ML20066K829
| ML20066K829 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Crane |
| Issue date: | 01/21/1991 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20066K775 | List: |
| References | |
| 100-PLN-7200.01, NUDOCS 9102060135 | |
| Download: ML20066K829 (114) | |
Text
y' gf CPUNC OPERATIONAL QUALITY ASSURANCE Humb3r PLAN FOR THREE MILE ISLAND UNIT 1 lOOO-PLN-7200.01 AND OYSTER CREEK Title CPUNC Operational Quality Assurance Plan for Three Revision No.
Mile Island Unit I and Oyster Creek 5
Applicability / Scope Responsible Office This Plan Has GPUNC-Wide Applicability Except TMI-2 6160 This document is within QA plan scope X Yes ___No Effective Date Safety Reviews Required X Yes No 03/11/91 List of Effective Pages on page 2.0 Sionature Concurrina Oraanizational Element Date.
Originator Om 1, kAA g,-
Director Quality Assurance t /31/4 %
Concurred N/A Coroorate Secretarv 5/31/90 By N/A Dir-Administration & Finance 5/24/90 N/A Dir-Corporate Services 6/18/90
.N/A e
Dir-Independent Safety Review 5/23/.90
/N? 2 Ml Dir-Nuclear Assurance
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'U N/A Dir-OCNGS 6'/12/9d N/A Dir-Site Services 5/23/90 l
N/A Dir-TMI Unit 1 7/03/90
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N/A Dir-Technical' Functions 5/25/90 l
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Administrative Support Manaaer
//81/7 /
s b87M B,esconsible Technical Reviewer
[/19/91 Approved
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Office of the President
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ADOCK 05000219 PDR
lCPUNCOPERATIONALQUALITYASSUPANCC Nutrb3r g g PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title CPUNC Operational Quality Assurance Plan for Three Revision No.
Mile Island Unit 1 and Oyotor Creek 5
LIST OF EFFECTIVE PAGES Page Rev.
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g gf GPUNC OPERATIONAL-QUALITY ASSURANCE-Numb 3r -'
PLAN-FOR-THREE MILE ISLAND UNIT 1
'1000-PLN-7200.01
-j AND' OYSTER CREEK Title GPUNC Operational Quality Assurance Plan lfor Three-Revision No.-
Mile Island Unit 1 and Oyster Creek 2
.i i
TABLE OF CONTENTS 1
i LIST OF EFFECTIVE PAGES 2.0 4
TABLE OF CONTENTS 3.0
+
DOCUMENT HISTORY 6 '. 0 -
i INTRODUCTION
'7.0, 1.0 ORGANIZATION 1.1 Office of the President.
8.0' 1.2 Directors THI-1_and Oyster Creek' 9.0 1.3 Director Technical Functions 9.0 1.4 Director Administration and: Finance
~9.0 j
1.5 Director Nuclear Assurance
.9.0 l
1.6 Director Site Services 112.0 3
1.7 Corporate Secretary 12.0 1.8 Director Independent Safety Review ~
13.0 1.9 Director Corporate Services-
'13.0 l
2.0 QUALITY ASSURANCE PROGRAM 2.1 General
-14.0 2.2 Scope 14.0 2.3 Graded Approach 16.0 2.4 Three-Level Assurance Approach-17.0 2.5 Operational QA Plan Control 19.0 2.6 Quality Assurance Program Review-20.0 2.7-Indoctrination and 'Iraining; 21.0 2.8 Classification Process 21.0 2.9 Recorde-of Regulatory: Commitments
'2240 2.10 Safety Reviews-22.0 2.11 Responsibilities.
'24.0 3.0 CONTROL OF DOCUMENTS AND RECORDS i
3.1 Policies, Plans, Instructions,, Drawings, Specifications.
27.0 3.2 Document Control 29.0-i 3.3_
Quality Assurance Records 13 2. 0 '
4.d DESIGN CONTROL 4.1 General-36.0 4.2 Requirements.
'36.0 4.3 Responsibilities 38,0 3.0 3685L (1/91) o
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g f-CPUNC OPERATIONAL QUALITY ASSURANCE-Numb 0r-PLAN FOR THREE. MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK.
l Title GPUNC Operational Quality Assurance Plan for Three Revision No.
1; 2
Mile Island Unit 1 and Oyster. Creek 4
TABLE OF CONTENTS fCONTINUED)
EA21 0.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement-40.0.
5.2 Identification and Control of Materials, Parts and Componente 46.0 6.0 CONTROL OF STATION ACTIVITIES 6.1 General
--49.0 6.2 control of Inspectione 49.0 6.3 QA Monitoring
- 52.0' 6.4 control of Special Processes 53.0
-6.5 Test Control.
54.0 6.6-Control of Measuring and Test Equipment (M&TE)
- 58.0 6.7 Handling, Storage.and Shipping 59.0 6.8 Inspection, Test and Operating-Status 61.0 6.9 Housekeeping and Cleanliness 63.0 6.10 Equipment, Control 64.0 6.11 Control of Construction, Maintenance 65.0 (Preventive / Corrective) and Modifications-6.12 Control of Surveillance Testing and Inspection -
69.0
~
6.13 Radiological Control 70.0 7.0 CONTROL OF RADIOACTIVE WASTES 7.1 General 72.0 7.2 Requirements 172.0-7.3 Responsibilities 73.0 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES' 8.1 General-
.75.0 8.2 Requirements
-75.0 8.3 Responsibilities
- 7 7 ~. 0 9.0 CONTROL OF-TRAINING 9.1 General 80.0 9.2 Requirements
~ 80.0 9.3 Responsibilities 81.0 10.0 AUDITS 10.1 General 83.0 10.2 Requirements 83.0 10.3 Responsibilities 85.0.
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g gf CPUNC OPERATIONAL QUALITY ASSURANCE-
.. Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01
-AND OYSTER CREEK Title GPUNC Operational. Quality ~ Assurance Plan for Three-Revision No.
t-Mile Island Unit 1 and Oyster Creek 4'
TABLE OF-CONTENTS (CONTINUED)
D i
APPENDICES:
87.0 Appendix A' - Comparison chart _ of Quality Assurance Plan Requirements with those of various parts of the code of Federal Regulations and Nuclear Industry Standards 88.0 Appendix B - QAD Review Requirements for Documents Within.
QA Plan Scope 89.0-l Appendix C -- NRC Regulatory Guide.-Commitments and Exceptions
_90.0 Appendix D - Terms and Definitions 109.0 l
t-5.0 3615L (7/00) i 1
l Nuder crunc orSRATIO*^t ouAtIrv ASSuRAncS Numser PLAN FOR THREE MILE ISLAND. UNIT 1 1000-PLN-7200.01-AND OYSTER CREEK Title CPUNC Operational Quality Assurance Plan for Three Revision No.
Mile Island Unit 1 and Oyster Creek 5
PREPARED BY.
EFFECTIVE REVIEWED'BY REVISION DATE DESCRIPTION OF CHANGE APPROVED BY 9
3 10/10/89 The commitment to Regulatory Guide 1.58 E. J. Ahern=
has been revised to require that the requirements and recommendations of the 1980 J. Jandovitz Edition of ASNT-SNT-TC-1A be used in con -
P.
R.- Clark junction with the-provisions-of-Section XI of the ASKE Boiler and Pressure Vessel Code currently committed.to by 0 PUN; and, to permit the use of later editions of ASNT SNT-TC-1A as referenced in Section XI of the ASME Boiler and Pressure Vessel Code provided that later edition of Section XI hsa been incorporated into.10CFR50.55(a).
(
(
4 07/18/90 Section 1.0 was, revised as a result of R. S. Markowski Corporate and'QA Department reorganizations-J. P. Heil and; to reduce the level of organizational P.
R., Clark detail; the activities of " security screening" and " fitness-for-duty" were identified as activities within-the scope of the Plan in 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 instal-lation testing responsibilities of-the Site Services Division; editorial changes were-made to Sections 6.6 and 7.2.1; Sections 6.11.2.1(a) has been-revised tolihdicate that the Oyster Creek and THI-1' Divisions are responsible for the technical as-well-ce the administrative procedures associated--
with maintenance;.the commitment to Regulatory Guide 1.8 has been modified to establish experience requirements needed:
for eligiability for the NRC licensed reactor-and senior reactor operator posi-tions; all affected sections-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 wasito further M. Heller clarify the text associated with Reg. Guide J.-P.
Hell 1.8 that was inserted by Rev. 4 (i.e. item-P. R. Clark 2 in Appendix C, Part 2). The commitment relies on the-text-of 10CFR55.
6.0 l.
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Mf GPUNC OPERATIONAL QUALITY ASSURANCE Numb 2r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title CPUNC Operational Quality Assurance Plan for Three Revision No.
Mile Island Unit 1 and Oyster Creek 2
INTRODUCTION GPU Nuclear (CPUN) is responsible for the operation and maintenance of TMI Unit 1 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 Unit 1 and Oyster Creek.
This plan replaces the Operational Quality Assurance Plans for TMI Unit 1 and Oyste; Creek.
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 dua 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 sub-sequent sections.
Control of documents and records is contained in Section 3.0; control of design is contained in Section 4.0; control of materials and services, including procurement, is contained in Section 5.0.
Sections 6.0 and 7.0 contain the plan requirements for those operational, support, and assurance activities associated with the safe operation of all plants; construction and/or modifications associated with corrective maintenance, plant improvement, and/or repair; and the processing and preparation for the transport and transportation of radioactive wastes. Specific requirements such as control of measuring and test equipment, inspection, special processes, test control, and status of inspections, tests and operations are included therein.
Sections 8.0, 9.0 and 10.0 again apply to all activities within the scope of this plan.
Section 8.0 addresses the identification and disposition of nonconformances associated with all aspects of the Program, In addition, this section contains the management controle provided for evaluating collectively material nonconformances and I
conditions adverse to quality and determining what corrective actions should be taken to preclude their recurrence.
Section 9.0 contains the requirements and administrative controls applicable to training; Section 10.0 contains the requirements and administrative controle applicable to the conduct of audits.
Appendices A, B and C contain additional requirements associated with the functional areas discussed in this Plan.
Appendix D contains the definitions of terms used throughout this Plan.
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3685L (1/91)
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_.GPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r-_
PLAN FOR THREE: MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 1.0 Organization 4
1.0 orcanization The GPUN Organization Plan is the highest tiered document that assigns major functional responsibilities.
Implementing documents assign more specific responsibilities and tasks and define the organizational interface (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 the scope of_this
_. plan.
The GPUN organization is structured on the-basis that the attainment of the objectives of this plan relies on those who manage, perform, and support the performance of-activities within the scope of this plan; and, assurance of this attainment relies on those who have.no direct responsibility for managing or performing the activity.
The organizations responsible for the conduct, support and assurance of operation, maintenance, modification, repair, inservice inspection and refueling of the nuclear generating stations is illustrated in Exhibit 1.
These organizations have functions located both on site and-off site.
1 1
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' Unit 1, and Oyster Creek. This responsibility is administered through his management staff, including:
Corporate Secretary Directur - Administration and Finance Director - Corporate Services Director - Independent Safety Review Director - Nuclear Assurance Director - OCNGS Director - Site Services Director - TMI Unit 1 Director - Technical Functions 3820L (7/90) 8.0
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GPUNC OPERAT7CNAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND' UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 1.0 organization 4
These OP management staff members give their full support to the
~
requirements set forth in this plan ensuring full compliance by their respective staffe.
1.2 Director-TMI-Unit I and ovster Creek
'h i
Each of the Directors-of the nuclear generating stations reports to the 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 j
and all applicable-laws, regulations, licenses and-technical require-
.ments.
The Division Director-Oyster Creek;is the senior CPUN repre-sentative at Oyster Creek _and as'such assures consistent implementa-tion of policies and proceduren at=the plant and at GPUN off-site.
facilities in-the Oyster Creek area. -The-Division Director-THI-leis-the senior GPUN representative at-the THI site and as such assures.
consistent implementation _of policies and procedures at-the plant and at GPUN off-site facilities in"the TMI area.
1.3 Director - Technical Functions i
The Director-Technical Functions reports.directly_to the. Office of the President.. The Director's Quality Assurance plan responsibil-ities consist of providing-the requisite engineering and/or-technical _
support toi maintain _the~ design basis of the nuclear plant; maintain the configuration control documents; conduct operating experience 1 assessment (s); provide nuclear fuel management; provide _ core perform-ance monitoring; staf f and direct shif t technical advisors; raonitor 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'
'I coordination of plant modifications;;and, conduct startup testing.-
1.4 Director - Administration and Finance The Director-Administration and Finance reporte directly.to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of establishing, maintaining, and.imple-menting procurement.and warehousing plans and/or procedures, 1
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g GPUNC OPERATIONAL QUALITY ASSURANCE Numb;r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 1.0 organization 4
1,5 Director - Nuclear Assuran23 The Director-Nuclear Assurance reports directly to the Office of the President.
The Director's Quality Assurance Plan responsibilities consist of establishing, verifying and iniplementing quality assurance plans, practices and procedures; establishing, maintaining and delivering training and education programe sufficient to assure safe, reliable and efficient operation; establishing, implementing and main-i taining radiological controls, radiological environmental.nonttortag, emergency preparedness, medical examination, and fitness for duty testing plans and procedures consistent with Corporate Policies and all applicable laws, regulations and licenses.
1.5.1 Director - ouality Assurance The Director-Qua.lity Assurance has the functional authority, inde-pendence and responsibility to assure the effective implementation of l
and compliance to the Quality Assurance Program.
Consistent with l
this responsibility is the authority to render interpretations in writing on those activities to which this plan applies and the extent to which the plan applies to those activities.
The Director-Quality Assurance reports directly to the Director-Nuclear Assurance.
Additionally, The Director-Quality Assurance has direct unencumbered access to the Office of the President and the Directors of each of the nuclear stations with regard to quality activities.
This reporting relationship has been established to p ovide the Quality Assulance organization with sufficient independ-enes from the influence of costs and schedulos to be able to effec-tively assure conformance to Quality Assurance Program requirements.
Exhibit 2 identifies the Quality Assurance Department (QAD) sections.
The Director-Quality Assurance has no duties or responsibilities unrelated to Quality Assurance that would prevent his full attention to quality assurance matters. The Director-Quality Assurance has the i
authority and respor.sibility to Develop and administer the maintenance of the Operational a.
Quality Assurance Plan and the Quality Assuranco Department procedures required to assure that all GPUN activities provide the required high degree of saf ety and reliability, b.
Audit, inspect and monitor the conduct of GPUN activities to assure that they provide the required high degree of safety and reliability and are carried out consistent with all applicable laws, regulacions, regulatory commitments, licenses, corporate policies and other requirements.
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M 7-IGPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r' PLAN FOR THREE HILE' ISLAND 3 UNIT l'
.1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 2.0 organization 2
c.
Provide welding, inservice inspection and nondestructive examination program development and maintenance.
Pr* form nondestructive examinations.
d.
Identify and-report nonconformances as they may exist Initiate, recommend:or provide solutions through designatud channels.
Verify implementation of resolutions, e.
