ML20066K771
| ML20066K771 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Crane |
| Issue date: | 01/28/1991 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20066K775 | List: |
| References | |
| C321-91-2009, NUDOCS 9102060118 | |
| Download: ML20066K771 (6) | |
Text
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GPU Nuclear Corporation i
G N Muclear
"::en:r 88 Forked River, New Jersey 087310388 609 971 4000 Wnter's Direct Dial Number:
January 28, 1931 C321-91-2009 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen
Subject:
Three Mile Island Nuclear Station Unit.1 (THI-1)
License No. DPR-50 (Docket No. 50-289) j Oyster Creek Nuclear Generating Station License'No. DPR-16 (Docket No. 50-219)
GPUNC OQA Plan, Revision 3, 4 and 5 Pursuant to 10CFR50.54(a)(3), enclosed are Revisions'3, 4 and 5 of the Operational Quality Assurance Plan for Three Mile Island Unit 1 and Oyster Creek. GPUN has determined that these revisions do not reduce the commitments previously approved by the NRC.
Attachment I lists the changes of Revision 3, 4 and 5 and providos the basis for the changes. Attachment 2 is the revised Operational Quality Assurance Plan for Three Mile Island Unit 1 and Oyster 1
Creek.
If further information is required, please call Mr. Michael Heller, Licensing Engineer, at (609)971-4680, l
Very truly yours, Vice President and Director l
Nuclear Assurance PDP/MH:jc Attachmente l
(C3212009) cc: Administrator, Region 1 Senior NRC Resident Inspector 00 9102060118 910128 PDR ADOCK 05000219 gi(
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GPU Nuclear Corporation is a subsidiary of General Public UtMes Corporation bh5: 1,l.1 i
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-r Attachmsnt 1 C321-91-2009 ~
i Page l of SL List of' Changes-
-GPUN Operational QA Plan Revision 3 q
'l 1.
Accendix C Part 2, Reculatorv Guide 1.58 Rev.
1._
The exception to this Regulatory-Guide has been revised to allow the use of later editions of' SNT-TC-1A provided that thatl edition is ' endorsed by an-edition' of Section XI of :
the ASME Boiler and Pressure Vessel-Code which has beenLincorporated-by-reference into.10CFR50.55(a).
The reason-for this' change is'to allow the use of 1980 edition of SNT-TC-1A in
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conjunction with-the provisionsfof ASME Section XI. -:It was desiredt to-usefthe:
1 1980 Edition because of the improved qualification and certification l guideline's
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for Level III.
Specifically,1the usage-of_ASNT. developed Level'III! examination?
questions, which were more in-line with-the broader responsibilities of the o
Level III position and were not available atithe-time'thei1975 Edition was j
issued, was desired.
This change-is not a reductionI$n prior ~ commitment-because-.SNT-TC-1A-provides'anf improved-examination process-for Leve1LIII's andinot-usednalone.=;ItLis>uced in the context of and concurrent with ASME 3ection XI,to the extent currently-committed to by GPUN.
As'such, the'" guidelines"Lof;thecetandard are
" requirements" as applied.. Furthermore,-the-use'of future _ revisions:of:that-standard as may be' invoked'by future revisions"totASME~Section XI?would not;beia-reduction in prior commitmentibecause the use of future editions:of this c
standard would be automatically endoraed by the NRC'through;the.. endorsement-of the ASME Section XI revision. 1As'a point of' emphasis,1GPUNm is'not requesting nor implying that its commitment to' a ' specific l edition off ASME 'Sectier. :XI ;would or could be changed prior to NRC review.
j
. List of Changes l GPUN Operational'QA Plan j
a Revision 4 i
1.
General. Organizational titles have been revised as necessary.throughout the text. This change is editorial in, nature'to af ste' consistency of:the text of 1
i the. Plan with-Section 1 of the Plan.. As such this is not a reductionJin prior c s
commitment.
2.
