek The Directors of the nuclear generating stations are each responsible fort

a. Providing the procedures, schedules and manpower necessary to implement the Surveillance Testing and Inspection requirements of the Operating License and Technical Specifications as applicable to the assigned unit.

b. Ensuring that the requirements for Surveillance Testing and Inspection are completed as required.

6.11 Radiolootcal control 6.12.1 Peautrements 6.11.1.1 A radiological controls program shall be established and implemented at each station tot

a. Control radiation hazards

b. Avoid accidental radiation exposures

c. Maintain exposures to workers and the general population as low as reasonably achievable (ALARA) and within regulatory requirements.

d. Provide guidance and specify appropriate methods or techniqLes to ensure that the performance of activities are in accordance with sound radiological control principles and in compliance with applicable regulatory requirements.

6.12.1.2 The radiological controls program is to be fully integrated into the applicable activities of each and every phase of operations at the nuclear generating stations.

6.12.1.3 Procedures shall be provided for the implementation of the radiological controls program. These proceourec shall contain the requirements for implementation of the program by the Radiological Controls Department and the requirements for inclusion of radiological controls in the plant operation, maintenance and testing procedures.

6.12.1.4 Tne radiological controls program includes the acquisition of data and provasion of equipment to perform necessary radiation surveys, measurements and evaluations for assessment and control of radiation condations, yl V

OCAPLA!!.P7 58.0 ,

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i w - r-w p -r - 7 ,

ENuclacr clglgcyr^aggy?n^f

, ""e L _uoc.01

Title:

6.0 control of Station Activities Revision No.

7 6.12.2 Respons ibil it ies 6.12.2.1 Division Directors Each Division Director is responsible for assuring that the requirements of the radiological controls program as applicable to their activities are adequately included in procedures and that the procedures are implemented properly.

6.12.2.2 Director-Nuclear Assurance The Director-Nuclear Assurance through the Director-Radiological ControlA/

occupational Safety is responsible for:

a. Esteblishing and maintaining the radiological controls program.

b. Providing the personnel, procedures and administrative controls to implement the radiological controls program.

c. Providing administrative and technical guidance applicable to radiological controls, radioactive materials, respiratory protection and radiological engineering including ALARA programs and dosimetry control.

l l

l C C A PLAll . P 7  %,O

[fl))})ggLAC:lmrr

- GPU NUCLEAR OPERATIONAL Number ouALITY ASSURANCE PLAN IcOO-PLN-72OO.01

Title:

7.0 Control of Radioactive Wastes Revision No.

] 7 7.0 CONTROL OF RADIOACTIVE WASTES OF MATERIALS 7.1 General 7.1.1 Heasures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71, Title 10, Part 20, and Title 49, Parts 100 through 199 applicable to the packaging and transporting of radioactive wastes or materials are satisfied.

7.1.2 Subpart H to 10CFR71 identifies the quality assurance criteria applicable to the control of packaging to be utilized to ship radioactive wastes or materials. The portions of this Plan that relate to the criteria in Subpart H to 10CFR71 describe to a large extent the administrative controls and quality requirements to be applied in the control, packaging and transportation of radioactive waste or material. A comparison of the requirements of 10CFR71, Subpart H and the applicable sections of this Plan are listed in Appendix A. These sections of this Plan will be implemented to satisfy the requirements of Subpart H to 10CFR71.

7.1.2 It is the policy of GPUN to minimize the generation of radioactive waste consistent with the ALARA concept to minimize personnel exposures and environmental contamination.

7.1.4 Title 10, Part 20, requires that a quality control program be implemented to verify compliance with Title 10, Part 61.55 (Waste Classification) and Title 10, Part 61.56 (Waste Characteristics). This Plan will be implemented to the extent necessary to assure compliance with those Parts of Title 10 (using a graded approach.)

7.2 Pecuirements 7.2.1 Procedures and administrative contro'.c shall be developed and implemented to cover the following:

a. Processing of radioactive wastes including the collection, handling and preparation for shipment of radioactive liquids and solids.

These procedures shall be consistent with the ALARA program and shall clearly identify the administrative controls and organizational responsibilitlec.

b. Training and qualification of personnel operating radioactive waste processing equipment, health physics monitoring, packaging and shippir,g (which includes Waste classification and establishment of Waste Characteristics) and other operations deemed appropriate by management,

c. The activities associated with the packaging of radioactive wastes or materials to include the proper selection of the receptacles to be used for containing the waste materials, the selection of the shipping containers (structures used to contain and support the receptacle and its contents) establishment of Waste Characteristics,.

Radiological control inspections of the packaging prior to' release, proper markings on the outside of the package and the preparation of shipping papers ard certificates. The activities shall be in accordance with 10CFR20, IOCFR61, IOCFR71, and 49CFR.

d. Movement of radioactive wastec or materials within and outside the protected area to assure personnel protection at all times.

OC A PLAll . P 7 60.O

i Nu'ilocr Gru NuCtrAR orrRATroMat QUALITY ASSURANCE PLAN numbar 1000-PLN-7200.01 l

Title:

7.0 Control of Radioactive Wastes Revision No.  !

l 7

l l l

l e. The shipment of radioactive wastes or materials from the Station to l

! be in accordance with the regulations of the U.S. Department of i

! Transportation for the transportation of hazardous materials (49CFR) and of the NRC (10CFR71 and 10CFR20).

f. Design, fabrication, assembly, testing and modification of packaging i used for transportation of radioactive waste or material which exceed the limits specified by 10CFR71.10 shall not be performed by l GPUN. Such packaging shall be purchased from an outside supplier l

and shall comply with 10CFR71 and 49CFR.

l l g. The packaging used for transporting of radioactive waste or l material, which doce not exceed the limits specified in 10CFR71.10, whether purchased from an outside supplier or designed by GPUN, shall meet 49CFR.

h. Minimization of the generation of radioactive wastes through l training programs, prudent scheduling and use of equipment and personnel and good housekeeping practices.

7.2.2 The carriers to be used for transporting of radioactive waste or material I shall be selected on the basis of their experience, knowledge of DOT

[ regulations, control and maintenance of their equipment and the selection l and control of their drivers. The carrier is required to have or shall be supplied documented procedurea covering acceptance of radioactive waste or material from a shipper, certification requirements, placarding, storage control, reporting of incidents and security.

7.2.3 operations involving radioactive waste processing or radioactive material shall be controlled to minin.ize personnel exposures or environmental contamination consistent with ALARA.

I 7.2.4 operations procedures relating to radioactive waste or material shipping and packaging shall be reviewed by the Quality Verification organization to establish any necessary witness or hold points.

7.3 Responsib:lities 7.3.1 Directors TMI. and Ovster Creek The Directors of the nuclear generating stations, thru their on-site staffs shall develop and implement procedures for minimizing the generation of radioactive waste, materials and the processing of radioactive waste and movement of radioactive materials. These procedures shall include the following:

l

a. Training of personnel in the methods to minimize the generation of radioactive waste.

b. Procec61ng and packaging of liquid and solid wastes,

c. Collection and identification of ratlioactive solids such as rags, pa pe r s , boots, gloves, etc. and have t hem moved to the Radwaste facility for packaging.

a l

r c APLAIL P 7 61.0 m,,,

Nualacr cru nuCtr^a oeta^T1oNat QUALITY ASSURANCE PLAN Number 1000-PLN-7200.01 l l

l Title 7.0 Control of Radioactive Wastes Revision No. I 7

d. Selection of the proper packaging for the specific contents to be shipped, taking into consideration the radiation levels,  ;

contamination limits and shipping requirements. Radiological I Control surveys the packaging for radiation level and, if acceptable, the operations Department marks the outside of the package with the appropriate markings, completes the shipping I papers / manifests and certificates, attaches the security seal and advises the carrier that the shipment is ready,

e. Review and acceptance of carrier procedures specified by the procurement documents covering the acceptance of radioactive waste or material for shipment.

f. Review and acceptance of the designs of packaging purchased from an outside supplier.

7.3.3 Director-Nuclear Assurance The Director-Nuclear Assurance is responsible through the Director -

Radiological Controls for monitoring all radiological activities associated with the processing and handling of radioactive wastes and for ,

providing advice on radiological matters relating to processing, packaging I and shipping.

7.3.3 Director-Nuclear safety Assessment The Director-Nuclear Safety Assessment is responsible to monitor and audit radioactive waste processing operations and radioactive waste or material I packaging and shipping to the extent necessary to verify they are .

performed in accordance with ectablished procedures, applicable l administrative controls and regulatory requirements.

7.3.4 Pesponsible Department "anaaet; Each manager shall establish the req.. i r ement s for personnel qualification I and institute training and indoctrinstion to satisfy these requirements.

Training requirements shall be comme::surat e with the importance and complexity of*the activity performed.

i fCAPLAU.P7 62.0

NLIC Fs>i I cpu NUCLEAR OPERATIONAt n==bar ggALITy ASSURANCE PLAN 1000-PLN-7200.01 1

Title:

8.0 control of Corrective Actions and Revision No. l Nonconformances 7 l l

l 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 General I 8.1.1 Nonconforming materials, parts, components, services or activities within the scope of the GPUN Quality Assurance Program shall be identified and controlled to prevent their inadvertent utilization. Measures shall be established which ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The cause of significant conditions adverse to quality shall be determined and appropriate action taken to prevent recurrence. The identificatien, cause, and actions taken to correct significant conditions adverr,e to quality shall be documented and reported to the appropriate levels of management.

8.1.2 Significant conditions within the intent of 10CFR21 shall be reported to appropriate management levels within the affected organization for review and evaluation.

8.1.3 Some deficiencies can be promptly corrected without initiating defined deficiency and/or nonconformance reports. Such deficiencies are typically those which are .solated to singular occurrences, not repetitive in nature, and/or are such that approp;iate action to prevent recurrence can be initiated at the time the deficiency is identified and do not require any action other than reporting the occurrence. Such deficiencies, when discovered during verification activities. shall be documented in the report of the verification activity. Such deficiencies shall be analyzed as specified by Subsection S.2.E.

8.2 Beautrements 8.2.1 Nonconformances include both hardware problems involving materials, parts, components or systems which do not comply with established requirements and non-hardware problems such as failure to comply with the Operating License and Technical Specifications, procedures, regulations and/or other established requirements.

8.2.2 It is the responsibility of all organizations and individuals involved with the TMI and Oyster Creek Maclear Stations to identify and report all nonconformances that affect structures, systems, equipment, materials, parts and components <:ithin the scope of this plan. These nonconformances may be of a minor nature as a result of wcrk activities, inspections, monitoring or revieus; or of a mayor nature such as those reportable directly to the NRC under 10 CFR Parts 21, 50 and 71 or the station's Operating License and Technical Specifications.