Stop work or further processing, delivery or installation or take other comparable actions when warranted to control and/ori prevent the use:of nonconforming materials or co.ctinuance:of nonconforming activities.
f.-
Initiate unit shutdown recommendations when warranted by-a-safety concern and obtain unit shutdown with-appropriate upper-management concurrence.
g.
Provide for a review of selected documents which prescribe methods for activities and quality' requirements for.itema, parts and msterials within the scope of1this Plan.
h.
Provide for a review for concurrence of Contractor and Vendor-
-i Quality Assurance Programs, i.
Provide for the QA review of selected-design and engineering documents within the scope of this plan.-
l j.
Provide-for QA review of selected' procurement documents within the scopo of this plan.
k.
Direct and mhnage'the Quality-Assurance. Department.
l.-
Provide a working interface and line-of communication with=other divisions and other appropriate' industry and regulatory groups; for all QA matters.
Provide indoctrination,-certification, and/tr training-programs m.
for the QA Department.
Assure QA indoctrination of appropriate personne1'outside of the n.
QA organization is provided.
l' L
o.
Immediately notify 'the Of fice of the President and appropriate Unit Directer of'any significant quality related problem'or deficiency.
p.
Perform assessments on a planned and periodic basis to comprehen.
stvely determine the effectiveness of the program and its-implementation; and, detect adverse' trends as may;be present.
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5 gf CPUN? OPEP.tTIONAL QUALITY AFSURANCE Numb 3r f
PLAH fOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 l
AND OYSTER CRETK i
Revision No.
i Titic 1.0 organisation 4
=
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.ssue periodic reierts to the Office of the president and Division Directors on the effectiveness of implementation'of activities within the scope of this plan.
I r.
Provide for and maintain records generated by-QAD until turnover to the record storage facility (s) for storage.
1..
2 Minimum oualifications of ouality hesurance Personnel The Director-Quality Aseurance shall have, as a minimum a baccalaureate degree in Engineering er Science,_with at least fifteen (15) years *of technical experience including ten years of managerial / supervisory experience in operstionsl, technical support and/or quality assurance activities associated with nuclear power plants.
At least one year of this experience shal.'. be in a Nuclear Quality Assurance organisation er a special training program approved by the Director, Nuclear Assurance will be completed within six months of assuming the. position.-
i Additionally, the Director-Quality Assurance must be kntwied,eable in operating license conditions, other regulatory requirements and commitments, plans, procedures and quality and technical standards.
Quality Assurance Department Section Hanagers are required to have a degree in Engineering ot Science and experience.in a position (s) having responsibility for the supervision and performance of_ operational, technical and/or quality assurance 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 pro-cesses, the qualification criteria shall bs delineated to the tech-i niques 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,l meenanical inspection, etc.).
The quclification requirements and experience-levelsL or other key f
Quality Assurance personnel are such'as to assure competence commen-surate with the responsibilities of and the Regulatory Guides asso-ciated with the activities performed by the position. _
r 1.6 Director - Site _Sarvices t
l The Director-Site Services reports directly to the office of the President. The Director's Quality Assurance Plan' responsibilities consist of estabitshing, 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.
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gf CPUNC OPERATIONAL QUALITY ASSURANCE Numbar i
PLAN POR THREE H!LE.! STAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Tit.e 1.0 organiattion 4
The Director's Quality Assurance Plan responsibilities also include 1
j the establishment, maintenance, and implementation of plans and procedures for nuclear plant security, security screening, safeguard contingencies and plant security guard force. training and qualiti--
cation consistent with Corporate Policies and all applicable laws, regulations, licenses and technical requirements.
1 i
1.7 corecrate secretarv l
t The Corporate Secretary reports directly to the Office of the President.
The Corporate Secretary's Quality Assurance Plan respcies-ibilities consist of establishing, implementing and maintaining i
document distribution and record retention programs and facilities.
1.8 Director - Indeoendent Safety Review The Director-Independent Safety Review reports directly to the office of the President. Thp Director's Quality _ Assurance Plan responsibil-ities consist of the establishment and conduct of' nuclear safety review and assessment activities which laclude those of the nuclear stations' Independent Onsite Safety Reviewforoup and the General Office Reivew Board.
1.9 Director - coroorate Services l
The Director-Corporate Services reports directly to the Office of tho' President.
The Director's Quality Assurance Plan responsibilities l
consist of the maintenance of the nuclear plants' operating licenses and the establishment, maintenance, and implementation of fitness for l
duty plans and procedures consistent with Corporate Policies and all l
applicable laws, regulatione'and licenses.
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gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1-1000-PLN-7200.01 AND OYSTER CP.EEK 1
Revision No.
Title 2.0 QUALITY ASSURANCE PRO 1 RAM 2
1 2.0 ouality AssurAntg_Procram 2.1 General This operational Qaality Assurance Plan is the highest CPUN document which provides tha 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 CPU Nuclear within the scope of this Plan.
This control la exerted primarily through the provision cf and compliance with implementing documents and assurance that such documents are adequate and consistently used.
t Adherence to the requirements of this Plan is mandatory for all GPUN orga-nizations 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, 6.111 provide the level of mas.agement control and assur-ance 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 varise 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 - Quality Ansurance is authorized and responsible for deter-mining if and to what degree this Plan applies to a given activity and/or' task.
In those situations.where interpretation of che Plan is required to l
provide clarity or resolve disagreements, such inter 14et. rations shall' be documented and approved by the Director - Quality Assurance.
- 2.2 Scope The scope of the.GPUN Operational Qurlity Assurance Plan includes but is not limited to items and activities related to safe nuclear plant opera-tion, protection of personnel and protection of the public.
To ensure consistency in identifying those items, parte, 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."
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AND OYSTER CREEK Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 4
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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 produces a Quality classification List which identifies the permanent plant structures, j
systems, and components that are within the scept 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 technict.1 and quality requirements will be specified, documented and approved as part of 4
the procurement process.
This Plan may ba applied to items, parts, and saaterials other than those designated as " nuclear safety related" or " regulatory required" as specified by GPUN management.
2.2.2 Activities within the scope of this plan are designated as within "QA Plan Scope." Activites that are within the scope of this Plan are those i
directly related to nuclear and radiological safety and protection of the public and are delineated below.
I support activities within the scope of this Plan are system / component /part classification, operating experience assessment, design, maintenance of environmental and fire protection qualification, nuclear fuel management, i
procurement, fabrication, handling, shipping, storage, cleaning, erecting, installing, testing, repairing, training, welding, inservice inspection, heat treatment, document control, records management, security screening and fitness for duty.
Operational activities within the scope of this Plan are normal, abnormal and emergency operation, chemistry control,-core performance monitoring, l
shif t technical advice, equipn. ant control,. surveillance testing, inservice testing, maintenance, housekeeping, fire protection, security, radio-logical controls, radiological environmental monitoring, radwaste prepa-ration 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, nondestructive examination, inspection, monitoring, sutveillance, and safety review.
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PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER-CREEK novision No.
Title 2.0 QUALITY ACSURANCE PROGRAM 2-The above activities are controlled through the use of approved documents which are, as a minimum, consistent with the requirements of this Plan, the unit operating _ License, specific Regulatory Guides to the extent j
listed and committed to in Appendix C of this' Plan, the Final Safety j
Analysis Keport, and other regulatory requirements and.cammitments.
Those approved documents which specifically prescribe the eethods to implement I
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 upons a.
Statements within the text and the regulatory guides identified in Appendix C of this Plan;
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b.
Th( rslationship of the task (s) to the safe operation of t..a nuclear plant; c.
'the relationchip 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 publict i
The relationship of the task (s) to regulatory requirements and e.
commitments, and; i
k f.
Other factors as may be specified by CPUN management.
i l
2.3 Oraded Aceroach The extent to which the requirements of this Plan and its implementing documents are applied to an item will be based upon the followings a.
The effect of a mt.lfhnetion or failure of the item on nuclearisafety or_ safe piant operation, b.
The design and fabricatto.. :3spitxity or uniqueness.of the item.
I c.
The need for.special-controls, and surveillance'or monitoring of I
processes,- equipment and operational activities. :
1 q
- d..The degree to which functionality.can-be demonstrated by-inspection or
.j test.
I e.
The quality history and degree or standardization of the_ item.
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_h gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 2r i-PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 i
AND OYSTER CREEK Revision No.
1 Title 2.0 QUALITY ASSURANCE PROGRAM 4
The gus11ty 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 j
requirements will be established by the responsible department and reviewed by the Quality Assurance Department consistent with Appendix 3 of this Plan.
l 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 pre-viously submitted to tbs 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 asso-ciated with emergency planning, physical plant security, safeguard contin-gency planning, radiological controls, radiological environmental controls, fire protection, inservice inspection, inservice testing, licensed operator qualification and requalification, process control, offsite dose calculation, shift technical advisor training, envirecAental qualification of electrical equipment, security guard training and qualification, etc.
2.4 Three Level Acoroach GPUN is committed to a comprehensive assurance process consisting of a three level approach to assure satisfactory, consistent and complete imple-mentation 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 activitios are performed by the Quality Assurance, Operations, Plant Maintenance, Radiological Controle, Site Services, Technical Functions, and contractor personnel. Where tha first-level activities involve independent inspection for purposes of acceptance and/or verification, the activity will be performed by the QA Deper'.mant or by organizations authorized to perform those activities by the QA Department.
Operations, Plant Maintenance, Site Services, Radiological Controls, and Startup and Test personnel perform activities such as tests, calibration of instruments, radiation wurveys, analyses.of samples, valve line-ups, etc.
Site Services; and, Plant Maintenance / Material' personnel perform checks, inspections and/or tests of modification, replacement, repair and/or overhaul activities.
' - Quality control personnci perform receipt inspection and checks and.
inspections of modifications and maintenac,.ce-activitics.
Contractors perform inspections as applicable to their. scope of. work.
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[ gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 i
AND OYSIER CREEK Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 4
Technical Functions personnel periodically perform walkdowns, obser-i vations, measurements, etc. to revalidate the physical or functional configuration or condition of plant systems or components.
In all cases, the inspection, check and testing activities are performed by individuals who ato knowledgeable of the activity being performed and are qualified to perforn, the work (refer to section 6.2).
Checklists, weld history records, travelers, r parts, 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, monitor.ng, and document review and are performed as deemed necessary by the QA Modifications / Operations or Corporate Procurement QA Sections. The level of surveillance or monite-ing applied is consistent with the importance of the item to safety and the extent of administrative controls utilized for the Level I activity.
For activities where GPUN Quality control is performing first-level inspection, no second-level activity is required.
At this level, procedures and instructions are established and surveil-lance and/or monitoring records will be completed and maintained.
Such surveillance / monitoring normally includes observation of tests and inspections, observation of selected operations, review of records, verifi-cations of test reports, and direct inspection on a opot-check basis.
The organizations performing this activity have the levels of-authority, the lines of internal and external communication for management direction, and properly trained personnel for implementation of these activities.
2.4.3 - Levol III - The purpose of this level of activity is toJassure, through a comprehensive program of review and audit, that the first and second
~
levels of the program are properly functioning, and that all' organizations-l conducting activities and/or tasks within the scope of this plan-are properly satisfying all the requirements of the Operational Quality Assurance Program.
At this level, procedures and instructions are established, including the use of comprehensive checklists or detailed reports for: documentation of the audit or third-level activity.
The. program requirements of ANSI N45.2.12 shall be eatisfied.
Lead auditors shall be utilized who are qualified to the requirements of ANSI N45.2.23.
Additional technical support personnel, from-areas with administrative re' porting outside the function that is being audited,'will be utilized as Audit-Program Manage-ment deems necessary.
The-organization performing-this' audit activity has sufficient authority. independence and lines of internal and external l
communications to obtain the necessary access to management to conduct 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.
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Title 2.0 QUALITY ASSURANCE PROGRAM 4
I 2.5 Operational cua11tv Assurance Plan Contrql This Plan is authorized by the Of fice of the President and requires that the appropriete 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 docu-ments (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.
f With the exception of Organization, Section 1.0 and QA Program, Section 2.0, each section of this Plan contains three major subsections:
ceneral - A summary description of the general approach of CPUN with regard to conttolling the specific subject (s)_of the section.
It charac-terizes the intent of the section by stating the overall objectives to be met and/or the results to be achieved.
Recuirements - A description of the requirements applicable to the specific subject of the section.
Eggoonsibilities - Identification of those organizations and their respon-albilities relative to the specific subject of the section.
2.5.1 Aceroval This Plan shall be originated by the Director-QA and-be approved by the Office of the President after being reviewed for concurrence by the-following:
Corporate Secretary Director - Administration and Finance Director - Corporate Services Director - Independent safety Review Director - Nuclear Assurance Director - OCNGS Director - Site Services Director - TMI Unit 1 j
Director - Technical Functions Administrative Support Manager 2.5.2 Revisions The Director - Quality Assurance, with the assistance of_the Licensing ~and Regulatory Affairs Director,=shall, for each-revision-to this Quality Arsurance Plan, determine if the changes reduce or do not reduce the I
commitments in this plan previously acceptwd by the NRC.
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PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK j
Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 2'
Revisions to this Quality Assurance Plan that do not reduce the commit-ments in thio Quality %ssurance Plan previously accepted by the NRC shall be originated by the Director Quality Assurance and approved by the office of the President with the concurrence of the Director - Nuclear Assurance and any Division Director-affected.
The Cover Page ;ontaining the.
approval and concurrence signatures of the office of the President and the Division Directors shall be retained. Revisions of this type do not require approval by the NRC prior to amplementation, but must be submitted to the NRC at least annually. The Document History page vill 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 sub-mitted to the NRC and receive NRC approval prior to implementation.
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 j
after submittal to the NRC whichever comes first.. The submittal.of the
.j revision to the Quality Assurance Plan must. include all pages affected by that change and must be accompanied by a transmittal letter identifying
~i 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 - Quality Assurance, 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 estab-lished in Sectica 3.
2.5.4 Effective Date of Imolementation Changes to this Plan shall be incorporated in-the.impismenting documents within 60 days of the icuuance date of the Plan unless an interim action plai. is define ( and approved by the Director - Quality Assurance.
2.6 Ouality Assurance Procram Review The effectiveness of the QA Program and11ts implementation is periodically
-reviewed by various organizations at various levels and the results of 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-QA Department through the: surveillance, monitoring and auditing functions.
Other_ divisions provide additional information/ evaluations are requested.
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]
AND OYSTER CEEIK Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 2
In addition to the reviews and evaluation performed by the QA Department, the Office of the President shall have, at least once per year, an inde-pendent assessment performed of the QA Program implementation to ensure that the QA Program is effective in ensuring that regulatory requirements
)
and commitments; and, CPUN policies are met.
This assessment may be performed utilizing the safety review groups, an independent consultant, representatives of other utilities _and/or his own staff. Any corrective action which may be deemed necessary as a result _of these assessments shall be formally identified and tracked through resolution.
2.7 Indoctrination and Trainino Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are required to be i
established and maintained.
A Training department is. established and.
staffed and is responsible for planning, scheduling, developing and providing training to CPUN personnel.
The indoctrination'and training programs are watablished by on-site and by off-site organize.tional 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 implemented:through either retraining, reexamining and/or recertifying.
When certification is required, a certificate (s) shall deline?te the i
specific function (s) the individual is certified to be able t', perform and the criteria used to certify the individual for that function (s).