. General. The phrase " measuring and test equipment"1 has:been changed toJ"MT&E" j
=in a majority of instances.-_This change.is editorial:in nature.~ JIt. represents a preferential use of an acronym to. assure clarity ofithe-Plan. test.
As such, 1
this is.not a reduction in prior commitment.
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Attachmsnt:1-
~ C321-91-2009 Page 2.of-5 1
.q 3..
Section'1.'1.
The first paragraph haslbeen' deleted. fThat paragraph:has been replaced by the." Office of the President".
The title " office of the President" has also-replaced the' title " President"~- -This change of' editorial in nature and.
j directed towards reducing the level of.-unnecessary organizational detail-toj _
j reduce the need to revise this-Plan.' As such, this is not:a reduction,in prior commitment.
4..
Section 1.4.
.The title. Director - AdministrationLhas been_ changed to Director <-
Administration and Finance.
The phrase >"maintainingband implementing?
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procurement, warehouse, and plant security programs" has been replaced by
" maintaining, and-implementing procurement and warehousingLplans and/or_
procedures"..This change is editorial in-nature and indicates the, reassignment of responsibility for plant security _ programs to the Site. Services Director.
Refer to Section 1.6.
This change is not a reduction in~ prior. commitment i
because the explicit assignment of responsibility-for plant-securityfprograms?
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has been maintained within the. text of the OQA Plan.
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- p 5.
Section 1.5.
The title Director Quality and Training.has-beenschanged to Director - Nuclear-Assurance.- The text' associated with the previous section-numbered 1.9 has been incorporated into this;section. 2The' previous title j
1 Director - Radiological and Environmental Controls,is no longer a separate GPUN Division Director title. The sentence "The Director's... practices and procedures; and, establishing, maintainingJand1 delivering training and education programs sufficient to assure safe, reliableJand efficient operating.in accordance with Corporate Policies..." now readsithe "The1 Director's..'.
practices and procedures; establishing, maintaining and delivering training.and-education programs sufficient to assure-safe, reliable 1and; efficient operation;.
1 establishing, implementing and maintaining:radiologica1Leontrols, radiological.
environmental monitoring, emergency preparednessi; medical examination, and'
- l fitness for duty testing plans and procedures consist _with Corporate Policies...". _ This change is editorial in nature and indicates the reassignment
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of Radiological Controls, Radiological-Environmental, Emergency' Preparedness,-
--j Medical Examinations and Fitness-For-Duty activities to the newly formed Nuclear i
Assurance Division.
This change is not a reduction'in prior commitmenttbecause
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the explicit assignment of responsibility for_these' activities'_has;either;been maintained or inserted within the text _offthe.OQA1 Plan.
6.
Section 1.6.
The title Director - Maintenance,sConstruction-'and1 Facilities has been changed to Director - Site" Services'.- 'The: sentence "The Director's
... implementing policles, practices and proceduresLfor managing,1 planning andL conducting all maintenance, repair, and. construction 1 activities;'and to con'uct d
all plant modifications, maintenance,: repair,-construction _and welding activities as assigned..." now reads "The Director's... implementing plans.and procedures for. managing,-planning and conducting maintenance, repair and construction activities; constructing plant modifications as assigned,1and conducting maintenance, repair, and construction activities as-assigned...".
Text has been added to indicate the-assignment of responsibilitiesLfor nuclearc plant security, security screening, safeguard contingencies, security guard force training-and. qualification. -This change is editorial in nature.
Th'is change is not'a reduction in prior aommitment because the explicit assignment of responsibility for these activitiet has either been maintained orsinserted-within the-text of the OQA Plan.
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o C321-91-2009 Page 3 of 5:
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7.
Section 1.B.
A new title Director - Independent Safety Review!has been established.