8.2.3 Activities such as examinations or checks performed to assess the condition of equipment or its operation are not considered to be nonconformances until it has oeen determined that it does not comply with established acceptance criteria. These activities shall, however, be documented on an appropriate form to control the activity. Once it has been determined that a nonconformance exists the condition shall'be reported as a nonconformance and the item controlled to prevent inadvertent use prior to correction.

8.2.4 Procedures shall be established which detail and implement the following corrective action system measures:

a. Conditions adverse to quality shall be evaluated to determine the need for corrective action.

ecuum n 63.0

r g j '"J-'y GPU NUCLEAR OPERATIONAL Numbar QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title 8.0 Control of Corrective Actions and Revision No.

Nonconformances 7

b. Corrective action documentation of significant deficiencies shall include identification, cause, and actions taken to correct and to preclude the similar recurrence. Nuclear Safety Assessment Department concurrence is required for corrective action disposition for all Nuclear Safety Assessment Department identified I nonconformances.

l C. Follow-up activities shall be conducted to verify implementation of corrective actions and to close out corrective actions in a timely l manner. I

d. Significant deficiencies, nonconformances and defects which are )

potentially reportable to the NRC shall be identified to appropriate management levels for evaluation and reporting to the NRC, as appropriate.

8.2.5 Procedures shall be established which detail and implement the requirements for identification and control of nonconforming items and activities and for the identification of the cause of the conditions and the actions to be taken to correct the conditions to prevent recurrence.

These procedures shall include requirements for the followings

a. Identification of the form to be used for reporting the nonconformance,

b. Description of the nonconforming item or activity and date of identification.

c. Identification of the initiator of the nonconformance report,

d. Description of the nonconformance, including identification of the requirement violated,

e. Identification of nonconforming items by appropriate means (tags, labels, etc.) and segregation, if practical, until disposition of the nonconforming item has been determined,

f. Disposition of nonconformance. The disposition shall be determined by the organization responsible for the nonconformance. Rework and scrap dispositions are made b; the material user without engineering review; use-as-is and repair a:epositions require concurrence and Justiftcation of cognizant engineering organizations. The Quality veri f t eat ion orgar.i:st ion .1 concur with all dispositions except those originated during rece:pt inspection. Receipt incpection hardware nonconformance dispos 2tions will be egneurred with by Plant Engineering.

Note: The individual providing the disposition will not sign for concurrence or verification of the disposition.

g. Notiftcation to the affected organizations of the nonconformance.

h. Verification method, verification and close out.

1. Record retention.

3 Bcqaired approval :ignatures cf the disposition and the verification.

1

k. Evidence of review for reportability to the NRC.

{

l r eartari. P 7 64.0 ,

1

4 Nusfrr cpu NUCLEAR oPERATzoNAt Numd=r

QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title 8.0 Control of Corrective Actions and Revision No.

Nonconformances 7 I i

8.2.6 Reworked, repaired, and replacement items shall be inspected and tested in accordance with the original inspection and test requirements or acceptable alternatives as determined by Engineering and the Quality Verification organization. (Note the Quality-Verification organization is not required for hardware nonconformances found during receipt-inspection.) All inspection, testing, rework, and repairs shall be l controlled by approved procedures and the results documented. 4 1

8.2.7 Prior to the initiation of a preoperational test on a safety related item all nonconformances shall be evaluated for significance or. impact on further testing or operation and shall be dispositioned as appropriate.  ;

The evaluation / disposition shall be documented. )

8.2.8 Nonconformance reports and those deficiencies addressed in 8.1.3 shall be periodically analyzed to detect adverse trends as'may be present. Such ,

analysis will be based upon severity, number, frequency of  ;

nonconformances, the causes of the nonconformances and the timeliness of '

the reporting and resolution of nonconformances. The results,of analyses shall be periodically' reported to management for review and assessment.

When significant conditions are identified or when actions are required by upper management to correct problems, such as a generic problem identified by the trend. analysis or repetitive failure to disposition i nonconformances, these problems shall be elevated to upper levels of )

management for resolution. J 8.3 Responsibilities 8.3.1 h Director-Nuclear Safetv Assessment I The Director-!!uclear Safety Asseccment is responsible for the followings

a. Review and concurrence of all procedures for reporting and controlling of nonconformances for compliance with the requirements of this Plan.  ;

b. Review, verification and concurrence with closeout of  !

nonconformances, when required. I 8.3.2 Director TMI and oyster Creek The Directors TMI and OCNGS are each responsible for ensuring that nonconformances are reported and corrected for all activities within the scope of this plan. Plant itens such as failures, malfunctions, deficiencies, deviations and defective materials, parts or components are handled in a manner consistent with their importance to nuclear safety and reviewed in accordance with appropriate procedures and the applicable Technical Specification.

8.3.2.1 Maintenance Director The Maintenance Director through the Quality Verification Manager is responsible fort

a. Initiation of nonconformances for items found unacceptable during inspection as required by procedures.

b. Review, verafication and concurrence with closeout of non-conformances when required.

V 1 OCAPLAH.P7 65.O ,

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l Nu3bcr cpu NoCtEAR oPERATim u QUALITY ASSURANCE PLAN nueer lOOO-PLN-7200.01 l

Title:

8.0 Control of Corrective Actions and Revision No, j Nonconformances 7 l 8.3.2.2 Plant Enaineerino Director The Plant Engineering Director is responsible for:

a. Initiation of nonconformances for items found unacceptable during receipt inspection.

b. Review, verification and concurrence with close-out of nonconformances for items found unacceptable during receipt inspection.

8.3.3 Recoonsible Department Mananer 8.3.3.1 Each Director / Manager is responsible for the disposition and corrective action of nonconformances identified as within the scope of his responsibilities.

8.3.3.2 Each Director / Manager is responsible for ensuring that nonconforming conditions are identified and controlled in accordance with approved procedures. Concurrence with dispositions will be as required by procedures.

1 I

l c c A rtati . 8 ' 66.O

. . . - . _ . - ~ . . - - - -- - - - - . ~ - - - --

I hlLl$h)(17 GPU NUCLEAR' OPERATIONAL Humber QUALITY ASSURANCE PLAN lOOO-PLN-7200.01 i

d Titlet 9.0 Control of Training Revision No.

?

7 i

9.0 CONTRbL OF TRA'. WING ]

i

9.1 General 1 I l l GPU Nuclear is committed to the safe operation of its nuclear generating 1

stations and the ptotection of the public health and safety. This

, commitment is accomplished, in part, by developing or maintaining the i j knowledge and skills necessary to manage, supervise, perform and verify activities within the scope of this Plan.

] GPU Nuclear considers training to be an important means of effectively

developing and maintaining proficiency and solving or avoiding performance

problems. Therefore, training shall be provided as determined to be

necessary which develops, maintains and supplements the skills and knowledge necessary to perform activities within the scope of this Plan.

Training shall be based on training need assessment. The extent to which j prior education, training and experience is sufficient to provide for the requisite job proficiency will be considered in deciding whether and what training will be provided for an individual. The content of the training 3 provided shall be consistent with regulatory requirements and commitments.

9.2 Pecuirements 9.2.1 Programs accredited by INPO shall be developed.and maintained in accordance with a Training System Development (TSD) process. Such a process provides a systematic approach to the design, development, and delivery of effective training programs. TSD is based upon behavioral learning objectives which are linked directly to job performance requirements.

9.2.2 The training programs associated with Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Protection, and Security Force Training shall be implemented and conducted by training plans and procedures comparable with the GPUN TSD process. The depth to which the process is applied may vary from program to program, but the implementation and conduet of training vill be based upon behavioral learning objectives which are linked to job performance requirements.

9.2.3 The documents associated with the trn;ning programs accredited by INPO and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security Force Tra:ntny Programs shall be reviewed, concurred with, and approved in accordance th the Training Management Control Documentation System proceuare tu arcare that related regulatory, management, technical, and functional requirements and commitments are incorporated.

9.2.4 Technical content review and interface process shall be established between the user department and the Training and Education Department to assure programs accredited by-INPO and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire B igade, and Security Force Training Programs are updated to reflect Lob performance, plant modifications, procedure changes, regulation changes, and job scope changes. >

9.2.5 The revaew and approval of the specific training program documents 'l' cevele ped and/or implemented by organizations, including contractors and/cr venocrs, other than Training and Education Department shall be delineated in procedure (s) or plan (s). The extent of Training and Edacation review of such training shall be as defined by a procedure (s) or ,

plants). I f

a (C APLMI. P 7 67.0 .

j

, , . . _. . . . . . , , , - _ . . . . , . _ _ _ ,__ _ , . _ _ - .______,m . _ . . _ _.

i Nucirr GPu NUCLEAR oPERATloNAL Number l QUALITY ASSURANCE PLAN 1000-PLN-7200.01

Title:

9.0 Control of Training Revision No.

7 9.2.6 Procedures shall be established for the qualification and certification of l instructors for programs accredited oy INPo and the Radiation Worker, l Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security l Force Training Programs.

9.2.7 To assure the integrity of qualification processes which utilize examinations, procedures for the control of examinations shall be used to address examination security.

9.2.8 A program and course evaluation process (s) shall be used to evaluate the effectiveness of training programs and courses in meeting training ob)ectives and in improving Joo performance. Such a process (s) and the extent of its usage shall be delineated in the appropriate procedure (s) or plan (s).

9.2.9 Procedures shall be established to assure that all required records associated with training provided within the scope of this Plan shall be identified, generated, maintained, and retrievable. These training records shall be sufficient to provide evidence of the content and ob]ective of the training provided, attendees, and date of attendance.

9.3 Responsibilities 9.3.1 Director-Nuclear Assurance l The Director, Nuclear Ascurance it responsible through the Training and Education Director for pro /1 ding selected training to GPU Nuclear and specified contractor personnel ac necessary to prepare them to carry out their assigned duties and to n.eet corporate policies, applicable laws, regulations, licenses, and technical requirements. Specifically, the Training and Education Director, chall be responsible for the establishment and maintenance of a training organization tot

a. Manage the training function consistent with regulatory requirements and commitments, corporate priorities, and the Training and Education Department TSD Procect.

b. Provide' personnel with training .:hich supports the development and maintenance of kno.eledge and scills required to perform activities within the scope of this Pla: :: a manner that will ensure the safe and effective execution cf their duties.

! c. Assure that the content of tra;ning provided by the Training l Department is consistent with and incorporates appropriate GPUN, local, state and federal regulatory requirements and commitments, including timely requalification.