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 imple-menting the requirements of this Plan shall be marked as specified by.
3.2.2.2.b of this Plan.
Items within the scope of this Plan shall be classified'and identified as l
" 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 - Quality Assurance prior to issuance.
i.
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AND OYSTER CREEK Revision No.
l Title 2.0 QUALITY ASSURANCE PROGRAM 2
Structures, systems and componente, but not parts thereof, shall be identified on a Quality classification List (OCL). A QCL shall be estab-lished and maintained, by Technical Functions, for each plant.
The classi-fication of structures, systems and components will be-subject to inde-pendent design review as part of the classification process.
Spara 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 I
part.
For procurement of spare or replacement parts which are of a different claesification, the classification will be determined by Plant Engineering or Technical Functions.
The determinations will be documented, reviewed by Quality Assurance consistent with Appendix B of this Plan, and retained.
Refer to Section 5.0 for specific requirements.
2.9 Reculatory Commitments Records of regulatory requirements and commitments are maintained by Licensing and Regulatory Affairs. Appendix C herein lists those Regu-latory Guides which contain specific quality assurance requirements with the stated CPUN position, exceptions and/or clarifications provided.
These must be complied with in conjunction with this QA plan.
Aprendix C will be revised, as necessary, to reflect any change in the CPUN commit-ment to the Regulatory Guides.
l 2.10 Safety Reviews I
l 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 necesbary, 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 CPUN Review and Approval Matrix.
The independent safety review in.an independent review of documents and j
substantive revisions of documents as specified by the GPUN Review and l
Approval Matrix.
It includes a review of a safety' evaluation.
This review is conducted by a_ qualified-Independent Safety Reviewer (ISR)Lon safety evaluations associated with documents and substantive revisions to-documento as specified by the GPUN Review and Approval. Matrix._ The ISR
'shall not have direct responsibility for the activity reviewed.
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Q M7 GPUNC OPERATIONAL QUALITY ASSURANCE NumMr PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 2
2.10.2 The second element of the safety review program is the Independent On-Site Safety Review Group (IOSRG).
An IOSRO 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 Nuclear Safety Assessment Director.
Each IOSRO will consist of a Manager, Nuclear Safety who reports to the Nuclear Safety Assessment Director 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 l
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 baeis up to a maximum of two years.
Each IOSRO shall have access to the unit and unit records as necessary to parform its evaluations and assessments.
Based on its reviews, the IOSRG shall provide recommendations to the management positions responsible for the areas reviewed.
IOSRO reports of evaluations and assessments shall be prepared, approvod, and transmitted to the Nuclear Safety Assessment
- Director, Director - Independent safety Review, and the management positione responsible for the areas reviewed.
2.10.3 The third element of the safety review program is the review by the Nuclear Safety Assessment Department (NSAD).
NSAD is an independent organization reporting to the Director -
Independent Safety Review.
In addition to overseeing the IOSRO, the Nuclear Safety Assessment Depar*
ment, through its headquartern staff, will assess all aspects of CPUN activities as well as developments elsewhere in the nuclear industry.
It shall provide the following safety review functiones An overview of activities affecting or potentially affecting safety.
a.
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.
b.
A Corporate Ombudsman accessible on a confidential basic to anyone in the company having a nuclear or radiation safety concern he or she considers is not being adequately addressed.. The Ombudsman is empowered to investigate such matters, identify any needed action and seek its resolution. The Ombudsman will reply to the individual who raised tht matter.
c.
Staff support to the General Office Review Board.
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Q gf CPUNC OPERATIONAL QUALITY ASSUI8SCE Numb 3r PLAN FOR THREE MILE ISLAND UN3Y 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 4
2.10.4 The fourth element of the safety review program is the General office Review Board.
This is a group of senior levei individuals with diverse backgrounds.
It reports to and takes general. direction from the office of the President but has direct access to the Chief Executive Officer and the Doard of Directors.
Its charter 16 broadly defined to enSowpass all matters potentially affecting nuclear safety so as to foresee potentially significant nuclear safety and radiation problems.
2.11 Resoonsibilities 2.11.1 of fice of the President The Office.of the President - GPUN is responsible to regularly assees the
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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 a.
Review of audit reports, periodic status reports, etc. on-the effee-tiveness ard implementation of the Quality Assurance Program.
b.
Performance at least once a year of an independent _ assessment of the-effectiveness of the Quality Assurance Program to assure that this program ensures compliance.with regulatory requirements and commit-ments and CPUN policies and directives.
This assessment may be performed utilizing the safety review groups, an independent consultant, representatives from other utilities and/or.the President's own staff. Any corrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution.:
2.11.2 Director - Nuclear Assurance The Director-Nuclear Assurance has overall responsibility for establish-ment of the CPUN Operational Quality Assurance Plan.
The Director through the Director-Quality Lasurance shall provide periodic status reports to the of fice of the President on the ef fectiveness and imple-mentation of the Qual.ity Assurance Program.
2.11.3 Director - Ouality Assurance The Director-Quality Assurance has the authority and. direct respon-L sibility to verify the effective implementation of this Quality Assurance Program.
This responsibility in principally discharged through the
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review of documents which-implement this Plan, the verification that such documents are effectively and consistently implemented, and providing the requisite leadership to assure that. required corrective action is promptly defined and implemented.
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Title 2.0 QUALITY ASSURANCE PROGRAM 4
The Director-Quality Assurance shall establish and implement a formally.
documented and procedurally controlled process to evaluate and report on the adequacy and continued effectiveness of this Plan and its implementa-tion. The basis for this evaluation report (s) includes reports of audits performed by Quality Assurance; QA' monitoring of station activities; evaluations of suppliers, source surveillance of equipment suppliers; audits of external service organitations; and quality trend analyses based on nonconformance and deficiency reports and reports of inspec-tions, examinations,' surveillance / monitoring and audits.
These actions may involve specific actions to provide compliance with this Plan and may include follow-up audits and revision to the Quality Assurance Program..
]
Implementation and closcout of. corrective actions shall be effectively l
followed up by the Director Quality Assurance to assure timely correction and complianec.
The Director-Quality Assurance is responsible.for the contents of this Plan and 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-Quality Assurance for review and-action.
2.11.4 Director - Technical Funttions The Director-Technical Functions is responsible for development and main-tenance of the Quality Classification List.
2.11.5 Director - Corocrate Services The Director-Corporate Services through Licensing and Regulatory Affairs is responsible for providing CPUN documented positions and interpreta-tions on all other regulatory guides;not contained in Appendix C of this Plan as may be required.
i 2.11.6 OPUN - Manacement Management personnel in each division are responsible for the implementa-tion of the Quality Assurance Program'by thGir division, department or i
group, including the development and implementation of approved docu-ments, ar.d, the training and indoctrination of their personnel associated with those of'their activities within the scope of 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 y
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-f and other activity as may be required to implement Technical Specifi-cations Appendix A, Section 6.5,-requirements.
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1 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 respon-sibility to correct includes adverse trends as may be identified by appro-priate analysis.
2.11.7 External oroanizatloan Suppliers who provide items, parts, materials, consummables, 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, consummables, and/or services The supplier's QA program shall be-subject to review for concurrence by the Director-Quality Assurance or his designee.
The extent to which the supplier's QA program will be applied will be specified by procuromant docutaents.
2.11.8 gesolution of Discutes and Ecealatione Disputes involving quality arising from a difference of opinion between QA/QC peroonnel and another organization (s) (engineering, procurement, manufacturing, construction, operation, maintenance, etc.) personne1' i
shall, if possible, be resolved at the level at which such disputes occur.
If this is not possible, the difference of opinion shall be esca-lated through supervisory / management levels until resolution is achieved.
The Director-Quality Assurance shall make the decision on matters related-to if and to what degree this plan applies to activities, quality requirements, and verification and acceptance to established requirements..
i The Director-Technical Functions shall make the decision on matters l
related to classification of items, parts, materials, and technical tequirements or design changes.
The Director-Quality Assurance shall be responsible.for evaluating deficiencies.for_ trends. Significant or repetitive failures to comply with administrative, technical,. operational or this Plan's requirements will be' further evaluated to determ.no the safety significance of the conditior..
In these cases, canagement 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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g gf GPUNC OPERATIONAL QUALITY ASSURANCE Numbst PLAN FOR THREE MILE ISLAND UNIT l-1000-PLN-7200.01 q
AND OYSTER CREEK Revision No.
I Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 2
l 3.0 CONTROL OF DOCUMENTS AND RECORDS j
3.1 Plans. Procedures, Instructions. Drawinos. Soecifications 3.1.1 General' Activities which are within the scope of this Plan shall be prescribed l-by approved documents of a type appropriate to the circumstances, i
These documents shall be complied with in the performance of the activity or changed prior to proceeding with tho activity. These docu-ments typically include but are not limited to those term 3d plans,
. procedures, instructions, directives, drawings and specifications. All personnel.shall be indoctrinated in the use or content of such docu-ments prior to commencement of the activity.
3.1.2 Reeuiremente 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 docu-ments shall:
i Define the responsibilities and authorities of personnel per-a.
forming the activity.
b.
Describe interfaces between GPUN organizational units and/or external organizations that participate in-or are'affected by the-conduct of the activity.
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 sue 6 activ-ities have been satisfactorily accomplished, Identify and specify the content of records-to be generated in e.
conducting the activity, f.
Include references as needed to implement the activity. When such I
references are utilized, the-specific requirements of the refer-ences which are-applicable shall be identified or. incorporated
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into the document.
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Title 3.0 CONTROL Ol
- 3aENTS AND RECORDS 2
g.
Be approved and concurred with by responsible personnel prior to the initiation of the activity.
h.
Be distributed in a controlled manner to preclude the use of obso-lete documents and with sufficient number of copies to assure availability to responsible personnel.
Reviews of such documents-shall be conducted by the Quality Assurance
-I Department (QAD).
The timing and scope of QA document reviews shall be as detailed in Appendix B.
-These QAD reviews are conducted to indepen-dently verify that the document is appropriate for use.
These QAD reviews assure, as a minimum, that the reviewed document is consistent with the pertinent QA Plan requirements; contain inspection and verifi-cation requirements where applicable; contain quantitative and/or quali-tative acceptance critoria; contain clear definition of the extent of documenting results of completed actions when required; and, has been i
(after implementing approval) prepared and reviewed consistent with QA Plan requirements;.
Documents which prescribe methods for implementing this Plan shall be followed as written or changed.
The requiremente for use of such docu-ments 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.
3.1.3 Responsibilities 3.1.3.1 Egoartment Manaaers The Director or Manager of.each department perforning activities within-the scope of this Plan is responsible for the preparation,Lapproval and implementation of documents which prescribe activities and/or tasks necessary to effectively implement.this Plan. This responsibility includes ensuring that provisions are made for interface controls for' internsl and external lines of communications among~ participating orga-nizations and technical disciplines.
. )
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PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 3.0 CONTROL OF DOCUMENTS AND RECORD 8 2
I 3.1.3.2 ouality Assurance Deoartment (QAD)
QAD shall review those approved documents which prescribe the methods; of complying with the requirements of this Plan.
When specified in procurement documents supplier Quality Assurance-Plans /hanuale,-cpecial process procedures, and inspection and test proceduras shall be reviewed for concurrence by QAD prior to authorizing the supplise to start work.
3.1.3.3 External oratnizations 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, cource surveillance, source inspection, monitoring and inspection programs.
3.2 Document control 3.2.1 General Document control procedures shall be established to control.and coordi-nate the classification, review,' approval,' issuance, revision,.and i
change of approved documents which prescribe methods or provide the technical and/or_ouality requirements for activities'and items within
~
the scope of.this plan. These documsc.t control-procedures shall ensure that such documents are reviewed for adequacy, approved for release and l
use, and distributed to the location where the activity is performed.
3.2.2 Recu i remtult,,g 3.2.2.1 Written document control procedures shall be established to provide for the control of the following types of approved documentos_
. a.
operational Quality Assurance Plan, GPUN organization Plan, CPUN Review and Approval Matrix, Quality Classification List, Environ-mental Qualification Master List (s), and Supplier Quality classifi-cation 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.
Quality Assurance. Department Plans, Procedures, and Standards.
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Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 2.
~
d.
Operating, surveillance Testing, Refueling and Equipment Control Procedures and Instructions.
i e.
Maintenance Work Authorizing Documents, Procedures,. Instructions, Vendor Manuals and Vendor Information.
3 f.
Engineering configuration control documents which include-safety; analysis, safety evaluations, calculations, standards, specifications, system / modification design descriptions, design 1
reviews and/or verifications, drawings and lists.
9 Computer codes utilized for calculational-tasks associated with activities within the scope of this Plan.
h.
Engineering, Manufacturing, Construction, Hodification, Instal -
latirn, Welding, Test, Inspection and Hondestructive Examination Procedures,-Instructions, Standards, and Specifications.
1.
Procurement Documents, specifications, and Contracts.
j.
Final Safety Analysis Report (s), Fire Protection Plan (s)i Fire Hazards Analysis Report (s),' Emergency Plan (s), Security Plan (s),
Safeguard Contingency Plan (s), Quard Force Training and Qualifi-cation Plan (s) and offsite Dose Calculation Manual (s).
k.
Nonconformance, Deficiency.and Deviation Reports or Requests.
1.
Operating and'Special Orders.
m.
Procurement and Haterial control Procedures and Instructions.
Radiological control, Procese: Control,. Radio 1'ogical Environmenta1>
n.
Monitoring, Radwaste Shipping and. Chemistry contro11 Plans, Procedures, Instructions. Standards, and. Specifications.
3.2.2.2 Procedures established for document control.sha11' prescribe the~
following requirements:
a.
Drawings, design 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,P.2.a above..
l l
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h gf GPUNC OPERATIONAL QUALITY ASSURANCE Numb 0r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 2
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 require-ments 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 organirations except for documents originated by organizations outside GPUN.
In this case, GPUN may designate the review and approval organiza-tiena.
Approved changes shall be promptly transmitted for incorp-oration into documents and obsolete or superceded documents shall be eliminated from use.
g.
Document distribution shall be sufficient to assere that the documents are readily available to responsible personnsh prior to commencement of work.
h.
The user of approved documents is responsible for assuring that the latest issue of the document is being used to perform work, thus assuring that voided, superseded or obsolete 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 this plan.
1.
In the special case of documents containing information pertaining to plant security, provisions shall be made to prohibit unauthorized disclosure of certain safeguards information.
These provisions shall include identification of the documents, restrie-tions on their distribution and storage in locked security storage containers.
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CPUNC CPERATIONAL QUALITY ASSURANCE Numb 3r PLAN POR THREE MILE ISLAND UNIT 1 1000-PLN-1J00.01 AND OYSTER' CREEK L
Revision No.
l Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 4
l l
3.2.3 Resoonsibilities 3.2.3.1 corporate Seeretarv i
Responsible'via the Information Management Center Managers to establish and maintain approved documents to implement the GPUN Document Control i
Program.-
3.2.3.2 Director - corocrate services Responsible to develop and administer a corporate policies and pro-cedures system.
3.2.3.3 Director - Nuclear Assurance Responsible via the Director-Quality Assurance for the review of GPUN document control procedures and the evaluation of;the overall document control system effectiveness through document review and audit.