This title had no previous!section number assigned.. Text has been i
added to indicate the assignmentlof responsibility._for nuclear safety assessmentf y
and review activities. _This-responsibility had.been'previously assigned'to the l
position tilted Director - Planning and Nuclear SafetyL(refer-to 1.9 below).--
l This change is not a reduction in' prior commitment because-the explicit l
assignment of responsibility for these activities has either been maintained or-l inserted within the text of the OQA Plan.-
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8.
Section 1.9.
The title Director - Planning and Nuclear Safety,'which had been.
previously numbered as Section-1.8,_has been changed:to' Director - corporate services. The text hao been revised to reflect'the transfer of nuclear safety.
i assessment activities to the position titled Director -~ Independent Safety.
-J Review and the addition of the responsibility forethe_GPUN Fitness-For-Duty q
Program.
This change is'not a reduction in prior commitment'because the-explicit. assignment of responsibility for_these activities has either been-maintained or inserted within the text of the OQA Plan.
9.
Exhibit 1.
This exhibit has been updated to be consistent with the revised text of Section 1.0 of this Plan.
As'such, thia is not a reduction in prior 1
commitment.
- 10. Exhibit 2.
This exhibit has been revised to-reflect a QA department reorganization. That reorganization is not a reduction in prior commitment.:
The independence of the QA department-has.not been effected; non of the.QA department responsibilities, that derive from the QA Plan, - had been transferred -
to another GPUN organizational unit.
- 11. Section 2.2.2.
The terms " security screening" and " fitness-for-duty" have been added.
This addition is consistent with.the_ Plan directly identifying-accivities that are within the-econe of the Plan.
An'auch,ethis 1sinot a reduction in prior. commitment.
- 12. Section 2.5.1.-
Editorial changes have been made to conformLto current GPUN:
organizational titles.
These include Director' Administration and Finance,-
Director ---Corporate.Servicea, Director - Independent Safety Review, Director 1
Nuclear-Assurance, Director - Site Services and Administrative Support Manager, As such, this is not a reduction in prior commitment.'
13, Seetton 6.5.2.1(b) and (c).
Previous. subsection ('b) and (c)Lhave:been: retained-and redesignated as (d)!and-(e).__New statements,have1been added and designated-L aa (b) and (c).
This change was~made as-a result of theJfact that maintenance can be performed by the plant divleions as well as Site Services. As part of.
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this, the responsibility to conduct post maintenance. testing and to maintain-the i
adequacy-of maintenance proceduresjis included;- This change is editorial and provides concietency with.the GPUN Organization Plan. ; This change is not a-redaction in_ prior commitment _because~the explicit-assignment of responsibility for these-activities has been increased within the. text of'this Plan.
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C321-91-2009 Page 4 of 5
- 14. Section 6.5.2.3(b).
The sentence " Prescribing and performing the construction..." has been changed to " Prescribing, performing and/or ensuring the performance of construction...".
This change was made to conform the text of the Plan to the situation were site Services would be " managing" instead-
" performing" construction or maintenance.
As part of this, the responsibility to conduct construction or post maintenance testing is augmented by " ensuring" t
l that such testing is completed. This change is editorial and provides consistency with the GPUN Organization Plan.. This change is not a reduction in prior commitment because the explicit assignment of responsibility for these activities has been' increased within the text of this Plan.
- 15. Sect ion 6. 5. 2. 3 (c). The sentence " Ensuring that
...by McF... performed documented and the results acceptable prior to turnover." now roads " Ensuring that for the work managed and or performed by Site Services.. 18..."
Refer to item 14 above.
As such, this is not a reduction in prior commitment.
This is an editorial change which is directed towards improving-the clarity of the text of the Plan and as such it to a reduction in prior commitment.
- 17. Sect ion 6. 6.1.1.
The phrase "...Such equipment..." has been replaced by
...Such measurina and test eauipment..." and the phrase "...Such measures...
instrumente..." has been replaced by "...Such measures...measurina and test' ggg1pment...".
This is an editorial change which is directed towards improving the clarity of the text of the Plan by consistently utilizing the same terminology and as such is not a reduction in prior commitment.