9.3.2 Departmant Directors and Manaaers Department Directors and Managers are responsible for assuring that their staff members are qualified to carry out assigned activities within the scope of this Plan. Training activities performed under their direction shall be performed cons:ctent .ci t h the requirements of this Section of this Plan.

l l

OC APLAll . P 7 68.0 l

l l

ENuabcr GeV NUCLE ^n OPEn^T1oNat QUALITY ASSURANCE PLAN numdsr 1000-PLN-7200.01

Title:

10.0 Assessment Revision No. i 7

I 10.0 1.SSESSMENT 10.1 General

a. A program of assessment will be conducted by the Nuclear Safety Assessment Department. The assessment program will combine elements ;

of assessment, monitoring, and audit to assess the adequacy of j performance for activities within the scope of this Plan,

b. Attributes such as accomplishment of objectives; ability to meet management expectations; and compliance to procedures, policies, plans will be considered when planning and performing assessment activities.

c. Nuclear Safety Assessment Department personnel will not have any direct responsibility for managing or performing activities being assessed. Nuclear Safety Assessment Department personnel wil'_ meet applicable qualification standards when required.

d. Assurance activities performed by other organizations (e.g. Quality verification) will be periodically evaluated to assure compliance to this Plan and applicable procedures.

I 10.; AUDITS 10.1.1 General A comprehensive and docurrented audit system shall be established, implemented and maintained to ensure that:

a. Plans, procedures and instructienc define sufficient organizational responsibilities, prescribe methods and provide results consistent '

with Operating License requirements, other regulatory requirements I and commitments, technteal requirements, contractual requirements, and this Plan,

b. Plans, procedures and instructions are effectively implemented.

c. Corrective aetton systems and n.anagement reviews provide for timely completion of requtstte action for identified deficiencies /

nonconformances/cccurrencec/ events.

d. Corrective action systems and management reviews provide effective identification and prevention of recurrent and/or significant program nonconformances,

e. Data is provided for CPUN management to optimize the efficiency of methods utilized to ensure regulatory compliance,

f. Data is provided for the continuing assessment of the effectiveness of all elements of the CPUN Qualaty Assurance Plan and implementing documents.

10.3 Peauirements 10.3.1 A comprehensive system of audits shall be established and conducted for both enternal and external actavities which are within the scope of this Plan.

TCAPLWl P7 69.0

N 8t'vr CPU NUCtzA8 oPtRATloMAt numb =r

(' ' " -

QUALITY ASSURANCE PLAu 1000-PLN-7200.01 Titles 10.0 Assessment Revision No.

10.3.2 Planned and scheduled audits shall verify compliance with the following:

! a. Operating License conditions, Technical Specification requirements, other regulatory requirements and commitments and the requirements of this Plan,

b. Regulatory Guides, ANSI Standards, and other codes and standards as endorsed by Appendix C of this Plan or other regulatory requirements or commitments,

c. Documents which prescribe methods and provide the technical l requirements for activities or items within the scope of this Plan.

d. Contractual requirements associated with external organizations providing nuclear fuel, in-core components and selected technical support and engineering services within the scope of this Plan.

10.3.3 The audit system shall include:

a. Delineation of the authority, responsibility, and organizational i independence of those responsible for the management and conduct of the audit program.

I

b. Procedure (s) for the qualification and certification of lead auditors.

c. Procedure (s) for the scheduling, preparation, performance, reporting of the results of audits, and distribution to appropriate levels of management.

d. Periodic analysis of audit results and the reporting of such results to appropriate levels of management.

e. Follow-up action to be taken based upon individual and collective audit results.

10.. 4 The frequency of conduct:ng schedule: :nternal audits shall be as specified in the nuclear unitc' Techn: cal Specifications. Unscheduled audits may be conducted at any time. Re-audits shall be scheduled as may l be required to assure that correcttve iaction(s) to previous audit results has been effectively implemented, ]

j l

10.3.5 The frequency of conducting external aadits of selected suppliers of '

technical support, e nv i ronnie n t a l monitoring, raowaste shipping, computer, j radioanalytical, and engineering services shall be scheduled once within the life of the activity or every three years depending on the duration of the contractual relationship.

10.:.6 Each audit shall be led by a CPUU certified lead auditor. Audit team members shall be utilized as required and will be classified as either

, auditors or technical specialists, depending on their function on the l audit team.

10.3.7 Those GPUN and external organizatione providing items and/or conducting activities within the scope of this Plan are sub]ect to audit consistent with the regatrements of this Plan.

10.3.8 Audtts shall be performed in accordance with pre-established written procedures or checklists. The personnel utilized to perform on an audit shall not have any responsibility for the activity audited.

fCAPLAll.P7 70,O ,

ENuciocr cpu Nuctssa oPra^TronAt QUALITY ASSURANCE PLAN Numder 1000-PLN-7200.01

Title:

10.0 Assessment Revision No.

7 10.3.9 Audits shall consist of reviews of approved documents and records and observation (s) of selected activities in sufficient detail to determine the appropriateness of the documents for use, effectiveness of implementation and the effectiveness of actions taken to correct previous nonconformances.

10.3.10 Audited organizations shall provide sufficient support to assure the accuracy of the audit results, review and response to audit nonconformances, and effective resolution / prevention of deficiencies. The corrective actions required to resolve adverse audit findings shall be defined and implemented in a timely manner.

10.3.11 Audit finding nonconformances shall be followed up in a timely manner.

Such adverse audit findings shall typically not be closed until the effective implementation of corrective action (s) is verified.

10.4.12 Sufficient records shall be generated and maintained to provide documentation of audit system scope of coverage, individual audit coverage (i.e., audit plans, checklists, or equivalent), audit reports, lead auditor certifications, followup and verification and results of periodic analysis of audit results.

10.4 Monitorina 10.4.1 Recuirements 10.4.1.1 A program for Monitoring of activities affecting items or processes within the scope of this plan shall be established and executed by the Nuclear Safety Assessment Department.

10.4.1.2 Monitoring is used to ectablish adequate confidence levels that activities within the scope of this plan are be:ng performed in accordance with the QA Program requirements and plant administrative controls. Monitoring will be performed on a graded approach and the degree of monitoring performed shall be based typically upon the status and safety importance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of testing or operating activities and trending data.

10.4.1.3 Monitors shall be qualified in accordance with a documented Nuclear Safety Assessment Department procedure that ensures that Monitors are knowledgeable in the activities they are monitoring to the extent that they can readily verify compliance of the activity being performed.

10.4.1.4 Monitoring reports shall contain as a minimum the following:

a. Identification of activity being monitored including specific reference to the program or procedural requirements governing the activity. )

l

b. Indication of compliance. l

c. Identification of Monitor

d. Appropriate distribution to supervisory or managerial personnel that have responsibility for the performance of the activity.

e. Identification of each nonconformance document when such nonconformances exist and are identified as a result of the monitoring.

10.4.1.5 Records shall be kept in sufficient detail to provide adequate documentation of a monitoring program.

nown 71.0

ENuciocr cru nuctEAa oeERAT1onAt QUALITY ASSURANCE PLAN number 1000-PLN-7200.01

Title:

10.0 Assessment Revision No.

7 l

10.5 Responsibilities 10.5.1 Director - Nuclear Safety Assessment The Director - Nuclear Safety Assessment is responsible to: 1

a. Establish and implement the assessment program and assure all required areas are assessed.

b. Provide the assessment organization which meets the requirements of this Plan. l l

c. Evaluate the effectiveness of the assessment program. I 1

d. Ensure the development and implementation of an assessment schedule which ensures that all required areas are assessed.

e. Analyze the results of assessment activities for quality trends and Inform the office of the President and the affected Division Director of the results. i 1

10.5.2 Director (s) - Assessed oraanization(s) l The Director (s) of the assessed organization (s) are responsible through Directors / Managers to ensure:

a. Sufficient support is given to the assessment process to optimize the accuracy of the audit results.

b. Sufficient review of audit results is provided to assure that effective preventive measures for audit nonconformances are defined and implemented.

c. Responses to audit findings are reviewed and approved by their organizations prior tc s u b.11 t t a l to the auditing organization.

d. Responses to audit find:ng are submitted to the auditing organization in a timel:. manner as defined in implementing plans, procedures and/or instructions

e. Corrective act2cn tu rer: . ce tu a . t findings are taken in a timely manner.

1 l

1 (C APLAII . P 7 72.0

ENuciocr GPu nuCLEAn OPERATION ^t QUALITY ASSURA!!CE PLAN nume=r 1000-PLfi-7200.01 Title Appendices Revision No.

7 APPE!! DICES I

1 APPEt2 DIX A Comparison Chart of Operational Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards i 1

APPENDIX B Nuclear Safety Assessment Department Document Review Requirements f APPEtJDIX C flRC Regulatory Guide Commitments and Exceptions APPE!! DIX D Terms and Definitions 1 l

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• APPENDIX A i l $ a g COMPARISON CHART OF OPERATIONAL OUALITY ASSURANCE PLAN REOUIREMENTS

oo WITH THOSE OF VARIOUS PARTS OF THE f 1.a.3 ~e CODE OF FEDERAL REGULATIONS AND NUCLEAR INDUSTRY STANDARDS ee a

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10 CFR 50. Apo. 8 ANSI N45.2 j

Criterion OA Plan 10 CFR 71. Suboart H ANSI N18.7 - 1976 Paracraoh OA Plan Criterion OA Plan Paracraoh OA Plan Paracraoh OA Plan I 1.0 2.0 2.0;9.0 71.103 II 2.0;9.0 3.0 1.0 3.1 1.0 5.2.12 3.3 III 4.0 1.0 71.105 2.0;9.0 '3.2 -1.0 5.2.13 4.0 4.0 71.107 4.0 5.0 ,

a.3 Q IV 5.1 5.0 5.1 71.109 3.3 1.0;9.0 5.2.14- 8.0 i 54A V 3.1 6.0 3.1 71.111

.5.1 3.4 1.0 .5.2.15 3.0 I

' r VI 3.2 7.0 3.1 Supplements 5.2.16 6.6

'* p VII 5.1 3.2 71.213 3.2 4.0 1.0;2.4;2.8 5.2.17 i

8.0 5.1 71.115 6.2 1 cc d VIII 5.2 5.1 10.0 5.2.18 6.4

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, o xviII 10.0 6.7 5.2.8 -6.12 5.3.9 3.1 19.0 10.0 7.0 i 5.2.9 -

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QUALITY ASSUPAUCE PLAM 1000-PLN-7200.01 l I l l

Title:

Appendices Revision No.

l l

l APPENDIX B Nuclear Safety Assessment Department Document Review Recuirements Nuclear Safety Assessment Department shall selectively review documents which

! prescribe methods to implement activities within the scope of this Plan or provide the l quality and/or technical requirements for items, parts, materials and activities that i l

are within the scope of this Plan. The purpose of such reviews is to verify that such l documents are consistent with the requirements of this plan. The minimum content of a Nuclear safety Assessment Department document review, as appropriate to the document reviewed, is provided in Subsections 3.1.2, 4.3.3, 5.1.2.3.(e), 6.2.1.1 and ,

I j 6.2.2.2.(b) of this Plan.

l The types of documents typically reviewed include plans, procedures and instructions, i procurement documents; work authorizing documents, and changes; etc. Refer to Section l 3.2.2.1 for specific types of documents which will periodically be verified by Nuclear l Safety Assessment Department review.

l Nuclear Safety Assessment Department revie.s of documents within the scope of this plan may be conducted before or after the documents have been approved for use.

l Furthermore, Nuclear Safety Assessment Department niay review all or a sample of specific types of documents within the scope of this plan. Typically, reviews of documents are conducted during the course of audits of functional areas. When appropriate document reviews will also be conducted during other assessment activities.

l Nuclear Safety Assessment Department Procedure (s) vill be written and implemented:

1 e To define the typical scope of document reviews.

e To provide for the periodic analysis of document review results. The l l analysis may be conducted utilizing statistical techniques if deemed i i appropriate or a more qualitative analysis may be employed. As a minimum, comment types and rates resulting from document reviews will be recorded to provide for a measurement of adequacy. The appropriate corrective action mechanism will be initiated uhen adverse trends are detected to obtain the desired level of perfor..ance.