3.2.3.4 All Functional Manaaers Responsible to provide specific document-control procedurse, as required, to implement the corporate document control policy.
Respon-sible to ensure that documents are available when required; to properly review and approve documents such as procedures, instructions, specifi-cations, drawings, etc. to ensure that changes to documents are l
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.
i 3.3 Records 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 l
j 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,fand retrieval of such. records, a
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l AND OYSTER CREEK i
Revision No.
j Title 3.0 CONTROL OF DOCUMENTS AND' RECORDS 2
l 3.3.2 Recuirements Approved documents shall be established for the identification. genera-l tion, collection, storage, maintenance, retention and retrieval of records and shall provide for the following minimum requirements:-
a.
Design specifications, procurement documents, and/or CPUN proco-dures shall specify the records'to be generated, supplied and maintained by or for CPUN, including retention times Typical records to be specified include operating logs, maintenance ant' modification procedures and related inspection results, report 3 4e
. 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; corrective action reports; and other records required'by Technical specifications.
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 I
3.
Identification of any conditions adverse to' quality.
4.
Inspector or data recorder ~ identification.
5.
Evidence a; to the acceptability'of the results.
?
6.
Action taken to resolve any discrepancies noted.
' )
1 c.
Record' storage facilities shall be established and utilized to
~
preven
- destruction of quality. records by' fire, flooding, theft and-
- i deterioration by environmental conditions: such asj temperature. or.
humidity,in compliance with:the standards, codes and regulatory 4
guides endorsed in Appendix C of this Plan.
d.
All records shall be legible in original or' reproduced form.-
4 I
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AND OYSTER CREEK Revision No.
Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 4
i 3.3.3 Resoonsibilitieg i
3.3.3.1 Director - Nuclear Assurance
-l i
The Director-Nuclear Assurance is responsible through the Director -
Quality Assurance, tors a.
Reviewing procedures related to the identification, generation, collection, retention, storage, retrieval, and maintenance of records.
b.
Establishing procedures and/or instructions for the.identifica-tion, generation, collection, retention, storage, retrieval, and maintenance of records generated by QAD, until they are turned over for storage.
3 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 source inspection, or receipt inspection to verify that required records have been generated and supplied with items, parts or materials.
3.3.3.2 GPUN Division Direet_ogg 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 L
until such time as they are transferrod to the applicable Information Management Center for etcrage.
l b.
Providing direction in approved. documents to ensure the identi-fication generation and maintenance of reaords-with sufficient detail-to furnish objective evidence that activities within the-scope of 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 Secretary The Corporate Secretary is responsible through the Information Manage-ment Center Managers fort i
a.
The collection, maintenance,'and storage of records in accordance with approved written procedures and instructions which conform to the requirements of this section.
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Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 2
i b.
Providing procedures and/or instructions which ensure the main-tenance, storage and retrievability of records..
c.
Establishing and implementing the CPUN Records Control System.
i 3.3.3.4 External oroanizations Records generated by suppliers shall be controlled according to the supplier's or GPUN procedures until such timeras they are turned over to the CPUN for review, acceptance, and t ransmittal to the' permanent-
. [
records file.
Purchased equipment'recoriis shall be retained by the i
supplier until the equipment'is released for shipment at which time the
]
records required by procurement documents are to be submitted.to OPUN.'.
When required by the procurement documents, seppliers-shall:establich F
procedures for the identification,- generation, callection,: storage, maintenance, retrieival and/or transmittal.of records.. Implementation j
of these procedures shall be assured by performance of source surveil-i lance, source inspection, monitoring and audits performed by QAD.
Records to be submitted with the shipment or retained by the supplier will be specifically identified-in procurement documents.
If' records are to be retained by the external organization for GPUN, then the storage condition and retention period-shall be specificed in the-procurement document (s).
These records'will be reviewed by QAD.and/or Engineering to provide the required degree:of confidenca in.the; adequacy of compliance of the supplier'with the requirementelof th'.s section.
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Title 4.0 Design Control 2
4.0 DESIGN CONTROL l
4.1 ceneral Measurus shall be established and. documented to assure.that the appli-cable specified design ~ requirements,:ruch as design bases,-regulatory i
j requirements, codes and standards are correctly translated into specifi-L cations, drawings, procedures or instructions.
These measures shall I
include provisions to assure that appropriate quality _ standards are specified and included or referenced in design documents for design of systems and structures.
4.2 ggpuirements Design control measures require that:
l 4.2.1 The organizational structure be defined, and authority and-responsi-bility of personnel involved in preparing,-reviewing, approving and verifying design documents be delineated.
4.2.2 The design bases, safety analysis, regulatior,, 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.
1 4.2.3 The materials, parts and processes selected by design are reviewed to assure that they are suitable for the inter. ted application, including compatibility of materials, accessibility Aur inservice inspection, maintenance and repair, ALARA considerations, personnel safety, fire-hazards analysis, and quality standards.
The review will-also evaluate I
suitability with regard to human factors which may affect safe opera-
~
tion and the suitability of commercial grade materials,. parts'and-equipment to the application.
.s l
4.2.4 Internal and external design interface controls, procedures, and-lines of-communication among participating. design organizations and-across technica1' disciplines are established and described for the.prepara-tion, review, approval, release, distribution, and-revision of'docu-wents involving design interfaces.
4.2.5 EJrors and deficiencies ~in approved. design documents,' including design
)
methods (such as computer codes) that covld adversely affect items and activities within the scope of this plan shall be doc sented, and act10n shall be taken to assure that these' errors!or deficiencies'are corre ted.
In addition, any errors or deficiencies-resulting from the' application'or.use of the design' documents shall beiidentified and:
~
corrected.
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PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 4.0 Design control 2
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4.2.6 Deviatior.s in specified quality standards shall be identified and procedures shall be established to assure their resolution and control.
t 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 l.
prior to such use.
4.2.8 Design verification methods (design review, alternate calculations or-qualification testing) shall be established and completed prior to turn-t
-over for operation.
4.2.9 Design verification procedures shall be established which assure the following i
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.
e.
The responsibilities of the verifier,'the areas and featuresoto be verified, and the extent of documention of the verification shall be specilled.
4.2.10 When verifications are to be accomplished solely by test -
a.-
Prototype, component or feature testing shall be' performed pricr.
to installatio, of the equipment, or prior to the point when-the installation would become irreversible.-
b.
Verification by test shall be performed.under conditions that simu-late the most adverse design conditions as determined by_ analysis.
I 4.2.11 Procedures shall be established to assure that' computer codes, and l
s changes thereto, are verified,: certified and controlled to prevent unauthorized changes.
i 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 o
to review and approve changes.-
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. PLAN FOR THREE MILE ISLAND UDIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 4.0 Design control 2
4.2.13 Design documen'aJ subject to procedural control include, but are not limited to, specificatioas, calculations, computer programn,: design i
descriptions,.and drawings, including flow diagrams, piping and instru-ment diagrams, system diagrams, facility drawings showing equipment locations and site arrangemects.
4.2.14 Mecsures, which include procedure changes, shall be.provided to. assure l
that responsible plant personnel are made aware of design-changes:
and/or modifications, which may< affect the pert'ormance of +deir duties.
4.3 Responsibilities 4.3.1 Director-TMI Unit 1, and Ovster Creek The Directors-TH! Unit 1, and Oyster creek are each responsible through their respective Plant Engineering Directors for the. implementation of design control measures in accordance with approved Technical Tunctions
.j proceduros.
4.3.2 Director-Technical Fuqctione The Director-Technical Tunctions is responsible f or the development and implementation of'the design control rueasures utilized by Technical-Futictions and Plant Engineering departments.
4.3,2.1 The Director-Technical Functions is responsibitt through the Director-Engineering Projects and the Director Engineering and Design for'coordi-nation 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 I
Design wills.
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 Quality Assurance review of applicable. design criteria docu-ments and~ specifications,; and changes thereto.
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Title 4.0 Design control 4
4.3.2.2 The Director-Technical Functions, through the Director - Systems Engineering, is responsible fore a.
Providing conceptual and analytical engineering service to other engineering groups as required.
b.
Providing technical administration of nuclear fuel-related engi-neering 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, through the Engineer-ing Services Director, for providing detailed design and drafting services and for the preparation and maint;enance 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 encineering disciplines as required to produce engineering documents for plant modifications and for the technical-perfcrmance of components and systems within the nuclear plants.
4.3.3 Director-Nuclear Assuraneg The Director-Nuclear Assurance is responsible.through the Director-Quality Assurance for providing Quality Assurance review of design and engineering documents to assure that appropriate quality requirements have been included.
In addition, Quality Assurance wil11 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.
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GPUNC OPERATIONAL QUALITY ASSURANCE
-Numb 22 j
PLAN FOR THREE. MILE. ISLAND. UNIT 1 1000-r f-7200.01
'AND OYSTER CREEK
.)
Revision No.
Tit 1e 5.0 PROCUREMENT.AND' MATERIAL CONTROL' 2
l l
5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement t
i 5.1 1 General
}
l S.1.1.1 Procurement of items,-materials,; parts, consumables,-equipment,Jand-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 docun.. ants; These methods shall-ensure-that technical, quality and regulatory requirements'and-rerulatory commitments applicable-to t.he procurement, are met as a minimun..
These methods shall ensure'that-procurement-sources are evaluated and confirm-that,the activities of_ consultants,_
vendors and contractore, a' purcha~ sed 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 Asurance' Plan.-
5.1.1.2 The general and specific requirements _for the; Quality Assurance Program j
of -all supplLers -including-their -subsuppliers s'upplying : items.:
o materials parts, consumables,' equipment or services, or within the scope of this plan shall'be prescribed by procurementidocuments.
These quality program requirements mhall'be consistent with Section 2.3 oi' l
this' Plan.
5.3.1.3 Quality Assurance Plan measures shall b'esapplied with a graded. approach to the procurement of new and, spare parts,-replacement' parts, com-mercial grade items and consumables. ' Procurement _of= spare o( replace-ment parts for structuras, systems.and components shall be subje-et to current QA program controls and.to-codes,' standards,ftechnical;and, quality requirements equal'to, or better thank original,-as may have been superseded ~or upgraded by regulatory requirements:or: commitments..
Ae a minimum, when documented. quality'and technical requirements.are not available,_then the procurement of spare parts,' replacement parts, j.
and consumables within the scope _ of this Plan :shall"be in accordance E
with an approved specification or.the:use justified by:a documented
_ engineering _ determination. The use of commercial grade it<<ms in l.
- nuclear safety-related applications shall-ce controlled'as specified by-l
'Section 5.1.2.4 of thic Plan.
i 5.1.2 Reauirements 5.1.2.1 Procurement Documents The requirement.a for the preparation, review, _ approval and control _of procurement.documente shall be prescribed in detailed 1 Jeedurts.--_
These procedures shall prescribe requirements'to-ensare that procuro ment documents:
4030' 3816L (12/88) l
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gf Ca... OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 ANJ OYSTER CREEK Revisian No.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL 2
a.
Specify the technical snd quality assurance requirements commensu-rate with regulatory requirements and commitmente and this Plan.
b.
Require applicable quality assurance requirements to be imposed on subvendors and subcontractors.
c.
Specify or reference design basis technical requirements, includ-ing applicable regulatory requirements and commitments, material and component identification requirements, drawings, specifica-tions, codes and standards, test, calibration, and inspection requirements, handling, storage and shipping requirements, and special process instructions.
d.
Identify the documentation to be prepared, maintained, and sub-mitted for rev!ew, approval and record information as applicable.
e.
Include an identification of :. hose items and activities within the scope of this plan.
f.
- 0entify those records which vendors or contctr.vas shall retain, maintain, and control; and those which vendort or contractors shall deliver prior to use or installation ot the item.
)
g.
Include right of access to vendors or contractors and subtier vendor and contractor facili".tes and records for source inspection
- d/or audit.
i'.
For spare or replacement parts, contain technical requirements at least equivalent to those used for the original procurement.
1.
Include the provision that suppliers shall refrain from imple-ment ng procedures wnich require owner approval pcior to obtaining such approval.
j.
Fequire design organizations performing design activities for GPUN to have and in.plement quality programs which include design I
co':rol provisions equivalent to those provided in this plan.
k.
Identify the programs, procedures, activities or conoitions that requiro GPUN approval and/or release.
Measuren shall be established for the review, approval, and release of procurement documents and subsequent revisions.
The reviews shall assure the inclusion of the ap.iicable technical, quality, regulatory, and administrative requirements in procurement documents prior to their use.
Review of procurement documents shal: be documented to provado objective evidence of their approval prior to release.
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gf CPUNC OPERATIONAL QUALITY ASSURANCE-
_ Numb 2r i
PLAN FOR THREE MILE. ISLAND UNIT 1
- lOOO-PLN-7200.01 AND OYSTER CREEK-
]
. Revision No.
Title 5,0 PROCUREMENT AND MATERIAL CONTROL.
2 5.1.2.2 Oualification and selection of External Oraanizations Evaluations of prospective suppliers shall be conducted and documented to demonstrate qualifications based upon-one os more of the'following-criteria:
a.
Review of performance histories which provide records of supplier previous capability to provide similar products or services.=
r b.
Review of the external organization's capability to comply with the GPUN Quality-Aesurance Program,;as applicable to'the items or services to be nupplied.
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).
.(
i Procedures shall'be established to prescribe the evaluation.and selec-tion of external organizations.
Contracts-or purchaee ordersffor items, materials, parts, consumables, equipment or services'within-the scope of this plan shall be awarded either toi I
d.
Externs', organizations whose-Quality Assurance' Program has'been_-
revir sed and accepted by GPUN Quality Assurance Department as befrg commensurate with the equipment =or services to be provided,-
or e
The external organization will be required, by-procurement docu-ments,.to work under the direct control of the GPUN Quality
~!
Assurance Program. -In these instances,5the supplier will not be required to have a separate _ quality assurance program.
t Wnen GPUN's acceptance.of;an external organization's quality assurance pecgram is required, it shall be reviewed for concurrence.by.GPUN= prior to initiation of the activity affected by their program.,
In the case af " commercial; grade items" the' procurement process shall.
-be controlled so that the dedication. process described'in 5.1.2.1 shall
-i be met.
5.1.2.3
-Manufacturino Assurance Heasurer sh'all be established to provide control of manufacturing activ-l ities.of. suppliers.
These methods shall be described in detailed written procedures.-
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.42.0 3816L (12/88) t
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~ Nu'mber PLAN FOR THREE MILE ISIAND UNIT l'
'1000-PLN-7200.01-AND OYSTER CREEK' Revision Nc.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL 2
The attributes of the manufacturing assurance program shall includes a.
Provisions for-the review for concurrence'of the supplier's draw-
)
ings, Quality Assurance manual,, manufacturing and quality proce- ~
y dures prior to fabrication.= When specified in approved procure-
- i ment documents suppliers _may not; implement procedures until' y
written notice of GPUN acceptance is received.-
b.
Established supplier inspection plans.that delineate, as required,.
the hold and/or witness points in the manufacturing procese for' specified review,. inspection,; verification-and test.-
c.