- 18. Sect ion 6. 6.1. 2 (c).
The last line previously ended "...for measurements or tests." now it' reads "...for measurements or teste until its calibration has been re-established." This is an editorial change which is directed towards-improving the clarity of the text of the Plan by reinforcing the requirement not to use M&TE until it acceptability has been defin.itively determined.
As such, this is not a reduction in prior commitment.
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- 19. Section 6.6.1.2(a).
The entire paragraph has been changed.
It now reads "The calibratton status of M&TE which is.used for determining the. functionality or l
quality of structures, systems and components within the scope of this Plan shall be maintained." This is an edito2.al change which is directed'towards improving the clarity of the text of the Plan by reinforcing the requirement not to use M&TE without first determining its calibration status.
As such, this is not a reduction in prior commitment.
- 20. Sect ion 6 11. 2.1 (a ).
The sentence." Establishing-administrative control procedures for..." has been changed to " Establishing procedures for..."
Refer to item 13 previously.
The term " procedure" in this cas is used to indicate technical as well as administrative " procedures". As such, this is not a reduction in prior commitment.
l C321-91-2009--
Page 5 of 5
- 21. Section 7.2.1fe).
"10CFR61" has been inserted into the text.ThisEis an editorial change directed to improving the clarify of the text of.the Plan-by redundantly stating another source of regulatory-requirements associated with-radioactive waste management.- As such, this'is not a' reduction in prior
- l commitment.
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- 22. Appendix C - Part '2 Rec. Guide '1.8, Rev. 1-4; May 1988.. An entire new-paragraph' has-been added to read "for-the NRC licensed positions of Reactor Operator::(RO).
and Senior. Reactor Operator (SRO), therexperience requirements of ANSI 3.1 l
1981 will be utilized totdetermine if, candidates. meet NRC'llcensing eligibility
=j requirements, until the' applicable site's simulator has been certified in' accordance.with 10CFR50.45.(b).
In accordance with NUREG 1262,, Questions 100 i
and 111, CPUN may accept candidates into the RO and SRO training _ programs who do:
not' meet the detailed' guidance contained in ANSI 3.~1 -~1981Eif-GPUN feels'that-the candidate Lis capable of performing the job and if: those programs utilize a i
simulator certified in accordance with 10CFR50.45.(b)."
i This-change is in responso to NRC request-to directly commit to.the ANSI /ANS-3.1-1981. -As such, this is not a reduction it. prior _ commitment.
- 23. Table of Contents.
The Table of Contents has been revised as appropriate to show changes in titles of sections or subsections _of.the Plan-(i.e. page13 and 4).
Changes in the page number on which the text for the section begins (i.e.
page 4 and 5).
If the text of the Plan was simply reset the' text on that reset page had been revised then the revision' number _of1that' reset page was not changed to reflect theffact that the text had been reset.
As-such, this is not-a reduction in prior commitment, i
List of Changes GPUN Operational QA1 Plan Revision 5 1.
Appendix C - Part 2P
. Guide 1.8.
Rev.
1-4, May 1988.
InLRevision 4, an entire new paragraph nad been -added which committed taa use; the experience-requirements of ANSI-3.1 - 1981 to determine if: candidates meetENRC licensing l
eligibility requirements, until the applicable site's simulator has been l-certified-in accordance with 10CFR50.45.(b).
Those words-relied on reference to NUREG'1262, Questions 100 and 111. In this revision, any reference to'NRC Generic Letter 87-16, dated.11/12/87 (NUREG-1262; Questions 100, 103, 104, 111 and-430)_-has been removed.
The text has been modified'to.be consistent with the-requirements of 10CFR55 unich rely.on-both'an u
INPO accredited, training program and a NRC certified: simulator.
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This change-is in response to.NRC request to directly commit to l
ANSI /ANS-3.1-1981. 'As such, this is not a' reduction in prior commitment.
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