Some plans, procedures and/or instructions are re3: ired by this OQA Plan to be

" reviewed for concurrence" by the D;recter-: F .ec r Safety Assessment. Such documents and changes shall be reviewed by the Nuclear Sate: Assessment Department prior to implementing approval. Other plans, proced-res, and/or instructions and changes thereto may be reviewed for concurrence by the Nuclear safety Assessment Department.

These documents shall be identified on the CPUM R e v i e'. and Approval Matrix.

l t

l f(APLAH.P7 75.0 l

l l

l Nu21rr cpu NUCLEAR oeERAT!oNAI.

QUALITY ASSURA!!CE PLAN nue.r 1C00-PLN '200.01

Title:

Appendices Revision No. i l

7 APPENDIX C OUALITY ASSURANCE PROGRAM NBC REGULATORY CUIDE COMMITMENTS bilD EXCFPTIONS This Appendix identifies those Regulatory Guides which contain Quality Assurance Program requirements and identifies the CPUN positions relative to compliance. Part I of the Appendix is a tabulation of the Regulatory Guides the corre:ponding ANSI Standard and Remarks. Alternatives or clarifications are detailed in Part 2 of the Appendix.

Compliance with these Regulatory Guides will apply to modifications, additions and activities performed after issue of this QA Plan and does not imply backfitting and/or retroactive compliance. It is also to be recognized that existing plant conditions, may prevent or preclude the satisf action of all requirenent s of a specific Regulatory Guide. These

, conditions will be documented and, alcng with the Justification, will be

, approved by the Director - !!uelear Saf ety Assessment.

i l

ccoun.n 76.o

APPENDIX C, PARTI COMMITMENT TO QUALITY ASSURANCEREGULATORYGUIDES FOR GPUN DEGRiiE OF RI G C.UIDli ANSI SIT). COMPI LANCE RFMARKS o

O I8 - 5/77, Rev. I-R f Personnct Scicction and Training N18.1 1971 . Modified See attached commcnis.

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$ e 4.26 2/76. Rev. 3 OA Clauificatsons and Ssandards Modif4d See attached coenments.

,g jN for Watcr Sarcam and Rad oactive ee in -

Wasic Contaming Components of jo Y Nucicar Power Plants .

s o e z -4 oc b l.25 2/79. Rev. 2 Quahty Assurance Program N45.2 1977 Full Comply with Regulasovy '

Requiremenas (Ocsign and Position.

Construction) 1.29 9/78. Rev. 3 Scismic Design Classification Mt*hfied Same comment as for Reg Guide I.26 j=j o

130 8/11/72 OA Requirements for the Install- N45.2.4 1972 Manh6cd See attached commenss.

c. action, inspccsion and Testing jw E

of Instrumcniaanin and lilecincal a:M liguipment R

y$

O 1 31 4/78. Rev. 3 Control of Fernte Conicns in o

I ull Comply with Regulasory Posalion. E oc A9 ' Stainicss Stect Wcld Mc al "

4 4 faa j3 4 33 2/78, Rev. 2 Quahey Assurance Program NIS 7 1976  % mh6cd See attached comments.

g[ Rcquircments (Operation) .

I ~4 g$O l 37 .3/16/13 OA Requirements for ricaning of N45 2.1 1973  %=hised &c attached comments 0 llued Spicms and AsunsatcJ Componcnis of Water Caulcd Nuticar Ptmcr Planes 13N 5/77. Rev. 2 OA Requiremsnes for PasLaging. N35 2 2 1972  % =hfacd &c assachcJ cumawats Shipgung. Rct'ening. Stora;;c and g llandling of Issms for Watcr o Cooled Nucicar Powcr Plants

.4 b

139 9/77.Rev.2 IlouncLccping Rcquercmcats for N45 2 3 1"73 M mh6cd Scc assached summents

o. Water C<mico Nuilcar Pimer O'

suma < Plants i O 5 8 54 6/73 OA Rcquirements for Pn ictieve tal 4 1972 M.=h6cd Scc assached commcnis g Comiengs Apphcd so Watcr C ukJ Nucicar Po.cr Plams e

ce e3

--4 H

. L'

t APPENDIX Ce PART I DEGREE OF i REG. GUIDE ANSISTD. COMPLIANCE REMARKS t

t g 5.58 9/80, Rev. i Qualifications of Nuclear Powcr N45.2 6 1978 Modified See attached commcats. [

. Plant inspection, finamination L 8 . and Tchaing Personnel r4 0 r- 2;  ?

e if4 6/76, Rev. 2 Quahay Assurance Requiremenes N45.2.11 1974 Modafied See attached comments.

3 5 A- *

$n for the Design of Nuclear e is Power Plants i

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$ l.74 2/74 Quality Assurance Terms and N45.2.10 1973 Full Comply with Regulatory Dcfinitions Position. I i

1.88 10/76, Rev. 2 Collection Starage and Main- N45.2.9 1974 Modified See assached comments.

icnance of Nucicar Power Plant

• Quahiy Assurance Records i

A gR I.94 4/76 Rev. i QA Requirements for Instal- N45 2.5 1974 Modifico See attached comments.

Od lation. Inspection and Testing of y

Structural Concrcic & Sicci  !

yy during Nucicar Powcr Plan i sa " Const ruceson

'o ak o g ;n I.Il6 5/77.Rcv.O.R QA Requirements for Installa. N4528 1975  %= bleed Scc assached commcnis. n$ i yE sion. Inspccreon and Tcsting of *

a. Mcchanical liquipmens and Sysicms j u"

p 0+ t Z3 1.123 7/77. Rev. l QA Requircments for Control of N45 213 197f.  %=hficd See assuhcd comments. '

ay Procurement of licms and Scru

$Os kcs for Nuclear Pomer Plants i

' I I 142 10/81.Itcv.I Safcay.Rclaicd Concrcic Siruc. N45 2 5 1974 %ideficd Sec attached comments.

surch for Nuclear Powcr Plants A W. 4 1977

((liher than Reactor Wucl> AfDl8 1977 and Containmcnis) ta 8 1.14) Design Guedance for Radnuctisc Sec alished commcnas 10/79. Rev i  % defecd [

w Wasic \tanagcment Sptcms.  !

, b E Strutturcs. and Components [

b #

g inssailed in I sght. Water-O O.

4:

Cooled Nusicar l'omcr Planis i i

0 I.144 Itcquircments for Auditing of g t/79 N45 212 1977  %=hficd Sec assuhcd comments

()uality Anurante Programs for Nuikar Pomcr I' lanes e

I 146 8/80 (Jualificatman ist Quality N45 2 I) l'ull Comply with Regulatory

]

w 1978 Anurance Program Audesurs Position. ~

N for Nuclear Powcr Plants I 3

2

_ - . .-. . .- -. - . ~ . - - . -- - - -_ ~ - - - - . _ _ ~ - . - .

Nuabcr GeV NuCLtAR OerRAT10NAt QUALITY ASSL'RANCE PLAN -

Number 1000-PLN-7200.01

Title:

Appendices Revision No.

7 APPENDIX C - PART 2 NRC Reoulatory Guide 1.8, Rev. 1-R, May 1977 Perr.onnel Select ion and Trainino

1. Guidelines have long been established in the company with respect to awarding ,

jobs to plant maintenances operations, and other bargaining unit personnel who may be. involved in testing, examination and inspection activities.

Personnel are qualified in accordance with the Job Description Manual. GPUN believes that the requirements specified in the Job Description Manual meet the intent, and in many cases, . exceed the requirements of ANSI N18.1. In ,

certain specific cases, we envision-that there may be individuals in the future who will'be qualified by GPUN because it feels.the individual is capable of performing a job even though the individual does not meet the  ;

detailed guidance contained in. ANSI NIS.1 with respect'to length of '

experience and formal training.

The unit staffs and the corporate organizations have been upgraded to meet ANSI /ANS 3.1-1978 except as otherwise noted.in the Technical Specifications.

L

2. For the NRC licensed positions of Reactor Operator (RO) and Senior Reactor Operator (SRO), the experience requirements of ANSI 3.1 - 1981 will be utilized to determine if candidates steet NRC licensing eligibility .

requirements, until the applicable site's simulator has been certified in accordance with.10CFR50.45.(b). In accordance with NURtc 1262,. Questions 100 and Ill, GPUN may accept candidates inte the RO and SRO training programs who '

do not meet the detailed guidance contained in ANSI 3.1 - 1981 if GPUN feels that the candidate .is capable of perf orn.ing the job and if those programs util;ze a simulator certified in accordance with 10CFR50.45.(b).

NPC Peculatory Guide 1.26. Rev. 3. Februarv 1076 Oualitv Group Classification and Standard f o r 'Ja t e r . Steam and Radioactive Waste Cont a in tn Components of Nuclear Power Plant s S.nce the original design and: construction cf TMI-I and Oyster Creek was to different classification criteria than contained in this guide; GPUN will comply .

with the regulatory position of this guide alth the following clarificationst '

l 1. For modification to existing plant cy r t ers , items will be classified by Techntcal Funettons accord:r.g tc thc or.ginal design basis or this guide.

This classification will not deg ra cis- t:p cafety.of the system being modified.

2 .- Additions to exAsting plant'systemc .::!! be made to the same code, standard l and technical requirements which were originally applied to the system to which the addition is to be made or tr. ore recent versions.of these codes,  :

i standards and technical requ i ren er:t s . The addition will not degrade the  !

! safety of the. system being added tc.