Methods for iden'ifying and reporting nonconformances and resolv -
ing of'nonconfc' nces where the supplier's suggested dieposition' is "Use-as-is" os " Repair". Such methods shall. require the' approval of the supplier disposition of nonconformances by the-responsible engineer:and approval of the responsible. Quality-Assurance organization..GPUN Quality Assurance shall also_ verify that repairs are accomplished in accordance'with the approved disposition.
d.
Notificat' ion of_ site'QC Receipt Inspection of outstanding noncon-formances 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 knr the criticality of the fur-nished items or services and;the evaluated resulte_of, supplier qualifications, including pre-award surveys and-QA document reviewe.
Revisions to source verificationiplans shall be made as warranted byfsupplier cerformance.
Typically, audits will:be-conducted on suppliers of services; and, source inspection,. source surveillances, and/or receipt. inspection will be conducted on suppliers of hardware.
f.
Control of supplier document package including review for complete-ness and:nceeptability.
Inadequate records which; render-the quality statusaof item (s) furnished indeterminate shall be
{
suf ficient cause ' for ' rejection of this item (s).
g.
Assessments of supplier control of quality shall be made,at a frequency 1and_ 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.
.43.0-
_I 3816L (12/88) l
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PLAN FOR THREE HILE ISLAND UNIT'l 1000-PLN-7200.01'
'AND OYSTER CREEK Revision'No.
- L Tit 1e 5~.O PROCUREMENT AND MATERIAL CONTROL-2
- l t
h.
Material acceptance procedures that assures q
1.
The material, component, or equipment'is clearly identified and that the identification and quantity correspond to the 4
information on the shipping documents and quality records.
C 2.
The. item's handling and shipping requirements have been met by the supplier and maintained.by the carrier.
4 3.
The item's record. package or compliance certificate is j
complete and adequate.
9 3
4 The material,-component-or' equipment meets the;tec..
.a1 requirements specifled in the procurement; documents,-inspec -
tion plans, checklists oc=other special engineering document..
f 5.
Items delivered which are not inl compliance with requirements are documented in accordance with the nonconformance-t procedure,' tagged (As item l configuration;or storage conditions 4
permit. Additional administrative controle shallLbe-used if.
tagging is not possible.), segregated (if:possible), and:
)
prevented.from being inadvertently issued for installation or' l
use.
.l I
l 6.
Items accepted.and released'are identified as-to the(r.inspec--
4 tion status prior to forwarding them-to a controlled storage 1
area or releasingLtriem for installation or further. work.
5.1.2.4 Commercial Grade Dedication for NSR-ADolications The process of acceptance of commercial grade items intended;for use-in
}
nuclear safety related applications 7shallsbe controlled.~and implemented
~
through an approved procedure (s):which includes the'following0 l
r a.
An engineering-evaluation to determine if-.the commercial; grade.
item performs a safety-function or.if its failure could compromise
[
a safety _-functions.
j b.
A determination that the definition of commercial gradenitem as
-I i
prov(ded in 10CFR21-is met.^
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c.
A determination of the critical chrracteristics which are essen-tial'for the performance of?its-safety function.
4 p
d.
-The definition of functiona. tests and/or! inspections, including i'
acceptance limits, to be performed to verify critical characteristics.
b 44.0-j 3816L (12/88) l i
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PLAN FOR THREE MILE ISLAND UNIT l-1000-PLN-7200.01 AND VYSTER CREEK Revision No.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL' 4.
I i
Verification that critical characteristics have been met by one of-e.
the following:-
1.
Performance of functional tests and/or inspections after l
1ecelpt by GPUN;
)
2.
Witnessing cf functional test and/or inspections at.the-supplier's facility.
3.
Assuring through audit'or surveillance that the supplier-has-a.
quality program which adequately controls the critical charac-teristics; performs _ tests an'd/or inspections which. verify that-critical. characteristics have been met; 4.
Establishing the commercial grade part performance. history-con-current with performing one of e(l)i.e(2) or e(3) above; or, 5.
Any combination of e(l) through e(4) above.
This dedication ptocess shall result-in the documented basis for the-appropriateness of the use of:the commercial grade? item (s) in thel specific nuclear safety related application (s).
5.1.3 ILqnp.gnelbilities 5.1.3.1 Director-Administration &' Finance The Director-Administration & Finance is responsible through the Director Materials Management for..the Administration and operation of contracting; procurement and ware-a.
housing activities of CPUN.
b.
Anaurancs that the technical and quality requirements, as-eshb-lished by requisitioners, are incorporated;into contract /
procurement documents wittout revision.
i c.
Assurance that bids are evaluated forzconformance to technical and quality requirements by the requisitioners, 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 et.bmitted in a_ timely manner and that they are complete and legible.-
3816L (7/90) i
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Nrder ovune oPra^Tzonit auxLITr assuainc=
number PLxN FOR THREE MILE ISLAND UNIT l 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 5
_ROCUREMENT AND KATERIAL CONTROL 4
f.
Assurance that pur;hase orders and-contracts for items and services within the scope of this. Plan are issued to external-orga-nizations-listed on the Suppliers Quality classification List.
5.1.3.2 Director-Nuclear Assurance i
o The Director-Nucleat 12 zurance is responsible through the Director-Quality Assurance tot a.
Assure that'QAD procedures.for the control of purchased' equipment, material and services are established, approved,-implemented and effective, b.
Review for cencurrence GPUN procodures necessary for the control of= purchased equipment,. material, and services that are within the scope of this Plan.
c.
Review supplier Quality Assurance Programs fa concurrence to tho extent required by the procurement documents.
d.
Review-for concurrence supplier record packages'as required by applicable procedures or procurement documents.
Establish and implement.-an adequate program of source inspection, e.
eource surveillance _and receipt inspection to assure that: items, parts, materials and consumables within.the scope-of this Plan comply with contract requirements.'
f.
Review procurement documents to' assure that quality requirements are correctly stated, inspectable and controllable; that there are adequate acceptance / rejection criteria; that source-verification or receipt inspection is specified; that minimum' documentation to be supplied is specified; and that the procurement ~ documents have been processed in accordance with:establishef.*quirements.. This review may include sampling _ review offprcv?out.y approved procure-ment documents or-in-line reviews of selected purchase requisi-tions or orders prior to placement, g.
Establish and maintain a Supplier Quality classification List-(SQCL) which documents the resu1*.s of the evaluations of pro-epective suppliers.
5.2 Identification and control-of Materiale, ter6.e and Cemoonents 5.2.1 General Measures shall t+ established to procide forl the identification and control of items, parts, materials, and consummables within the scope of this plan.' These measures shall assure that11ncorrect or noncon-forming iter re identified and controlled in order to prevent their 46.0 3016L (7/90) a-
Mf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r-PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 J
AND OYSTER' CREEK
-Revision No.
Tatle-5.0 PROCUREMENT AND HATERIAL CONTROL' 2
inadvertent installation or use.-
Where required by_ 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: nd. control.is maintained at various stages of manufacture, installation, or erection.
Identification requirements shall be specified in the applicable design and procurement documents.
5.2.2 Reauirements l
5.2.2.1 Identification.and traceability requirements shall'be included in-speci-fications and drawings.
)
5.2.2.2 Material, parts, and components, including = partially fabricated sub-assemblies or subdivided materialo,shallibe identified to preclude the
~
use of incorrect or-defective items.
5.2.2.3 Items, materials, parts, consumables, and equipment within the ccope of.
this_ Plan shall be identified so that they.can beitraced to appropriate documentation, which provides objective' evidence of"the te'chnicalEand-quality requirements mets such documents include but areJnot, limited to a.
Specifications b.
Drawings (including as-builts)
I c.
Phyrical and Chemical Test Reports i
e.
Nonconformance Reports f.
Inspection Reporte and Checklists g.
Storage Maintenance Instruc' ions h.
Hondestructive Examination Reports 1.
Vendor _ Certificates of Compliance consum-
?
The identification and/or end use of items,; materials,-parts'l ables, and equipment shall be specified in procuremens do umento and-work authorizing documents -to provide this-traceab11-1:y.
47.0-3816L (12/88)
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Q gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 2r PLAN FOR THREE MILE ISLAND UNIT 1 lOOO-PLN-7200.01 AND OYSTER CREEK i
Revision No.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL 4
l l
3 i
Traceability.to heat and/or lot number shal. be provided when required by code (s).
Traceability is provided for pa.*ts of items within the scope of this plan. However, if the parte d: not provide or contribute to the performance of a nuclear safecy function, traceability will not' i
be provided for those parts unless required by code (s) or regulation (s).
5.2.2.4 The location and method of identification ois11 be specified so as not' to affect the form, fit, function or qualit;r of the item being identified.
5.2.2.5
- Correct identification of materiale, psets and components shall be verified prior to re'r ee for fabr'~atica. chiiravg, installation, and t
a testing.
5.2.2.6 Where physical identif'ca;;on is either impractical or insufficient, physical separation,-procadural control, or other approved means may be employed.
5.2.2.7 A receipt inspection, oren specified by procurement documents,-shall be performed at the site to verify that_ identification for received items is complete and accompanied by specified documentation.
In the case of commercial grade items,: receipt > inspections shall be conducted con-sistent with 5.1.2.4 of this plan.
i 5.2.3 Resoonsibilities 5.2.3.1 Resoonsible Deoartment Mana21I Each Department Managt is responsible for ensuring that; procurement documents contain appropriate requirements for the identification and control of-materials, parts, or components and that only_ materials, parts or components which-have been accepted by QAp are-used.
5.2.3.2 DirecuA.,im lear Assurance The Director-Nuclear Assurance is responsible through'the Director-Quality Assurance for Review of procedures for maint'aining identification in_accordance_
a.
with the requirements of this section.
L.
Verificatiot. of identification during receipt inspection.-
c.
Monitoring and conducting _inspectione, surveillances and audits to verify conformance to the requirement of this.section.
1 5.2.3.3 QJrector-Administration & Finance The Directer-Administration & Finance ~is responsible through1the Director Materials Management for assuring that-correct identification of materials, parts, and components are verified prior to release for i
fabricat Lon, shippicg, installation and testing.
9 48.0-
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g f_
GPUNC OPERATIONAL. QUALITY ASSURANCE Numbst _ _
y PLAN FOR THREE MILE,1SLAND UNIT.1 11000-PLN-7200.01 AND OYSTER CREEK Revision 30.
Title 6.0 CONTROL OF STATION ACTIVITIES 2
6.0 CONTROL OF STATION ACTIVITIES 6.1 General This_section providos; general requirements which are applicable to the-
{
operational, support, and assurance activities which are directly related to-the safo operation,; maintenance _and-modification _of the nuclear station.
-I i
-l 6.2 Control of Inanections-
- 6. 2.'l Recuirements 1
- 6. 2.1.1 A program for performance of inspections of activities within the_tcape of this plan shall be established and executed'by, lor for, the organt-
- ation performing the activity to verify conformance to_the documented' instructions, procedures, specifications and drawings for accomplishing the activity. Design specifications,: drawings, procedures, or instruc-tions shall include the necessary requirements for performance of i
inspections.. These requirements include acceptance criteria and refer-ence to codes,' standards,'and regulatory requirements _and commitments.
These-requirements shall be further: translated _into procedures,pinstruc-tions, or checklists which shall contain, as required,;theffollowings i
Identification of characteristics and activities'to'be inspected.
a.
O b.
Methods to be used including necessary meheuring. and test equip-ment and the accuracy-requirementa.;
-c.
Identification of organization' responsible for. performing the
-t inspection.
-d.
Acceptance and rejection criteria.-
Identification of-required procedures,. drawings and-specifi-e.
catLons,. including the applicable = revisions.
_f.
Documentation of inspection.results including-identification of.
-the individual performing the-inspection.
6.2.1.2 Inspectors (including-NDE personnel) shall be qualified _infaccordance with applicable-codes, standardeLand,CPUN or GPUN accepted qualifi-
! cation programs and their qualification and~ certification shall:be.kept current and' documented.
49.0 3818L (12/88) q
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'I
i Nmier ceune orra^rzon^t ourtITr assuainer number PLAN-FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Pevision No.
7ttle 6.0 CONTROL OF STATION ACTIVITIES 2
6.2.1.3 Individuals performing inspections and/or examinations 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 Assurance organization, the procedures and personnel qualification criteria shall be reviewed and concurred with by the responsible Quality Assurance organization. prior.to the initia-tion 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 individuale not assigned first line supervisory responsibility, are not intended to dilure or replace the clear responsibility of first line supervisors for the quality of work performed under their supervision. When inspections and/or exami-nations associated with normal operations of the plant (such as-routine maintenance, surveillance and tests) are performed by' individuals other-than those whoLperformed or directly supervised the work, but are within the same group (reporting to different supervisors), the following controls shall-be mets The quality of the work will.be demonstrated through a functional a.
test when the activity involves breaching a pressure' retaining item.
l b.
The qualification criteria for the personnel are reviewed and found' acceptable by the Quality Assurance organization prior to initi-ating the inspection.
Inspections 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 Quality Assurance.
l l
b.
Deficiencies identified shall be handled cc.nsistent :with the requirements ci Rection 8.0 of this plan.
c.
Indapendent inspections and/or monitoring _of such cases of main-tenance and inspection shall be conducted'by Quality Assurance.
The frequency and scope of such independent verifications shall be based:on the observed. quality _of the'inspectionc.
6.2.1.4 The Quality Assurance Department-shall establie.a 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.
50.0-
,3818L.(12/88)
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Q gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
i 6.2.1.5 When QA Hold Points have been established, either contractually, by=
procurement, or internally by plant procedures, work may not proceed beyond the Hold Point until either inspection is performed or waived by the responsible Quality Assurance organization.
6.2.1.6 Inspections of modifications, repairs, and replacements shall be by the same method and to the same criteria as the original or by an approved, documented, engineering.and QA alternate. Where verification of inspec-tion is being performed on previously accepted lots,-sampling inspec-tion shall be representative and only to the extent necessary to assure adequacy of control..The sampling-plan shall be determined by Quality ~
Assurance.
Inspection personnel shall be provided with suitable equip-ment and tools, which are calibrated as necessary, and controlled to assure that accuracy requirements are satisfied andLthat inspectione are. complete, j
-j 6.2.1.7 Ir.apection 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'confir-mation of an inspection program.
6.2.2 Resoonsibilities 6.2.2.1 Director-Technical Functions The Director-Technical Functions le responsible for ensuring that-requirements for inspections are included in design specifications, drawinVs, procedures and instructions and that these requirements tnclude acceptance criteria and, as applicable,Ereferences to codes, atandards and regulatory requirements and commitments.
6.2.2.2 Director-Puelear Assurance The Director-Nuclear Assurance, through the Directer-Quality-Assurance, is reeponsible fort Aasuring that inspectors are qualified in accordance with app 11-a.
cable codes, standards, regulatory requirements and commitments, and CPUN or GPUN accepted qualification programs.
b.
Reviewing maintenance and inctallation documents for inclusion-of-inspection and test rsquirements and QA hold and/or witness pointa.
Reviewing and concurring With the personnel qualification criteria of individuale performing inopectior.c, including.those who are not part of the QA orgahization.
51.0 3818L (7/90) 2
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Nmler' oeuac orzaarronit ou^' rr ^ssua^"c=
d=r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 g
AhD OYSTER CREEX
-Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 2
d.