3. For new construction, the latect app 1trable code willL be utilized unless such utilization would result in hardch:p or unusual difficulty without providing an equ2 valent level of safety i

d q1 f C API.Att . P 7 79.0 , , ,

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_.- _ - _ _ -- - , _ - - _ . , - _ . . ~ _ _ _ _ _ _ _ . _ - _ - _ _ _ . _ . . . - . . _ . , . - , - . _ . _ _ . . _ .

i Nucirr GPu nUCtEAR OPERATIONu Nu e r QUALITY ASSURANCE PLAN 1000-PLN-7200.01 l

l

Title:

Appendices Revision No.

l 7 l APPENOIX C - PART 2 i

NPC Reaulatorv Guide 1.30, Auoust 1972 l

Quality Assurance Beauirements for the Installation, I n spect ion and Testino of Inst rumentat ion and Electric Ecuipment GPUN shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to maintenance and modification activities even though such requirements I

were not in effect originally. Technical requirements associated with maintenance and modifications shall be the orig 2nal tecnnical requirements or better (e.g.,

code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

Sections 5.2 and 6.2 of ANSI N45.2.4 list tects thich are to be conducted during the construction phase. In lieu of this, GPUN utilizes its Engineering and/or Maintenance organt:ations to establish the need for specific tests or test procedures during the operational phase.

NPC Peculatorv Guide 1.33. Per 2. Februar- 197E l Ouality Assurance Procram Pecuirements (Operation) l The CPUN QA Program complies uith the regulatcry position of this guide with the following clarifications:

1. Regulatory Position C.4 of the regulatory guide Tne frequency of performance and the minimum topical coverage of internal audits will be consistent v:l t h Section 6 cf the nuclear units' Technical Specifications. Paragraph C.4.a in interpreted to mean audits will be conducted once each 6 months to verif; that the nonconformance and corrective action program is properly implemented and documented, particularly as related to actions taken to correct def2riencies that affect items classified as nuclear safety related or regalait required.

2. Paragraph S.1 of ANSI UlE.7-1976 titled " Program Description" 1 1

This paragraph refere to ::.e con ; . l a t . - ' cf a " summary document" to identify 1 I

the sources, index the Ecurce decure:.tr ;t the requirements of this standard and to provide a consolida ce base fs t :.e oescription of the program. For the purpose of clarlty, t t. i t "GK Nurie; Operational Quality Assurance Plan" is tne " summary

• cocument rey.:. re J . A p! -:..:1x A correlates the sections of this Plan to ANSI 18.7-1976. Sectic: . . ' . trovides the " consolidated" base l and description for the progrart. In plem-nt ing document s are identified in l Section 3.0, are required to be cons. stent with this Plan and Appendix C of l

this Plan, and are marked ar stated in Section 3.0. l

3. Paragraph 5.2.2 of ANSI N15.7-197E titled " Procedure Adherence" In accordance with Section 6.8.3 of both the Oyster Creek and TMI-1 Technical S pec i f i c a t ions , temporary changes shall be approved by two members of GPUNC Management Staff qualified as Responsible Technical Reviewers and knowledgeable in the area affected by the procedure. For changes which may affect the operational status of facility systems or equipment, at least one of :nese andavacuals shall ne a member of facility management or supervision holding a Senior Peactor Operator's License on the facility.

r(APLAN,P7 80.O

f I

l Nucbcr Geu NuctrAP oetRATloNA:

QUALITY ASSURANCE PLAN Number 1000-PLN-7200.Cl l

Title:

Appendices Revision No.

7 APPENDIX C- PAPT 2

4. Paragraph 5.2.8 of ANSI NIE.7 - 1976 titled " Surveillance Testing and Inspection" l

In lieu of a " master surveillance' schedule, a technical specification surveillance testing schedule shall be established reflecting the stetus of

, all in-plant surveillance teste and inspections required by technical j specifications.

l

! 5. Paragraph 5.2.15 of ANSI N16.' - 1976 t it led " Review, Approval and Control of l Procedures" I

Ine third sentence of the third paragraph is interpreted to mean applicable procedures shall be reviewed following a reportable incident such as an accident, an unexpected transient, significant operator error, or equipment malfunction.

l c. Paragraph 5.2.17 of ANS: Uli 7 - 1976 titled " Inspections" l

Not all inspections will requi e a separate inspection report. Inspection requ.rements may be integrated into appropriate procedures or other documents with *he procedures

. or documents serving as the record; however, records of inspections will De identified and retrievable.

NPC Peculatorv Guide 1.37, March 16, 1C73 Ouall-. Assurance Pecairementr for Cleanin, cluids Systems and Associated Components of Vater Coc;ed Nuclear Power Plants l

t The CPUN Quality Assurance Progran coep.ier t .t h the regulatory position of this j guide with tne following clarificatic:<

1. The second sentence cf pa r a g r aiu. C.3 "-la te amended to read: l l

.ne water quality for f;na. f;ucne; of :lato systems and associated components shall be at least equi cale: t to tne quality required for normal operation. This r eq u i re:re nt ooes nra q71 ;. to dissolved oxygen or nitrogen limits nor coes it infer that en~. d er -

otner additives normally in the system water wi.. be addeu tt t r.i- fl - -ster.  !

1

2. Paragraph C.4 should be ame:.de:! tt a i

Material such as inks, temperature ind; cat;ng crayons, labels, wrapping materials (other than polyethylene), ,stcr soluhle materials, lubricants, NDT l penetrant materials and couplants, wh i cl. contact stainless steel or nickel l alloy material surfaces shall contain ne r. ore tnan trace elements of lead, l

zinc, copper, mercury or otner lox relt n; alloys or compounds. Maximum allowable levels of water l e a c n a r;l e chltrade icns, total halogens and sulfur compounds snall oe defined ana impcsea cr the aferementioned materials.

l I

l r(APLAM P? 3; O

__ J

l E Nu3bcr cpu NUCLEAR oeERATIoN^t QUALITY ASSURANCE PLAN Numb =r 1000-PLN-72OO.01 l

Title:

Appendices Revision No. ,

7 l APPENDIX C - PART 2 i l

3. Section 2.1 of ANSI'N45.2.1-1973 states that required planning is frequently )

performed on a generic basis for application to many installations on one or  ;

more projects. This results in standard procedures or plans for installation I and inspection and testing which meet the requirements of the Standard.

Individual plans for each item or system are not normally prepared unless the I work operations are unique. However, standard procedures or plans will be I I

reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section 11 Paragraphs 2 and 3 of ANSI N45.2-1977 ehich provides for examination, measurement or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

4. GPUN intends to conform to the Cleanness requirements of Section 3.1 of ANSI N45.2.1-1973 with the exception of permissible particle sizes for cleanness Classes B and D. In these cases, CPUN will conform to the requirements of ANSI N45.2.1-1980, Section 3.2.2.l(b) which states, "These shall be no pa rt ic le s larger then 1/32 in. by 1/16 in. long (0.8 mm by 1.6 mm)" for cleanness class B and Section 3.2.4.4 which states, " Particles no larger than 1/16 in. by 1/8 in. long (1.6 mm by 3.2 mm) on a 14-mesh (1.4 mm, ASTM E-ll, Specification for Wire Cloth Sieves for Testing Purposes) or finer filter, or the equivalent. for cleanness Class D.

5. Section 3.1.2.1 of ANSI N45.2.1-1973 states that surfaces shall be examined without magnification under a lighting level (background plus supplementary lighting) of at least 100 foot candles. GPUN intends to permit the use of neutral 181 gray card with a 1/32" black line for determining acceptability of illumination in lieu of the 100 foot candles.

6. Section 4.0 of AhiI N45.2.1-1973 states that items are not to be delivered to the point of installation sooner than necessary unless the installation location is considered a better storage area. The strategy f or the storage of items is based on many factors, one of which is to not adversely affect the item's acceptability while in storage. If other factors make it desirable to store an item at the installation site, and the location is acceptable from a quality standpoint, it is not our intention to eliminate that site as a potential ntorage ares. As an alternate to this requirement, items may be delivered to the inctalls::an site sooner than absolutely necessary when determined to be advanteeous for other considerations.

Example - reduced nandling or earles se:ers, thereby reducing susceptibility to handling damage. In all such cares, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1-1973.

7 Section 6.0 of ANSI N45.2.1-1973 states that where environmental contamination causes degradation of quality, seals are installed and the item is tagged with identifications and instructions for seal removal. GPUN utilizes procedural controls which specify the authorization requirements for l seal removal. " Tags" are not normally utilized.

l I

j. CC APtA11. P 7 82.0 l

l NLlSlO((7 GPU NUCLEAR OPERATIONAL Numb 2r QUALITY ASSURANCE PLAN 1000-PLN-7200.01 l

Title:

Appendices Revision No.

7 APPENDIX C - PART 2

8. Section 7.2 of ANSI N45.2.1-1973 allows piping systems to be flushed only I

with water. A water flush of piping systems using other fluids can lead to contamination and/or other problems which would affect the reliability of i these systems. ANSI N45.2.1-1980 provides requirements and recommendatiens l

for flushes using fluids other than water. For flushing of hydraulic instrument, control, lubrication and other non- water systems, GPUN intends to conform to sections 3.4.2, 3.4.3, 3.4.4, and the guidance of Table 3.3 from ANSI N45.2.1-1980. Specifications and procedures for flushes utilizing this exception must specify, as applicable: particulate contaminate levels; water content; water soluble contaminate levels; organic contaminate levels, flush time, flush pressure / flow / amount; type of fluid to be used; and, the restrictions identified in Sections 3.4.2, 3.4.3, and 3.4.4.

NPC Reculatory Guide 1.38, Rev. 2, Mm 1977 Ouality Assurance Pecuirements for Packaoino, Shinofno, Peceivino, Storace and Handlino of Items for Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with the regulatory position of this guide with the following modifications or clarifications to ANSI N45.2.2-1972:

1. Section 2.4, Personnel Qualifications. As a point of Clarification, personnel who perform the audit (s) described in Section 2.4. will not b' qualified in accordance with ANSI N45.2.6. Such personnel are qualified in accordance with Regulatory Guide 1.146, dated 8/80.

2. Section 2.7, Classification of Items. The four-level classification system for storage of items will be followed, however, the designated issification level may not be explicitly identified on the item. The class. ation level will, however, be traceable through the procurement documents.

Classification differing from section 2.7 will be considered acceptable provided no degradation is assured; for example, electric motors designed for outside service may be stored in a level C area rather than a level B.

3. Section 3.2, Levels of Packaging. The four level classification system for packaging of items may not be used explicitly. For commercial grade items standard commercial grade packaging requirements may be specified.

4. Section 3.6 concerns prevention of haloaennted n aterials from contacting stainless steel or nickel alloy mater.c.' The clarifications applicable to Regulatory Guide 1.37, identified pre"1-..rly, also apply to this section of ANSI N45.2.2.

5. Section 3.7.1 Cleated, sheathed boxes call De used up to 1000 lbs. rather than 500 lbs. as specified. This type cf bov i. e4:e for, and has been tested for, loads up to 1000 lbs. Ot ner ma' i- c a t trandards (i.e., FED Spec.

PPP-8-601) allow this. Special qualificat<a tbs:3.? shall be required for loads in excess cf 1000 lbs.

6. Section 5.5, Correction of Nonconformances. This section provides for rework- and "use as is" dispositions for nonconforming items. As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used.

7. Section 6.2.1 for storace of level D items access will be controlled and limited by posting. Other positive controls such as fencing or posting of guards will be provided for higher storage levels.

resn ati.p7 83.0

NLIC:bc c r cpu NucttAn oeEnATloNAL ouAtlTy AssuaANCE ptAN uu b=r lOOO-PLN-7200.01

Title:

Appendices Revision No.

7 APPENDIX C - PART 2 l

l

8. Section 7.4 states that a system should be established to indicate l acceptability of all equipment and ragging after each inspection, specify .

control of nonconforming lifting equipment, and supplement periodic l ir.spections with special visual and nondestructive examinations and dynamic l load tests. In lieu of this, GPuN does perform dynamic load tests on new equipment, preventive maintenance on cranes, nondestructive examination of lifting hooks annually, and a visual inspection of lifting equipment prior to use.

9. Appendix A.3.4.1 The last sentence of L.3.4.1(4) and (5) should be corrected as follows:

(4) "However, preservatives for inaccessible inside surfaces of pumps, valves and pipe systems containing, reactor coolant water shall be the water flushable type.'

(5' "The name of the preservative used shall be indicated to facilitate touch up.'

10. Appendix A 3.4.2, Inert Gas Blankets. There may be cases involving large or complex shapes for which an inert or dr, air purge flow is provided rather than static gas blanket in order to provide adequate protection due to difficulty of providing a leak proof barrier. In these cases a positive pressure purge flow may be utilized as an alternate to leak proof barrier.

11. Appendix A.3.5.2 Tapes will meet a sulpnur limit of 0.301 by weight instead of 0.10s as specified in A.3.5.2(1)(a).

This limit is reasonable based upon the c h ea,1 c a l content of commercially available tapes. Tapes will be of a contrasting colur rather than " Brightly Colored" as required by A.3.5.1(;).

12. Appendix A.3.7.1 In lieu of A.3.'.;(3) and (4), the following will be imposed: Fiberboard boxes shall be securely closed either with a water resistant adhesive applied to the entire area of contact between the flaps, or all seams and.]oints shall be sealeo uith not less than 2-inch wide, water resistant tape.

NPC Peculatory Guide 1.3C, Rev. 2, Sentomber : ~~

Hourekeepino Pecurremente for Water Cnnled Morlear Pouer Plancs Endorses ANSI N45.2.3

- 1973 The CPuN Quality Assurance Program complies with this guide with the following clarification to ANSI N45.2.3-1973.

1. Sections 2.1 and 3.2 The Nuclear stations vill not utilize the five level l zone designation system referenced in ANSI N.15 . 2 . 3 , but will utilize standard I janitcrial and work practices te maintain a level of cleanliness commensurate I with company polley in the areas of heu t e r.ee p i ng , plant and personnel safety, and fire protection.

Cleanliness will be maintained, consictent with the work being performed, so  ;

as to prevent the entry of foreign mater.al into systems within the scope of this plan. This will include as a minimum documented cleanliness inspections which will be perf ormed immediately prior to system closure. Control of personnel, tools, equipment, and supplies vill be established when major portions of the reactor system are opened for inspection, maintenance or repair. l l

l l

rcAPLAn.P7 84.C

~l 1

NUCPX.T GPu NuCttAn oeERATIOn^t ===bar 1000-PLN ~1200. 01 QUALITY ASSURANCE PLAN

Title:

Appendices Revision No.

7 APPENDIX C - PART 2 Additional housekeeping requirements will be implemented as required for i control of radioactive contamination.

2. Section 3.2.3 discusses fire protection. Except for the quality assurance aspects of fire protection, no specific commitments are made in this Plan.

As part of other activities, GPUN has established positions or commitments relating to fire safety or protection.

NPC Peculatorv Guide 1.54, June 1o73 Ouality Assurance Pecuirements for Prot ect ive Coat i nas Appl ied to Water Cooled Nuclear Power Plants Tne GPUN Quality Assurance Program complies with this guide with the following clarification:

1. CPUN will comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to mau.tenance and modification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) shall be the original requirements or better.

2. Tne quality assurance program for protective coatings includes the planned and systematic actions necessary to provide adequate confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service.

All protective coatings, except those ncted in 3 below, applied to surfaces within containment are tested to den,onst rate that they can withstand LOCA condit ions . These tests are performed in accordance with Section 4 of ANSI N101.2, Protective Coatings (Paints) fer Light Water Nuclear Reactor Containment Facilities, under LOCA cendations which equal or exceed those described in the FSAR.

The quality assurance program is applied for Protective Coatings consistent with the nature and scope of scrk cpec;fieJ in the technical specifications.

The following elements are incluue.

(a) Preparation of coa:Ingr crecificatzen and procedures for generic coating ,

materials / systems.

l (b) Review and evaluation of coating ca.nufacturers' demonstration test data and quality assurance n.easures for control of manufacture, identification, and perf orn.ance veri f icat ion of applied coating systems.

(c) Review and evaluation of supplier qaality assurance measures to control storage and handling, surface preparation, application, touch-up, repair, curing and inspection of the coating systems.

(d) Training and qualification of inspection personnel in coatings ins pe ct i on requirements.

(c) Sapplier serve 111ance inspection.

The ccatings qualification program and the associated quality assurance requirerents are necessary only for coatings whose failure or failure meenanisc would have a significant effect on safety, ocarua m E5.0

Nualrr GPu NuCtEAR oeEa^u oNat QUALITY ASSURANCE PLAN nueer 1000-PLN-720C.01

Title:

Appendices Revision No.

7 APPENDIX C - PART 2

3. Regulatory Guide 1.54 is not imposed for:

(a) Surfaces to be insulated.

(b) Surfaces " contained" within a cabinet or enclosure (for example, the interior surfaces of ducts).

(c) Field repair on any Q-class coated item less than 30 square inches of surface area such as:

o Cut ends or otherwise damaged galvanizing.

o Bolt heads, nuts, and miscellaneous fasteners.

o Damage resulting from spot, tack, or stud welding.

Field touch-up and repair of larger areas shall be in accordance with item (1).

(d) Small " production line" items such as small motors, handwheels, electrical cabinets, control panels, loudspeakers, etc. where special painting requirements would be impracticable.

(e) Stainless steel or galvanized surfaces.

(f) Coating used for the banding of piping.

J (g) Stripable coatings used for cleanup

4. Quality Assurance documentation may nct 1;e similar to records and documents listed in Section 7.4 througr. 7.E of A"5: NIC1.4 but will be evaluated to assure tnat they provide at leant the r:.c o degree cf documentation as required by this standard. j i

NRC Peculatory Guide 1.50 Per 2, s e n t e rne t.l_C t '. i 1

Oualifications of Nuclear Powar Plan: Inspectagat . Examination, and Testina Personnel The GPUN Quality Assurance Program comrdlec ;th this guide with the following clarification: l

1. The guidance of Regulatorv Guide 1.59 shall be followed as it pertains to the qualifications of inspection personne! :.c verify conformance of work activities to quality requirements. The qualification of other GPUN personnel shall be in accoroance with GPUN established requirements. The qualifications of plant operation personnel concerned with day-to-day operation, maintenance, and certcin terl.nical services shall conform to Regulatory Guide 1.8.

Tne qualification of nondestructive testing personnel shall be in accordance wAth the requirements and recommendations of ASNT Recommended Practice No.

SNT-TC-1A, 1980 Edition. In addition, SMT-TC-1A shall be used in conjunction with the additional provisions of the applicable ASME Boiler and Pressure Vessel Code. Later editions of SMT-TC-1A may be utilized as referenced in Section X: of the Code provicled that the edition of the Code has been incorporated by reference into Title 10 of the Code of Federal Regulations, Part 5;.55a.

r C APLAll . P 7 6b.O

! ENucirr GPu NUCLE ^a OPERATION ^t QUALITY ASSURANCE PLAN Number lOOO-PLN-7200.01 l

t

Title:

Appendices Revision No. l f 7

! APPENDIX C - PART 2 i

Recertification of NDE Level III personnel shall be at an interval of every 5 years as noted by ASME Code Case N-341 and N-356 rather than the 3 year interval recommended by SNT-TC-1A, 1980.

l Oualification and subsecuent recualification of cersonnel conductina visual examination activities within the scope of the applicable ASME Section XI edition shall be performed consistent with that applicable ASME Section XI edition as further permitted and accepted bv ASME Section XI Code Cases associated with oualification in visual examination endorsed by the current revision of Reaulatory Guide 1.1412

2. Plant operation personnel may be utilized to perform the visual leakage examinations required by the edition of ASME Section XI and related codes currently committed to for the conducted of in-service inspections. Such personnel shall be qualified consistent zith these ASME code requirements.

The selection and qualification of such personnel shall be prescribed by a procedure (s) which is reviewed and concurred with by the Quality Verification organization.

3. Not all personnel who:

A. Review and approve inspection and testing procedures, B. Evaluate the adequacy of activities to accomplish the inspection and test ob]ectives, C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, D. Certify Level III individuals in specific categories or classes, will.be certified as meeting the Level III capability requirements of ANSI N45.2.6-1978. Rather these persennel will be determined by management through evaluation of their education, experience, and training to be fully qualified and competent to perform tnese functions. The basis for the determination will be documented.

NRC Reculatory Guide 1.64, Rev. 2, June IC76 Ouality Assurance Recuirements for the Desion cf Maclear Pouer Plants GPUN will comply with the kegulator Posit;c: entablished in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to maintenance and modification activitter even though such requirements were not in effect originally. Technical requiremente ie.o., code requirements, material properties, design margins, manuf acturing prccesses, and inspection requirements) associated with maintenance and modificatien+ shall be the original requirements or better.

The Quality Assurance Program complies with this guide with the following clarifications:

1. Regulatory Position C.2(1) of the Regulatory Guide:

If the designer's immediate Supervisor is the only technically qualified andavadual ava21able, this review can be conducted by the Supervisor, providing that: (a) the other provisions of the Regulatory Guide are .

satisfied, and (b) the Justification is individually documented and approved  !

in advance by t he Supervisor 's managen.ent , and (c) audits cover frequency and  !

effee Aveness of use of Supervisors as design verifiers to guard against j abuse. i 1

i l

CCAPLAll.P7 87.0 j l

1

. . - ~ . -~ - _ _ _ _ - . . - - _- - . -- -

Nucbcr GPU NUCtEAR oPERATroMAt QUALITY ASSURANCE PtAU-Number 1000-PLN-7200.01 .

l

Title:

Appendices Revision No. 5 7

APPENDIX C - PART 2

2. Sections 6.2, 7.2 and 8.0 of ANSI N45.2.ll-1974 Each of the above sections reiterate the need to apply design control provisions equivalent to original or previously verified designs. Design control provisions include revision, review, and approval of the design document (s) affected and design verification.