Identification of inspection plans to be used for verification of it.Jpections on previously accepted lote.-
s 6.2.2.3 Resoonsible Denartment Manacer Each responsible Department Manager performing work rcquiring inspec-tions is responsible fort a.
Notifying the QA Department of the work being performed.
b.
Ensuring that maintenance and installation-documents with1" the scope of this plan are, transmitted to QA to provide for the inclusion of' hold and/or: witness points prior to approving such~
-documents for use, Assuring that estab;.1hed-QA-Hold Points are not bypassed without c.
prior QA authorizat.on.
d.
Assuring that all information, records or-copies of records asso-3 clated with their work are made available to QA personnel.
1 Each responsible' Department Manager performing!1nspehtionsIls 4
responsible for Assuring that the personnel performing inspections-are qualified in e.
accordance with applicable codes, standards,. regulatory require-ments and commitments, and GPUN or GPUN accepted qualification program (s),
f.
Assuring that the results of all inspections'are properly docu-mented and the results'are' evaluated by designated personnel.
6.3 CA Monitorino' 6.3.1 Recuiremente 6.3.1.1 A program for QA Monitoring of activities affecting items or processes within.the-scope of this plan shall be estab1!.shed and. executed by thel QA Departrent.
6.3.1.2 Monitoring is used.to establish adequate confidence levels that-activ-ities within the scope of this plan are being performed-in accordance with the QALProgram requirements and plant administrative controls.:
Monitoring will'txa performed on-a' graded approach and the decree 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..
'52.0 3818L (12/88)
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g gf GPUNC OPERATIONAL QUALITY ASSURANCE Numbor PLAN FOR THREE MILE IST.AND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK
' Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES-4 6.3.1.3 Honitors shall'be qualified in accordance with a documented QA Department procedure-that ensures that Monitors-are knowledgeable in.
the activities'they are monitoring to the extent that they can readily verify complianca of the activity being performed.
q 6.3.1.4 Monitoring reports.shall contain as a minimum the followings-a.
Identification of activity being monitored including opecific--
reference to the program or-procedural requirements governing the
-activity.
b.
Indication of complianca, c.
Id? - 'ification 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 ahen such noncon-formances exist and are-identified as a result of the monitoring.
6.3.1.5 Records shall be kept in su'ff'icient detail to-provf.de adequate.docu-l mentation of a monitoring program.
f 6.3.2
-Resoonsibilities l
(
6.3.2.1 Director-Nuclear Assurance.
'The Director-Nuclear Assurance through the Director-Quality Assurance,-
is responsibie fort-j a.
Establishing the requirements for QA monitoring-of'. activities and practices affecting items'or processes within the scope of this i
plan.
b.
Ascuring that QA Monitors are adequately trained and are' qualified to perform'their duties.-
c.
Assuring that adequate awareness;of plant status 18--maintained by-site QA Hanagement through discussions with plant' personnel',-
attendence at status meetings,-etc., to permit the definition of
~
appropriate real-time monitoring activities.
d.
Assuring that reportelof the' monitoring activities have~ sufficient o
details and provide adequate confirmation;of-the monitoring program.
l 53.0 3818L (7/90) l I~
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g gf CPUNC OPERATIONAL QUALITY ASSURANCE Numoor PLAN FOR THREE'HILE ISLAND UNIT 1 1000-PLN-7200.01 1
AND CYSTER CREEK Revision No.
1 Title 6.0 CONTROL OF STATION ACTIVI1(ES
?
6.4 Control of Soecial Processel 6.4.1 Emad rement s 6.4.1 1 Special processeo are those processes that require interim in-process contro..a in addition to final inepection to assure quality.
Such.
processes include,-but are not limited to, weldino, neat treating, chemical cleaning, nondestructive examination, plant chemistry control, and the procescing and preparation for shipment of radioactive wastes.
1 6.4.1.2 Measures shall.be established and cocumented to assure that special processes are accomp12shed under controlled conditions in accordance with applicable codes, standards,_ applications criteria, regulatory requireinents and commitmen -
ind other special requirements includirg the use of qualified personnel and procedures.
6.4.1.3 Procedures for special processesishall be established to meet the requirements of applicable codes, standards, and regulatory require-ments.and commitments or-to meet 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 forithe-control of spec?31 processes shall be reviewed and_ approved by qualified personn'el.
Procedures, equipment, and personnel performing special processes shall be qualified in accordance with applicable codes, standards, and specifications. Organizational responsibilities shall be colineated for the qualification of special processes, equipment and personnel.. Qualification records-of-personnel, equipment, and pro-l_
cedures associated with special; processes shall be established,~ pre-pared and kept-current. For special processes not_ covered by_the exi? ting codes or standards, or_when item quality requirements excee.i-the requirements of established codes or standards,.the:necessary quali-fications of personnel, procedures and equipment shall'be defined in the procedure..
l-6.4.2 Resoonsibilities 6.4.2.1 E5 onsible Deoartment Manacer Each responsible Department Director / Manager perf3rming special processes is responsible fort
) saring that the established program requirements for controlling-a.
r:.i accomplishing special processes are implemented.
).
b.
Assuring that the procedures, including changes,,are reviewed, approved and qual 1*1ed prior to use.
+
c.
Assuring that personnel and equipment used 1n' -the performance of special procetees are qualified.and the records of qualification are maintainedi 4,
3 54.0 1
h i.
_ _ _ _ - - _ _ _ _ _ _l
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[ gf GPUNC OPERATIONAL QUALITY. ASSURANCE-Number PLAN FOk THREE MILE ISLAND UNIT 'l 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
i Title 6.0 CONTROL OF STATION ACTIVITIES 2
6.5 Test control 6.5.1 Reauirements 6.5.1.1 A documented test progeam shall.be established:to assure that all testing required to demonstrate that-the etructures, system, oc com-ponents within the scope of this plan wil) perform satisfaa ar,1y in-servico. The teste shall be perfor. sed in accordance with'writtea, approved,nand' controlled test procedtres or instructions which intor-porate or reference the requirements end AF';; Lance standards cont ained in the applicable design documents. =The setent-of testing shall"be based on the complexity.of the modification, replacement,,or repair.
Testing, including proof testa prior to' installation, hyd;a Lesting, 4
Inservice Testing (IST)-and preoperational tests, necessary-to demonstrate that the installed or modified structures,-systems and-
. j components will perform satisfactorily _in service, shallJbe accom-plished in accordance with written approved procedures or instruc-
-tions.
These procedures'shall be consistent'with'or incorporate _the technical and quality requirements and acceptance limite 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 tne test, including cautionLor safety notes in sufficient datai) to avoid operator interpretation.
Test prerequisiter such as calibrated instrumentation,-adequate:
c.
test equipment and instrumentation including accuracy requirements, l
completeness of item to be tesced, suitable and. controlled-environ-mental conditions, and perconne.V to be-provided to conduct testing _
under the direction of-a~ qualified test supervisor or test engineer.
d.
Provisions for data collection and stotage.
t e.
Acceptance and rejection criteria as specified in design and.
Methods of documentingLor recording test data and results,: in l
eufficient detail to prevent misinterpretation..
g.
Mandatory nold or witness _ points for inspection bylGPON Quality Assurance and/or other designated personnel.
h.
Provisions for control of jumpern, lifted' leads and jurisdictional or safety tags.
55.0 3818L (12/88)
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Nrder oeune orzaarzon^t ouxtzrv ^ssuaxacz "e=ter PLAN FOR THREE MILE. ISLAND UNIT 1 1000-PLN-7200.01 AND OY3TER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACIIVITILS 4
i
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1.
Provisions for returntng a system tv normal honfiguration upon l
completion of the tast, including ve.ificati'an.
- j. Provisions for assuring test prerequisites have been met.
6.5.1.2 Test results shall be documented, evaluated, and their acceptability _
determined by a responsible individual or group.
l 6.5.1.3 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.
Teste during the operational-phase to provide assurance that failures or substandard performance do not remain undetected and that the required. reliability of systems wichin the scope of this plan is maintained.
d.
Tests during activities associated with ptant maintenance.during the operational phase ' and to demtnetrEte sa'.isf actory performanc.e l
following plant maintenance or. procedural changes.
6.5.1.4 Tests performed following plant repairs or replacements shall be
.l conducted in-accordance with the original design and testing. require-
-j
-ments,or approved, docu. tented alternatives. Testing shall be
]
sufficient to confirm that the changes reasonably' produce expected.
{
results and that the change does not' reduce safety of operations.
6.5.2 Responsibilities 6.5.2.1-Directors TMI Unit 1, and Ovster creek 7
The Director of the nuclear generating stations are each' responsible for assuring thatJeesting performed at their-assigned station is performed in accordance with the~requiroments 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-
-maintenarce testing for the work-performed by TMI~ Unit 1 or Oyster sa:ch.
56.0 3818L (1/20).
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{' gf GPUNC OPERATIONAL QUALITY ASSURANCE Numb!r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLH-7200.01 AND OYSTER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
c.
Ensuring that all post-maintenance testing performed by TMI Unit 1 or Oyster Creek is documented and the results accepted prior to operation.
d.
Assuring that operations personnel have the required special training and skille.
e.
Assuring that the test results are documented and are evaluated for acceptability by a responsible individual or group.
f.
Assuring that identified discrepancies are addressed, resolved and reported as required by the Operating License and Technical Speci-fications of the Unit.
6.5.2.2 21 rector-Technical Functions The Director-Technical Functions, through the Director-Startup and Test is responsible to perform a startup and test function to assure new or substantially modified plants, facilities and systems are tested.
These responsibilities shall includes a.
Preparing test plans and implementing procedures, b.
Directing testing and assuring test engineers have the required special training and skills.
Ensuring that test documentation is completed, as required, and c.
reviewed prior to turnover to operations.
d.
Coordinating technical assistance of testing.
6.5.2.3 Director-Site Services The Director-Site Services, through the applicable station Site Services Director, is responsible fort Ensuring supporting persor.nel have the required special training a.
and skills.
b.
Prescribing, performing and/or ensuring the performance of con-struction or post-maintenance testing requirements for the work managed and/or performed by Site Scarvices, Ensuring that all construction or post-maintenance testing c.
including hydrotesting, for the work managed and/or performed by Site Services is documented and the results reviewed and accepted prior to turnover.
57.0 3818L (7/90)
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Q M7 GPUNC OPERATIONAL QUALITY ASSURANCE Number-PLAN FOR THRE0 MILE ISLAND UNIT 1~
- 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
6.6 control of Measurina and Test Eeuioment (M&TE) 1
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- 6. 6.1 -
Reauirements 6.6.1.1 Measures shall be established to control installed and portable equip-ment which are used to conduct measurements or tests related to
~
I determining the functionality or quality of structures,-systems and-
[
components within the scope of this Plan.
Such measuring and test l
equipment typically includes tools, gauges,' meters and other devices.
Such measurements and tests include as a minimum 1those associated with the activities of operation,; maintenance, modification, chemistry, radiological and environmental' controls, nondestructive examination and.
inspection.
Such measures shall ensure that measuring and test equipment are. properly identified and calibrated or adjusted at specified periods to malnuain accuracy within specified111mits.
Measures shall also be-established to ensure that range, type,- accuracy and use of the equipment ecnforms to specified requirements.
4 6.6.1.2 Requirements for each control program shall' include inspection and verificatior.. of accuracy upon-receipt of equipment, identification of all gauges and instruments, calibration and scheduled recall for call--
c bration and traceability tuoDan accepted Standard. 'These' activities shall be subject to.QAD monitoring and auditing.1: Procedures shall be l
established to implement the=following requirements:
I a.
Establish the calibration technique and frequency requirements, maintenance requirements, and controls forLall M&TE which are used-in the measurement, inspection;. and monitoring of components, systems, and structures within.the scope 1of this Plan- (e.g.' instru-ments, tools,-gauges, fixtures, reference andctransfer standards, 1
and' nondestructive examination equipment).-
i b.
The identification of M&TE traceable to the calibration test data.
c.
M&TE requiring calibration:ehall be identified' aid controlled in-cecordance with written, approved procedures to assureithat approved calibrationLintervals are not: exceeded.- M&TE.shall-be clearly' labelled to indicate the date.on which the current call-bration expires.- M&TE that has: exceeded'the approved calibration interval shall'not be used-for measurements or tests 1until its calibration has been re-established.
d.
Establish calibration frequency for.M&TE based on required
' accuracy, purpose,: degree of usage, stability characteristics, and/or any other condition which may affect the measurement.
.A celibration recall system shall be. implemented to assure recali--
oration within the-required period.for each piece of M&TE covered under the-scope of this program.
j 58.T
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'I I
Revision.No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
).
-i Establish methods for determining the validity of previous inspec-l e.
tions 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.
I f.
H&TE used to calibrate instruments and gages (e.g.-flowmeters, transmitters, sensors, pressure gauges,' level. indicators, etc.)
I 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 H&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-lil and the secondary. standards-used to'cali-bratscthe working standards shall have an accuracyJof four times-i greater'than that of the working standards.
When the above raquirements'cannot be met, the-standards used to-calibrate the-H&TE shall-have a precision and_repeatabilitysthat-assures that.the equipment being calibrated.will be:within the l
required tolerance. 'The basis of acceptance will be documented and authorize'd byLthe supervisor of the calibrating organization.
Some M&TE because of.theirfconstruction (suchlas mechanical dial-indicators) or hecause they are not adjustablei(such as' rulers)
'need not be periodically calibrated.. However, their physical condition and where applicable the accuracy shall two routinely checked prior to use.
g.
The calibration status of M&TE whi;h is used for. determining-the-functionality or quality of structures, systems and componente-within.the scope of this Plan shallibe maintained.-
h.
Utilization of reference and transfer standards traceable to nationally recognized standards. Where national standards do not
~
exist, provisions shall 13e established to document the basis for the calibration.
1.
1NDE equipment shall be-controlled and calibrated in accordance with the industry code governing its use.
59.0 3818L (7/90) 1
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I Nrder ovunc or=aarlonxt auxtzrv ^ssuax"c=
uu dor PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.-
Title 6.0 CONTROL OF STATION ACTIVITIES 4
6.6.2 Epsoonsibilities-P 6.6.2.1 Responsible Leoartment Manacer i
Each Department Manager utilizing M&TE in activities,affecting the fune-tion or quality of structures, systems,-components and activities within the scope of this plan sha11' assure that such M&TE is controlled-in accordance with an approved calibration control program which conforms to the requirements of this Plan.
6.7 Handlino. Storace and Shiccina 6.7.1 Recuirements 6.7.1.1 Measures shall'be established and documented to contr:1 handling, stor-age, 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 ship-ping of radioactive wastes are contained in Section 7.0 of this Plan ~.
6.7.1.2 Procedures shall be established to control the cleaning, handling, storage, packaging, and shipping of materials,- componente, 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-lJmised to, the following a.
Packaging and preservation procedures to provide assurancs=of ad'-
quate protection against corrosion, contamination, physical droage or any effect which would' lower the quality lof.the items or.causa deterioration during shipping, handling or storage.
special'protec-tive environments, special coverings, inert gas atmospheres,-
moisture contents, and temperature controls shall be specified:aa
. required and their existence verified and documented.
b.
cleaning methods to provide assurance that necessary cleaning opera-tions are carried;out prior to packaging, storage or installation.