The last sentence of Paragraph 6.2 could be read to imply that-two separate reviews are required for " field changes" to previously approved designs: (1) the review of field changes for the effect on overall design and (2) design verification. As a point of clarification with regard to " field changes,"

the effect of the field change will be independently evaluated and the need for design verification of the specific field change will be' determined. If the review determines that the field change has no effect on the previously approved design then that review constitutes a design verification of that l

field change. If the review determines that the field change does have an l

effect on the previously approved design then a design verification of the I resolution of that specific field change will be conducted.

Also, field changes that are " minor" as described in paragraph 7.2 of the standard will not be design verified. Procedural requirements shall be provided to identify when such field changes are " minor" in the' context of l paragraph-7.2 of the standard.

l NRC Reculatory Guide 1.88. Rev. 2, Oct obe r . 1976-Collection, Storace, and Maintenance of Nuclear Power Plant Availability Assurance Pecords GPUN will comply with the intent of this regulatory guide by compliance with the requirements of ANSI /ASME NQA-1-1979, Supplement 175-1 and Appendix 17A-1 including Appendix 17-1, NQA-1A-1921.

NRC Reculatorv Guide 1.94. Pev. 1, April 1076 Ouality Assurance Reauirements for Installation, IR20ection and Testino of Structural concrete and structural Steel durino the Construction Phase of Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification (s):

1. QA programmatic /administ rat :ve requiren.ent s included in the Regulatory Guide shall apply to maintenance and r.mdifient :on activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modificatione shall be the original ,

requirements or better (e.g., ecde ret.:rements, material properties, design margins, manufacturing processes, and inspection requirements).

2. Section 5.4 of ANSI N45.2.5-19'4 cpecifieE the calibration frequency and method of automatic cut-off impset wrenches used to make up and insoeet high strength bolted' connections; and, the calibration frequency of hand held torque wrenches used to insnect high strength bolted connections. Section 5.2.6 of ANSI 18.7 as well as 6.6 of this plan also specify controls for measuring and test equipment. Sections 5.2.6 of ANSI 18,7-1976 in' conjunction with 6.6 of this Plan shall be used in lieu of 5.4 of ANSI N45.2.5 to control the frequency of calibration of automatic cut-off impact wrenenes and hand held torque wrenches used to make up and/or inspect high strength bolted connections. The method of calibration will be consistent with the manufacturer's recommendation (s).

i reartAitr7 8S.0 7.

s

_ _-s _ __

..,_.-_,p. .,-..,.,,my, _,,m_,,_,, .,,p.-. - , , . , , . , _,

Nualrr GeU NUCLEAR OPERAT:ONAt QUALITY ASSURANCE PLAN Number 1000-PLN-7200.01

Title:

Appendices Revision No.

7 APPENDIX C - PART 2 NRC Reculatory Guide 1.116. Rev. O-R, May 1977 Ou a l it y Assurance Recuirements for I nst allat ion , Insoection and Testina of Mechanical Ecu2pment and Systems The GPUN Quality Assurance Program complies stath this guide with the following clarification:

QA programmatic / administrative requirements included in the Regulatory Guide shall apply to maintenance and modification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications, shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).

Much of N45.2.8 applies to construction and pre-operational testing. As a result, many of the listed tests are not appropriate in an operational plant. In lieu of this, GPUN utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test procedures during the operational phase.

NPC Peculatory Guide 1.123, Pev. 1, Julu 1Q77 Oua2ity Assurance Recuirements f or Cont rol of Procurement of Items and Services for Nuclear Power Plants Tne GPUN Quality Assurance Program complier ith nis guide with the following clarification:

1. Section C.3. A corrective act:on cycten may, depending upon complexity and/or importance to safet;. of tne itea ci service provided, be imposed upon the supplier. When a corrective act .a .5 in posed on a supplier, the applicable elements of Section 9.0 of tne standard will be included and its implementation will be verified.

2. Section C.4. Applicable information ec:rernina the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.

3. Section 4.2.a of ANSI N45.1.13-1970. 'nen evaluation of a supplier is based solely on historical supplier data, thece data .till primarily include records that have been accumulated i r, connectio:. uth previous procurement actions.

Data that includes expertence cf users of identical or similar products of the prospective supplier anJ product operating experience will be used if available.

l

4. Section 4.2 of ANSI N45.2.13-1976. In the special case of " commercial grade !

items" the supplier does not have to be evaluated by one of the methods identified; however, the procurement docaments shall contain requirements specific to the item being procured. l l

S. Section 7.5. As a point of clarification, personnel who perform the audit (s) I as described in Section 10.0 of this Plan will not be qualified in accordance i with ANSI N45.2.6. Such perscnnel e.re gaalified in accordance with Regulatory Guide 1.146, cated S/80.

6. Section lO.2.d of ANSI N45.2.13-1976. The requirements of this section are interpreted as f ollo.es: Tne percer atterting to a certificate shall be an authorized and responsible ecployee of the supplier and shall be identified my the supplier.

ccm.w o 69.0

l Nucirr GPu nuCLrAR OerR^T:OnAL QUALITY ASSURANCE PLAN Number ICCD-PLN-720C.Cl l

t i

Title:

Appendices Revision No.

7 APPENDIX C - PAPT 2 l

! 7. Section 10.2.1, Verification of the Validity of Supplier Certificates and the i effectiveness of the Certification Systec, is as follows: The verification l of the validity of supplier certificates and the effectiveness of the i certification system are accomplished as an integral part of the total

! supplier control and product acceptance pr gram, and nr> separate GPUN system l exists that addresses itself colel;. to such verification. The degree of l

verification required will depend upon tne type of item or service and their I safety importance. The means cf verification may include source witness / hold l points, source audits, and document revleus; independent inspections at the l time of material receipt; user tests or selected commodities, such as i

concrete components; and tests after installation on selected components and I systems. All of these means verify ihether or not a supplier has fulfilled procurement document requirements and wnether or not a certification system is effective.

UPC Peculatory Guide 1.142 October 1QB1 Safety-Pelated Concrete Structures for Nuclear Po er Plants (Other Than Reactor Vessels and Containments)

GPUN shall comply with the Regulatory Position established in this Regulatory Guide as augmented by ANSI N45.2.5, AMS!/AMS 6.4-1977 and ANSI /ACI 318-77 for the

! design and construction of n e .. Duclear Safety Related or Regulatory Required structures and additions to existing Guclear Safety Related or Regulatory Required structures. Inspectors will be qualified acccrding to eit her ANSI N45.2.6 or Appendix "!! cf Section III, Divicier ., cf the AS"E Boiler and Pressure Vessel Coce.

NRC Peculatory Guide '.143. Octobar l e' ;

Desjar Guidance for Radioactive Uaste 'u n a aec e: vestems. Structures and Components Jnst alled in Licht-Water-Cocled Nuclea: P ;. . m i l a:.t r Since the original design and canciru ct i c: cf 1 u-1 and Oyster Creek was to I different classification criteita tha" ~ * -neJ in this guide; GPUN will comply '

with the regulatm y position of thic guide i the following clarifications:

1. For modification to exictin p. ant r . < ; e> e , items will be classified by Technical Functions accord.nr t; itw : ,.a. design basis or this guide.

This classification wil. nr de: , ,  !!w cafety of the system being modified.

2. Additions to existing plari cyste ... De n.ade to the same code, standard and technical requiremente schien .:O re Or.;;. . ally applied to the system to which the addition is to be marle er r. c re recent versions of these codes, standards and technical requ iren ent s . The addition will not degrade the safety of the system being added to.

3. For new construction, the latent applica.tle code will be utilized unless such utilization would result in hardship or unusual difficulty without providing an equivalent level of safety.

4. Hose mav be used in lieu of n i t se here t h r- connections are temporary The anticipated anpiteetione c' hoae o .i l e t "tpn.a. ll y be (1) connections to ece rartor owned skid mounton radion: 1 " c- .;a r t e processino eautoment, ( 2_.1 connectione te o nonmounte- fre uent. -ci.anced com;gnent such a s a bu r i_a_,,1 liner /H:C or (3) connectiom to nm mted pieces of radioactive waste crecessino or collection eq u en. hich nust be readily removable (e.a.

Items elaced on ecutprent hatchen). "tp_preesure ratino of such hoscs and connections shall ecual or excoed those of tha svstem(s) or component (s) to wnich thev are connected.

r( API.All P7 90.0

i i

l Nucirr GPu Nucl.rAR oerRAT1onAt QUALITY ASSURANCE PLAN Nueer 1 COO-PLN-720C.01 l

l l

Title:

Appendices Revision No.

7 APPEND:X C - PART 2 l 4

l l

Prior to use, the hoses shall be hydrotested to the acoropria*.e cressure for the system or comonnent to which thev are connected. After itstallation, they are to receive recular hydrotestino or in-service insoections.

A safety evaluation is required t o iust if- the use of such hose connections.

NPC Peculatory Guide 1.144, J a nu a r- IC'O Auditino of Oualltv Assurance Pronrar s fcr Nuclea' Power Plants CPUG is in Dasic agreement with the position set forth in the Regulatory Guide I subject to the following comments:

l

1. Sections C.3.a(1) and C . 3 . a f il Minimum scheduling frequency and topical coverage of the GPUN internal audit program will be as defined in Section 6 of the nuclear units' Technical Specifications.

2. Seetto- C.3.b! ). Source surveillance till be utilized in lieu of or in addition to receipt inspect on. As pert:tted, external audits of such procurement actions will typically not Le scheduled.

3. Sectier C . 3 . t' t ? 3 External audits of selected cuppl err of services tahich are within the scope of this Plan will be scheduled and conuucted at least once within the life of tne act;vity er every tnree yearc. Refer alco to 10.2.5 of this plan.

An annual evaluation of suppl:er* of . t e:r s , parts, n'aterials and services w;11 de conducted. These ecal:attent ... be conducted utilizing the results of source surve llance, source . n e pect : c: , receipt inspection a..d/or audits; and, other factors. These e.ai..atione .. determine the need to conduct audits of suppl:ers of i t e.: r , i.a r t e tr. iterials; or, increase the frequency of concucting audats of sup!..erc .. ;e: :ces.

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FC AP1.A!! . P 7 91.C

i ENucirr GPU nUCLtAn OPrRAT:ONAL QUALITY ASSURANCE PLAN Number 100C-PLN _,200.01 i j

Title:

Appendices Revision No. j 7  !

I APPEND:? O I l

t d

Terms and Definitionc j This Appendix contains certain terms and their definitions that are important to a 1 uniform understanding of the requirements cf the GPUN Operational Quality Assurance Program. ANSI N45.2.10-1973, as endorsed by Regulatory Guide 1.74, and NQA-la-1981 contain terms and definitions applicacle to the nuclear industry. The terms and t definitions found in these documents are upplicalle tc the CPUN Operational Quality i Assurance Program and, for convenience, are included, in part, herein. Those terms ,

and definitions which are the same as listed in ANSI N45.2.10-1973 or NQA-la-1981 are "

identified by footnote (1). Certain exceptions : the terms and definitions found in ANSI N45.2.10-1973 and NQA-la-1981 have also been taken. These exceptions are identified by footnote (2). ,

ACCEPTANCE (as used in relation to acceptance Cf a occument): Generally approved, I believed or recognized. Does not require signature of person accepting. ,

i ACCFPTANCE CP!?EDIA: Specified limite placed on characteristics of an item, process, i or service cefined in codes, standards, or other documents. (1)

ADMIN!STRATIVE CONTROLS: Rules, orders, instructions, procedures, policies, practices j and cesagnations of authority and responsibill:V l l

ALAPA: (Aeronym for As Low As Peaconably Achievable) - a method of analysis of the performance of activities in radiologira; areat tc determine specific methods for redue;ng man-rem exposure. l I

APPPOVAL: An act cf endorsing and aca;r ptc;t.ve authorization (signature) to a 4

document ey tne person (s; respons;: le fr: he , : r - . e: ; t2) i APCH!TEC 'ENn!NEEP!NG I A 'EJ: A f r. .m. m

- t: provide engineering or design services.

1 AS-FtU!LT DATA: Documented data that e ie s r r . : .e- . condition actually achieved in a j proauct. (1) I l

a AUD11: A formal, independent arti..ty con =ucteJ :th the intent to verify conformance witn established requirements. This arttvat; ;c :erformed in accordance with written {

procedures or checklists te verify, r; exar.. :st ; : and evaluation of objective i

evidence, that documents and arti'.;;2er .t'. t crope of this Plan are consistent with requirerents, are oe:ng effect. . . rple'e is and provide results which are cons: stent w:th technica'. requirerer* ne te "ec..rce surveillance", " source inspection", ":nspectior "surve;..a:.T . . . . a: " survey" are not synonymous or equivalent tc tne terr " audit. i ' i BASFL!NE ENG!NEEPING DOCU*ENTS: Incluuet 'cu t ac .;; 1:m;ted to safety evaluation, design criteria documents, flow charte, 57 c t e. De z . g: Lectriptions, general arrangement crawings, single-line diagrairt, a n:1 it.: diagrams which show or define basic plant parameters. For instonec, Centrol Pa :m 2 , Layout and Control Room arrangerent draeangs are baseline at:unenic.

BASIC COwPONEN*: A term defined t r. ;CCFIC1, a "tarle component

• means a plant structure, syste , component or part ( ;n 1: d; n:; design analyses), necessary to assure (1) the integr.t', cf the reactor 000.la:n p r e n t. a r e Luandary, (2) the capability to shutdown tne rearter and raintain . .:. a safe r n .;t oown , or (3) the capability to prevent or r.t.7 ate One e r r.c eq u e n re c f arcade ti that could result in potential off-site espasurer cor p r.c.e tr *!re referre- :: :- 10CFR100.11.

ecmov 92,7

Nualzr CPU nuCtEAe OPEaAT:ONAL Number QUALITY ASSURANCE PLAM 1000-PLN-7200.01

Title:

Appendices Revision No.

7 APPEUDIX D CALIBRATION: Comparison of two instruments or measuring devices, one of which is a standard of known accuracy traceable to national standards, to detect, correlate, report, or eliminate by adjustment any discrepancy in accuracy of the instrument or measuring device being compared with the standard.

COMMERCIAL GRADF ITEM: An item that meets all of the following conditions:

Is used in applications other than nuclear power plant facilities or activities; Is not subject to design or specification requirements unique to NRC requirements for nuclear power plants; May be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (e.g., a catalog).

NOTE: Tne technical requirements set fortt. .a the published product description must match the requirements needed to satief; the design function of the item.

Commercial grade items, when used as a basic component, must be dedicated prior to operation.

CONCURPENCE: Written agreement that the provisions in a document for which review has been requested are acceptable for implementation ilthin, or from the standpoint of, the reviewer *s area of responsibility.

COND! TION ADVERSE TO OUALITY: An al'. Inclusive ter.r used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and nonconftrmances. A significant conditlen a:! verse t o quality is one which, if uncorrected, could have a serious effect on s a f e t ', or operability.

CONTPACTOR: Any organization under contrart fer furnishing items or services. It includes the term Vendor, Supplier, Subcontractor, Facrtcator and subcontractor levels, where appropriate. (1)

CONTROLLED DOCUMENT

• A document ter.icn is ast:gned and distributed to an individual, organitation or location and requirer that ind; .aua' or organization to be accountable for the document. The districut ;ng 1:ent is responsible for providing the rec 2plents with current revisions to the accun+nt .

COPEECTIVE ACTION Measures taken it cert. r_: .t;ons adverse to quality and, where necessary, to preclude repetition i;.

DEDICATION: The process by which a Oc: : err.... gr . t ei.. s designated for use in a nuclear safety-related application (c .  : . ;r ; t ,

a point in time, typically after receipt, when the party designating the .ter acc. .c Jefaciency reporting responsibility associated with such use.

DES 1CN BASES: That documented inf ern.at ion which ident2fles the specific functions to be performed by a structure, system, or ccaponent Of a facility and the specific values or ranges of values chosen for ccr.trell:no paraneters as reference bounds for design.

DETA! LED DES!CN DOCUMENTS: Engineering design docun.ent s derived from the Baseline Engineering Documents that provide the deta.; cf design sufficient to fabricate, install and test a modification or s y s t en. . Tnts includes but is not limited to Procurement, Material, and/or Test Specificatione, Installation Specifications, Fire Hazard Analyses, construction drawings, fabrication drawings, Bill of Materials, etc.

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Nucber Geu NUCLEAR OeERATIONAt number 1000-PLN-7200.01 QUALITY ASSURAMCE PLAN

Title:

Appendices Revision No.

7 APPENDIX D DOCUMENT: Any written, pictorial, graphical or other reproducible media information l describing, defining, prescribing, specifying, reporting, or certifying activities, I requirements, procedures or results. A document is not considered to be a record until it is completed and contains the required signatures. (2)

. ENGINEERING (Encineeri This term refers to the technical responsibilities.of Technical Functions, Plant Engineering or A/E's.

EXTERNAL ORGANIZATIONS: Any organization participating in the project which is not a j part of GPUN. This term includes vendors, A/E's and contractors. This term is j synonymous with the term supplier.

ITEM: Any structure, system, or component of a nuclear power plant including nuclear fuel and radwaste systems. This item also includes licensed radwaste shipping containers. Quality classification shall be performed for mechanical, electrical, and instrumentation items at the component level. Mechanical items shall include valves, equipment and specialty items. Electrical and instrumentation items shall' include electrical, distribution, instrument and control panels, cabinets, switchgear, motor '

control centers, non panel mounted instruments, transformers and motors. This term does not necessarily include parts of components. l LEAD AUDITOR: An individual qualified to organize and direct an audit, report audit results, and evaluate corrective actions. This term is not equivalent to the term

" auditor." The term " audit team leader" is equivalent to the term " lead auditor."

MONITORING / SURVEILLANCE: An act of assuring compliance of activities to program requirements by direct observation or record review. Generally, monitoring is performed on site and surveillance is performed at a vendors's facility.

NUC]. EAR SAFETY RELATED: Structures, systemc and components designed to remain ,

functional for all design basis conditions necessary to assure the following safety l functions:

1) The integrity of the Reactor Coolant Pressure Boundary.

2) The capability to shutdown the reactor an:1 maintain it in a s&fe (hot) <

shutdown condition; or

3) The capability to prevent or mitigate the consequences of accidents which could result in potential of f-stte exposures comparable to the guideline exposures of 10CFR100.

PROCUREMENT DOCUMENT: Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to define the quality and technical requirements for purchase. (1)

OA PLAN SCOPE: This term is a designator used on the coversheet of approved documents which prescribe the method of performance of actav2 ties or tasks identified in Section 2.2.2 of this Plan.

OUALIFICATION (Personnell: The characterictics or abilities gained through education, I training or experience, as measured againct established requirements, such as standards, or tests, that qualify an individual to perform a required function.(1)

OUALIFICATION (Procedures): An approved procedure that has been demonstrated to meet the specified requirements for its intended purpose. (1)

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Nusizr GeU nuctEAn OPERAT10Nu Number l QUALITY ASSURANCE PLAM 1000-PLN-720C.01  ;

1

Title:

Appendices Revision No. l 7 l APPENDIX D l

I OUALITY CLASSIFICATION: A process for identifying the technical and quality requirements of structures, systems, and components based upon regulatory requirements  ;

and commitments, safety function and/or reliability consideration. l OUALITY CLASSIFICATION LIST (OCL): The approved and controlled document used to record the identification of structures, systems and components that are within the ,

scope of this Plan.

FECORD: A completed document which has been authenticated which furnishes evidence of the acceptability of an item, part, material, or activity, etc. within the scope of this Plar,.

REGULATORY REOUIRED: Those items which are not nuclear safety related but which must meet NBC regulatory requirements or commitments. Sources of regulatory requirements and commitments, as a minimum, consist of those associated with expressed conditions of the unit operating license, FSAR, fire protection (Appendix R and BTP Appendix A),

security, environmental qualification of electrical equipment, seismic response capabilities, licensed shipping containers to the extent committed by GPUN, generic letters, IE Bulletins, ICCFR50.54(f) e c r re s pen:ien ce , certain MUREG documents, etc.

REVIEW FOR CONCURRENCE. A review of a document conducted prior to that document being approved for use. A review conducted by someone Other than the individuals who prepared; or, will approve the document for use.

SPECIAL PPOCESS: A process, the results of which are highly dependent on the control of the process or the skill of the operators, or Loth, and in which the specified quality cannot be readily determined by inspection or test of the product. (1)

SUPPLIER: A firm which provides items, parts, materials or services from an off-site facility and operates under the require: tents cf their con QA program.

SUPPLJ EP OUALITY CLASSIFICATION LIST (SQCLl A approved and controlled list of suppliers who have been evaluated by GPUN for their capabilities to produce or provide items or services or both within the scope of th. Plan.

TRACEABILITY: The ability to trace the histor., tpplication, or location of an item ,

and like items or activities by meant cf recorde. Information. (1) l TREtID ANALYSIS: A quantit at ive met ho; of co!!ect. and analyzing nonconformance/ deviation events witt. the xa', cf c,etenatically determining programmatic / procedural weaknesses.

VENDOR: A firm which manufactures iterr at an off-cite facility and operates under the requirements of their own quallt; accucance irpgrau.

VERIFICATION: An act of Confirming, substantiating and assuring that an activity or condition has been implemented in conformance v i t t. the specified requirements. (1)

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