The level of cleanliness required,'and verification'and documenta-tion requirements shall be specified in the procedures.
c.
Detailed handling methode-for all' items that require special hand--
ling.
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 accordance with written procedures at establish;d intervals to ensure their reliability and availability for use.
60.0 3818L.(7/90)
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CPUNC OPERATIONAL _ QUALITY ASSURANCE.
Numb 3r PLAN FOR THREE MILE ISLAND UNIT l' 1000-PLN-7200.01 I
AND OYSTER CREEK-Revlalon No'.
Title 6.0 CONTROL OF STATION ACTIVITIES-4 d.
Storage practices.to provide for methods of storage and the controll of items in storage which will minimize the possibility of damage or deterioration during storage.
Periodic inspections offstorage' nesas'shall be parformed;and= documented to verify' compliance with storage proceoures. Release of items for-installation shall also be procedurally controlled.
e.
Provisions-to assure-thatTproper marking and labeling of items and j
containers is: accomplished to provide-identification and necessary instructions during packaging, shipment and storage.
l
-f.
Provisions for documenting and reporting nonconformance to hand-ling, and shipping requirements.
i g.
Provisions for the storage of chemicals, reagents, lubricants and' l
- other censumable materials which will be ured in conjunction wl.h' i
systems which are within the scope-of this plan.
h.
Provisions for " Limited 1 Life": requirements:(including " Shelf Life" and " Service Life" for applicable materials).
6.7.2 Responsibilities a
l 6.7.2.1 Responsible Decartment Mandoers Each responsible Department Director / Manager is1 responsible for identi-fying in procedures, drawings,. specifications or procurement' documents those handling,: storage-and shipping requirements'necessary-to assure compliance with the< requirements of-this= Plan.
6.7.2.2 Director-Administration and Finance The Director-Administration and Finance, through the Director-Materials' Management, is-responsible. fort-a.
Providing the' procedures for the receiving and-storage of materials, ptrts and components.
i b.
Assuring that the personnel responsible for the' handling and storage'of materials, parts and components are adequately' trained-la the performance of.their duties and that they implement the-nrocedures properly.
c.
Providing adequate storage of items, materials, components, Land parts within the scope of this' plan.
61.0 3818L (7/90):
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GPUNC OPERATIONAL Of!ALITY; ASSURANCE Numb 3r.
PLAN.FOR THREE MILE ISLAND UNIT.1.
1000-PLN-7200.01 AND OYSTER CREEK
\\
Revision-No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
6.7.2.3 Directors TMI Un!t 1,
and ovater 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 performed in accordance with the requirements of-this Plan.
6.7.2.4 Director-Site Services The Director-Site Services is responsible for assuring that the hand-ling, cleaning and storage requirements of this Plan are incorporated in the procedures and are: properly implemented on-all maintenance and modification projects performed by Site Services at the generating stations.
6.8 Insoeetion, Test, and Operatino Status 6.8.1 Secuirements 6.8.1.1 Measures shall be established and documented =to ensure that the required inspections'and tests are performed and that the-acceptability i
of items with regard -to inspection and tests -performed 'is known through-out 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,cdiagrams,-electrical and mechanical jumpers, or other suitable means, to assure-that required inspections and tests are satisfactorily completed to prevent inad-5&rtent bypassing of required-inspections and. tests and=to-prevent inadvertent operation.
6.8.1.2 The requirements for an acceptable inspection,Ltest.and operating status program for structures, systems, and1 components throughout fabrication, installation, test and operation include -
Design and quality documents which address the requirements for the a.
identification of inspe; tion,-test, and operating status _of struc -
turea,Erystems and components.
b.
Procedures which include-c)ntrols for the application and removal of inspection and welding stamps, and~other status indicators such as tags,-jumpers,-markings, labels, and stamps.
- i 62.0-
=3818L-(7/90)-
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GPUNC OPERATIONAL-QUALITY ASSURANCE' Numbst' PLAN FOR THREE MILE!!SLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK' Revision
'o.
j Title 6.0 CONTROL OF STATION ACTIVITIES 2
l c.-
Procedures for controllingLthe bypassing er altering of the-sequwnce of required inspections, tests or other-critical opera-tions are procedurally controlled.with ccncurrence by_the Quality'
-Assurance organization. yThe' procedures shall provide for: the identification of items which have satisf actorily' passed such.
' +
inspections and tests,-where necessary-to preclude inadvertent bypassing of required inspection and tests.
I d.
In cases where' documentary _ evidence is not available_to confirm that an item has passed required inspections-and tests,Lthat item i
shall be considered nonconforming until'such evidence becomes available. LAffected systems shal~1:also be. considered to be inoper-
- nble and reliance shall not.beJplaced on such systems to fulfill their intended safety functionse e.
Procedures requiring identification of the operating status of systems', components, controls,_or support equipment in' order to i
prevent inadvertent or unauthorized operation.
These procedures shall require control measures 1such as locking or-tagging =to' secure' and identify equipment'in a controlled _ status. ' Independent verifi -
cation shall be required, where appropriate, to ensure that]
necessary measures, such as tagging: equipment, have been-imple-
-mented correctly, f.
Methods which ensure temporary modificationsfvariations shall be controlled by approved _ procedures which include a requirement'for independent verification. A log shallsbe maintained of the current status-of such temporary' modifications / variations.
g.
Methods which ensure that nonconforming servicesLand inoperative or malfunctioning structures,_ systema, components or materials shall-be identified in accordance with the' requirements of,this Plan.
6.8.2 Responsibilities 6.8.2.1
.ectors TMI Unit 1.
and Ovster Creek.
The Directors of the nuclear generating-stations <are each' responsible for assuring-that the appropriate. requirements for controlling 7the inspection, test and operating status, including independent 1 veri *i-l-
uation, are incorporated in-the-procedures used-on all' fabrications, installation, test and operation activities. performed at their respective stations.
63.0 3818L (12/88) j 4
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gf CPUNC OPERATIONAL QUALITY AF"URANCE Numb;r l
PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 1
AND OiSTER CREEK i
Reviolon No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
6.9 Hagpekeepina and cleanliness 6.9.1 Recuirements 6.9.1.1 cood 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.
6.9.1.2 Housekeeping encompasses all activities related to the control of clean-lineen of facilities, materials and equipment; fire prevention and protection including disposal of combustible material and debrie; control of access to areas, protection of equipment, rsdioactive con-tamination control; and, storage of eclid radioactive waste.
(.9.1.3 Housekooping practices shall aneure that only proper materials, equip-ment, processee, and procedures are utilized and that the quclity of the item is not degraded as a result of housekeeping practices or techniques.
During maintenance activities, certain portions of safety-related systems or componente may be subject to potential contamination with foreign materials.
To prevent such contamination, control measures, including measures for access control, and tool account-ability shall be established. Additionally, immediately prior to c!rcure of system (s) or component (s), an inspection shall be conducted and documented to ensure cleanliness.
Special housekeeping consi-dorations shall be made for maintenance of radicactively contaminated systems and components.
6.9.2 Responsibilities 6.9.2.1 Directore TMI Unit 1, and oyster creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining programs and practices for house-keeping and cleanliness control of all work activities performed by the plant site staff, supporc organizations and contractors in accordance with the requirements of the GPUN QA Program.
6.9.2.2 Director-Site Services The Director-Site tervices through the site Site Services Directors le responsible to implement housekeeping and cleanlinese control plans, procedures, instructions or practicos associated with all work activ-ities performed by MCF personnel and contractors.
4 64.0 j
3818L (7/90) l l
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Q gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r-PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND 0.' STER CREEK
. Revision No.=
Title 6.0 CONTROL OF STATION ACTIVITIES 4-6.9.2.3 Director-Nuclear Aesurance-The Director-Nuclear Assurance, through the Director-Quality Assurance -
is responsible for monitoring the ho sekeeping and cleanliness practices at-the nuclear generating stations.
6.10 Eaulement Control 6.10.1 Recuirements 4.10.1.1 Authorization to remove plant installed operational equipment or systems from service, for maintenance or modification, shall be granted by the on-duty Shift Supervisor.
6.10.1.2 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 with-out specific advanced approval by the designated Operations management personnel in each instance. The procedures for controlling the removal from service and the reture to service of equipment shall requires a.
Control measures ?.uch as locking or tagging.to secure and identify equipment in a c',ntrolled 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 func-tional test which-conclusively proves the proper installation and subsequent removal of the temporary modification. A log or equi-valent documented evidence shall'be maintained of tha current status of such temporary modifications which are-installed.
D 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.
t l
e.
When equipment is ready to be returned =to service, operating
. personnel shall place the equipment in operation and verify and document its functional acceptability.
l
- f. - The equipment shall be adequately identified on the documentation to assure traceability.
65.0 3818L (7/90)-
(I-U1Nader cru"c orra^Tronit euxtITv assuainer ummber PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 2
6.10.2 Fesponsibilities 6.10.2.1 Directore TMI Unit 1.
and ovetor Cregh 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 propor implementation.
6.11 Control of Construction, Maintenance (Preventive / Corrective) and Modifications 6.11.1 Feau ire.nent s 6.11.1.1 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 laaet equivalent to that specified in the original design basis and requirements, materials specifications and inspection requiremnnte.
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.
Construc-tion, maintenance or modification of equipment shall be pre-planned and performed in accordance with written procedures, instructions or drawings appropriate to the circumstances which conforn to applicable codes, standards, specifications, and criteria.
In this regard, modifi-cation type work in areas and systems of the 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 Diiector or designee (s).
6.11.1.2 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 valvo packing may not require written procedures.
Whereas, work involving inter-departmental coordination or risk of nuclear or personnel safety requires a higher level of administrative control such as approved procedures and sign offs to properly coordinate, direct and document the activity.
i 66.0 3818L (12/88)
~
I g gf GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 3 1000-PLN-7200.01.
AND OYSTER CREEK-
-Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 2
l 6.11.1.3 Skills normally possessed by-qualified maintenance personnel may not-
~
require detailed step-by-step delineations in a written procedure but 1
are subject to general administrative procedural controls that govern
)
or define the following areast a.
Methods.for obtaining permission and clearance from Operation personnel to work and for logging such work.'
b.
Factors to be tahen-into account, including the necessity of main-taining occupational radiation exposure as low as is reasonably _
achievabic (ALARA)..
c.
Method for identification of what procedural-ccverage is necessary for the maintenance, construction and. modification activity.
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 maintenance,-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.
6.11.1.4 Means-(for example, inspections, measurements, tests,. welding,' heat.
treatment, cleaning, nondestructive examination'and worker qualifi-cations in accordance with applicable codes and standards) for assuring quality of maintenance, modifications or construction activities and-measures to document the performance thereof-shall be established.
Measures shall be established and documented to:1dentify the inspection and test status of iteras: to be used in maintenance, modification, and construction activities.
6.11.1.5 A corrective maintenance program shall be developed-to maintain:
structures, systems and components within the scope of this plan at.the quality required for them'to perform-their intended' functions.
Corrective maintenance shall be: performed in a timely manner -to ensure that items within the scope of this plan are adequately maintained 'in the original, as designed, functional status.
6.~11.1.C A preventive maintenance program including procedures as appropriate for structures, _ systems, and components within the scope of this' plan i
ahall be established which prescribes the frequency and type of main-tenanco to be performed.
In all cases, maintenance shall be scheduled j
r.nd planned so as not to compromise the safety-of the plant.. Planning j
shall consider the possible safety consequences of concurrent or 67.0 3818L (12/88)
[ gf GPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN FOR THREE MILE ISLAND UNIT 1.
1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES
'4 sequential maintenance, 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 maintained in the original, as designed, functional status.
6.11.1.7 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 revie wed and accepted in accordance with the requirements =of Section 2.8 of this Plan.
6.11.1.8 Design, procurement, construction, testing _and inspectionLof all modifi-cations shall be performed in accordance.with the applicable portions of this Plan.-
6.11.1.9 Upon completion of the design phase of a modification, Technical Functions turns the project over to site Ser, vices for installation of the modification with an engineering document package.
Procurement of the required materials, parts and components is generally initiated by-Technical Functions, but may be initiated by'other organizations as necessary.
Site Services prepares the necessary-instellation procedures or instructions consistent with the engineering requirements, completes the installation and construction testing and compiles the records which it_ generated for record retention._ Engineering problems identified during installation shall be identified to Technical Functions for resolution using the appropriate documentation as identified in the implementing procedures.
Site Services shall notify Quality Assurance and, where applicable, the Authorized Inspection
-Agency of all-witness and hold points in sufficient time for per-formance of the inspection. Witness and. hold points may be waived only-with prior written authorization from the;QA Departmen?..
6.11.2-Resoonsibilities 6.11.2.1 Directors TMI Unit 1.
and Oveter creek The Directors of the nuclear generating stations are each responsible fort a.
Establishing procedures for preventative and corrective maintenance.
consistent with the GPUN organization and maintenance plana.
b.
Ensuring that maintenance and modification activities are performed in accordance with the requirements of this Plan and the-applicable Operating License and Technical Specifications.
68.0 3818L (7/90)
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.. =. - -....
Q gf CPUNC OPERATIONAL ~ QUALITY ASSURANCE.
Numbor PLAN-FOR THREE MILE ISLAND-UNIT 1 1000-PLN-7200.01, AND OYSTER CREEK Revision No.'
Title 6.0 CONTROL OF STATION ACTIVITIE 4
Planning, scheduling, performing,Ldirecting and documenting main-c.
tenance consistent with the CPUN organLzation and maintenance plans.'
d.
Establishing administrative control' procedures for modification: work consistent with the CPUN organization plan.
6.11.2.2 Director-Technical Functigng The Director-Technical Functions is responsible-fors-a.
Reviewing and approving the procedures which define the_ scope and limits of responsibilities of plant engineering with regards.to modifications.
}
b.
Ensuring that design and procurement activities associated with plant:
modifications are implemented in accordance with approved-procedures, c.
Controlling.the. drawings and. specifications used for plant modifications, d.
Preparing and issuing.as-built drawings of1 plant modifications, as appropriate.
i e.
Ensuring that modifications are designed,. procured and installed in-accordance with. requirements;which are either equal-to or:better than the original requirements.-
f.
Preparing and filing: design,Eengineering and-Technical 1 Functions' initiated procurement records in.accordance-with~the QA Records' requirements of this Plan.
g.
Providing the design'and~ engineering supportEduring installation and.
testing of plant modifications; including _the resolution.of engineering.
problems-identified during installation.-
I h.' Maintaining control; of : technical' configuration-of the plants and' maintaining the associated-drawings: current.
6.11.2.3 Director-Site Services The Director-Site Services,)through the applicable station 1 Site Services
~
Director, is responsible fort, t
a.
Planning, scheduling, performing, directing and documenting construction, modification and maintenance consistent with the 0 PUN Organization and maintenance plans, b.
Providing the supervision and labor necessary,to complete the assigned work.
69.0
,3818L (7/90)
=- -
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g gf OPUNC OPERATIONAL QUALITY ASSURANCE #
Number.-
PLAN FOR-THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK-Revision No.
Title 6.0 CONTROL OF STATION ACTIVITIES 4
c.
Ensuring that' installation of a modification!is' implemented in conformance with engineering requirements.
Deviations from'engi-neering requirements are not authorized except as specifically-1 approved by engineering in advance.
QA review for concurrence is also required in advance if-the deviation affects the inspect-ability or planned inspections of the installation (s) affected.
d.
Providing Technical Functions with the infor.iation necessary to prepare and issue as-built draxings.
e.
Preparing and filing installation. records in accordance with the QA Records require;nents of. this Plan.
f 6.11.2.4 Director-Nuclear Assurgngg The Director-Nuclear Assurance, through the Director-Quality Assurance, is responsible fore a.
Reviewing installation and maintenance procedures or equivalent work authorizing documents to provide for the assignment of QA hold and/or witness points to selected documents.
b.
Performing inspections and/or examinations required for the com--
pletion and acceptance of_the installation.
Verify the appropriateness of qualit y requirements in f abrication c.
and installstion specifications.
6.12 control of Surveillance Testina and Insoection 6.12.1 Reauirements 6.12.1.1 A surveillance testing and inspection program shall_be established and implemented in accordance with the Operating License and Technical Specification requirements of the plant to ensure-thatistructures,_
systems,- and components within the scope of _this plan will continue to operate, keeping parameters.within normal bounds, or__will act to put the plant in a safe condition ifithey exceed normal bounds.
6.12.1.2 Provisions chall be made for performing required surveillance testing and inspections, including inservice inspections..Such" provisions-shall include the establishment of a Technical Specifications sur-.
veillance testing-schedule reflecting the status of all planned 1nplant=
~
surveillance tests and inspections.
Frequency of surveillance. tests and' inspections may be related to the resultsLof reliability analyses, the frequency and type of. service, or ' age of the item or system,- as appropriate.
70.0 l
3818L (7/90)
I l-1' l
l l
U M f-GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN-FOR THREE MILE ISLAND UNIT 1.
-1000-PLN-7200.01 AND OYSTER CREEK-Revision No.
Title 6.0. CONTROL CF. STATION ACTIVITIES.:
1 6.12.1.3 Additional control procedures.shall be instituted, as.t.ecessary, to assure timely conduct of surveillancr tests and inspections and appro-s priate documentation, reporting,;and evaluation of the results.
Procedures shall be. established--to assure proper review of surveillance.
test data-andLthe-return of systems to an-operable status followings the-completion of testing.
These procedures shall include provisions for the documentation of authority, conduct, responsibility, and verification involved in returning the system:toLan 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.-
6.12.2 Responsibilities 6.12.2.1 Directors TMI Unit 1.
and Oveter Creek The Directors of the nuclear generating stations are eachJrespc dible 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 - Sitrveillance. Testing 'and Inspection ara completed as required.
6.13 Eadioloaical control 6.13.1-Reauirements 6.13.1.1 A radiologicalLcontrole program shallLbe established:and implemented at' each station,tos-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 regulatoryfrequirements.
d.
Provide guidance and Jpecify' appropriate methods or_ techniques to ensure that the performance =of. activities are in accordance with-sound radiological' control principles and in compliance with applicable regulatory requirements.
6.13.1.2 The radiological controls program-is to:be fully integrated into the:
applicablo activities of'each and every phaseLof operations at the nuclear generating stations.=
71.0 3818L
-l J
[ gf :
GPUNC' OPERATIONAL QUALITY ASSURANCE
-Number PLAN FOR THREE MILE ISLAND UNIT 1 -
1000-PLN 'i 200.01 AND OYSTER' CREEK-Revision No.-
Title 6.0 CONTROL OF STATION ACTIVITIES 1
l 6.13.1.3 Procedures shall be provided for the implementation of the radiological f
controle program.
These procedures shall contain the requirements for implementation of the program by the Radiological Cont"ols Department and the requirements for inclusion of radiological cont.ols in the-plant operation, maintenance and testing procedures.
6.13.1.4 The radiological controle program includes the acquisition of data and provision of equipment to perform necessary radiation surveys, measure-ments and evaluations for assessment and control of. radiation conditions..
6.-13.2 Responsibilities 6.13.2.1 Division Directors Each Division Director is responsible. for' assuring that the rt {uire-men *e of the radiological controle program as applicable to freir activities are adequately included'in procedures and that the proce-dures are implemented properly.
6.13.2.2 Director-Rad (plocical & Environmental Controls the Director-Radiological & Environmental controle is= responsible fort Establishing and maintaining the radiological controle program.
a.
b.
Providing the personnel, procedures and administrative-controls to implement the radiological controls program, Providing administrative and technical guidance. applicable to c.
radiological controls, radioactive materials, respiratory protec-tion and radiological enginuoring including ALARA programs-and dosimetry control.
1 72.0 3818L i
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-CPUNC OPERATIONAL-QUALITY ASSURANCE Numbar.
- PLAN FOR THREE HILE. ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 7.0 CONTROL OF RADIOACTIVE WASTE
- 2 1
7.0 CONTROL OF RADIOACTIVE WASTE 7.1 General 7.1.1 Heasures shall be established and documented'to assure that the require-ments of the Code of Federal Regulations, Title 10, Part 71,-Title 10,'
Part 20, and Title 49, Parts 100;through 199 applicable to the-pack-
- aging and transporting of radioactive wastes are satisfied.-
7.1.2 Subpart H.to 10 CFR-71 identifies the quality. assurance. criteria appli--
_ l cable to the control of radioactive, waste. - The portions of this Plan that relate to the criteria in subpart H to 10 CFR.71 describe to a large extent the administrative controls and quality requirements _to be-applied in the control, packaging and transportation of radioactive material.
A comparison of the requirements of 10 CPR 71, Subpart H and the applicable sections of this Plan are111sted_in Appendix A.
These sections of this Plan will be implemented to satisfy the! requirements.
of Subpart H'to 10 CFR 71.
q 7.1.3 It is the policy of GPUN to minimize-the generation of radwaste materials 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 be11mple-mented to verify compliance with Title 10, Part 61'.55 (Waste Classifi-cation) 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 Recuiremente 7.2.1-Procedures and administrative control 3:shall be developed and implemented to cover the following l.
a.-
Processing of radioactive wastes including the collection, handling and preparation for shipment of radioactive'liquide and solids.
These procedures shall be_ consistent =with-the:ALARA program and shall clearly identify the administrative controis and.organi-zational responsibilities.
b.
Training and qualification of personnel operating radioactive waste
. processing equipment,_ health physics' monitoring,; packaging and shipping (which includes Waste classification and establishment:of-Waste characteristics) and other operations-deemed appropriate by management.
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{ gf CPUNC OPERATIONAL QUALITY ASSURANCE
~ Number' I
PLAN FOR THREE MILE-ISLAND UNIT.1 1000-PLN-7200.01
$FD OYSTER CREEK
' Revision No.
Title 7.0 CONTROL OF RADIOACTIVE WASTE
-4' c.
The activities associated with the packaging of radioactive wastes 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,-Radio-1 logical control inspections of_the packaging prior to release, proper markings on the outside of the package and the preparation of shipping papers and certificates.
The activities shall be in accordance with 10CFR20, 10CFR61, 10CFR71, and 49CFR.
- i i
d.
Movement of radioactive materials within and outside the protected area to assure personnel protection at all times.
e.
The shipment of radioactive material from.the Station to be.in_
accordance with the regulations of the U.S.. Department of Trans-portation for the transportation of hazardous materials (49CFR) and of toe NRC (10CFR71-and 10CFR20),
t f.
The packaging used for transporting.of radioactive _ wastes, whether purchased from an outside supplier.or designed by.OPUN, shall m6et the applicable requirements of 10CFR20,' 10CFR71 and!49CFR..
g.
Minimization of the generation of radwaste materials through 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 wastes shall be selected on the basic of their. experience, knowledge of DOT regula-tions, control and maintenance. of their_ equipment and the selection and control of their drivers.- The carrier is required to have or shall be supplied documented procedures covering acceptance of materials from a shipper, certification requirements, placarding, storage _ control, reporting of incidents and security.
7.2.3 Radwaste operations shall be controlled to minimize _ personnel _ exposures or environmental contamination consistent with.ALARA.
7.2.4 Operations procedures relating to radwaste shipping and packaging shall be reviewed by_QAD to establish any necessary witness or hold points or activities to be monitored.-
7.3 Responsibilit ies 7.3.1 Directors TMI Unit 1, and Oveter Creek The Directors of the nuclear generating stations, thru their.on-site staffe shall develop and implement procedures for: minimizing the' genera-tion of radwaste materials and the processing of radioactive waste,and movement of radioactive materials.
Thess procedures shall include the following:
o 3680L (7/90) 74.0
.3-
.2.
h gf CPUNC CPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE-MILE ISLAND UNIT 1 1000-PLN-7300.01 AND OYSTER' CREEK Revision No.-
Title 7.0 CONTROL OF RADIOACTIVE WASTE 4-f a.
Training of personnel in the methods to minimize the generation'of radwaste materials, b.
Processing and packaging of liquid and solid wastes.
c.
Collection and identification of radioactive solids such as rage, papers, boots, gloves, etc. and have them moved to the Radwaste facility for packaging.
d.
Selection of the proper packaging for the specific contents to be.
shipped, taking into censideration the radiation, levels, contami--
nation limits and shipping requirements.
Radiological 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 papers / manifests-and certificates, attaches the security seal and advises the carrier that the shipment is ready.
Review and acceptance of carrier procedures specified by.the e.
procurement documents covering the acceptance of radioactive-waste materials for shipment.
f.
Review and acceptance of the designs of packaging purchased from-an outside supplier.
7.3.2 Director-Nuclear Assurgngs The Director-Nuclear Assurance is responsible-through the Director -
Radiological & Environmental Controis 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 and-shipping.
The Director-Nuclear Assurance is responsible throughLthe Director Quality Assurance to monitor,= inspect-and audit radioactive waste processing operations and racioactive material packaging anc shipping-to the extent necessary to verify tr.?v are. performed in accardance with established procedures, applicable admir.istrative controls.and regulatory requirements.
7.3.3 Resoonsible Decartment Mana.ggra Each manager shall-establish the requirements for personnel qualifi-cation and institute training and-indoctrination to;aatisfy these, requirements.
Training requirements shall be commensurate with-the importance and complexity of the activity performed.
3688L (7/90) 75.0
[ gf GPUNC OPERATIONAL QUALITY ASSURANCE Numbsr PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 8.0 Control of Corrective-Actions and Nonconformances 2
l 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 General 8.1.1 Nonconforming materials, parts, components, services or activities within the scope of the CPUN Quality Assurance Program shall be iden-tified and controlled to prevent their inadvertent utilization.
Heasures shall be established which ensure that conditions adverse to-i quality, such as failures,' malfunctions, deficiencies,' deviations,;
defective material and equipment, and nonconformances'are promptly iden-i tified and corrected. The causeaof significant conditions adverse _to quality shall be determined and appropriate action._taken to provent H
recurrence. The identification, cause, and actions taken to correct significant conditions adverse to quality shall be documented and reported to the appropriate levels of management.
8.1.2 Significant conditions within the intent of 10 CFR 21 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 typi-cally those which are isolated to. singular occurrences,_not repetitive in nature,- and/or are such that appropriate action to prevent' recur-rence 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 8.2.8.-
8.2 Reau irement s 8.2.1 Nonconformances include both. hardware-problems involving materials, parts, components or _ systems which do not complyL with established requirements and-non-hardware problems such as failure to-comply.with-the operating License-and Technical Specifications, procedures, requ-L 1
lations and/or'other established requirements.
8.2.2 It is the responsibility'of'alll organizations and individuals involved with the THI-l 'and. Oyster Creek Nuclear Stations to identify; and report 1
all nonconformances that affect structures,. systems, equipment,_
materials, parts:and components within the scope of-this plan.
These nonconformances may be of a' minor nature as a result of work activ-ities, inspections, monitoring =or reviews; or-of a major 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.
76.0 3898L (12/88)
..m
' h g f" l CPUNC OPERATIONAL QUALITY ASSURANCE Numb 2r-PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK l
Revision No.-
Title 8.0 Control of-Corrective Actions and Nonconformances 2
1 i
8.2.3 Activities such as examinations or checks performed to assess the l
condition of equipment-or its. operation are not considered to be non-conformances until it has been determined that it does not comply with I
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 inad-vertent use prior to correction.
8.2.4 Procedures shall be established which detail and-implement 1the j
'following corrective-action system measures 1
a.
Conditions adverse to quality shall-be. evaluated'to determine the i
need for corrective action.
b.
Ccerective action documentation of significant deficiencies shall include identification, cause, -and actions -taken: to correct and to preclude the similar recurrence. -QAD concurrence is required'for corrective action disposition for all QAD' identified nonconformances.
c.
Follow-up activities shall be conducted to verify implementation of corrective actions-and to close out. corrective actions in a timely
- manner, d.
Significant' deficiencies, nonconformances and defects which are' potentially report ble to the NRC shall be. identified to appro-priate managemer.'c levels;for evaluation and reporting to the NRC, as appropriate.-
8.2.5 Procedures shall be established.which detail and implement'the require-ments for identification and control of nonconforming-items and activ-ities and for the identification-of' tie causerof theJconditions and the-actions to be taken to correct the c:aditions to prevent' recurrence.
These procedures shall includa requirements for the followings a.
Idontification of the form.to be:used for reporting the nonconformance.
i 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<(tage,-
labels, etc.) and segregation, if practical, until'dispositioniof the nonconforming item has been determined.
77.0 3898L (12/88)
.z.,
Nuder ovune orraarzonat ount2xr ^=suaxac=
a==bor PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Title 8.0 Control of Corrective Actions and Nonconformances 4
f.
Disposition of nonconformance.
The disposition shall be determined-by the organitation responsible for the nonconformance.- Rework and scrap dispositions are made by-the material user without engi-neering review;-use-as-is and repair dispositions require con-currence and justification of cognizant engineering organizations.-
QA concurrence is required for all dispositions..
i g.
Notification to the affected organizations of the-nonconformance.
h.
Verification method,, verification and close out.
1.
Record retention.
- j. Required approval signatures of:the disposition'and the verification.-
k.
Evidence of review for reportability to'the NRC.
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 Quality Assurance. All inspection,1 testing, rework, and repairs shall be controlled by approved procedures-and the reoults documented..
8.2.7 Prior to the initiation of a'preoperationalJtest on a-safety related item all nonconformances shall be evaluated for significance or-impact on further testing or operation and shall be'dispositioned-as appro-priate. The evaluation / disposition shall be documented.
B.2.8 Nonconformance reports and those deficiencies addressed in 8.1.3 shall be periodically analyzed to detect adverse trends a:s maylbe present.
Such analysis-will be based upon severity, nunter, frequency.of non-l conformances, the causes of the nonconformances and.the timeliness-of i
the reporting and resolution of nonconformances..The results of analyses shall be periodically reported to management for review and 1
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 dis-1 position nonconformances, these problems.shall be elevated.to upper levels of management-for resolution.
8.3 Reewuilbilities 8.3.1 Director-Nuclear Assurance The Director-Nuclear Assurance through the Director-Quality Assurance is responsible for the followings a.
Review and concurrence of all procedures for reporting and con-trolling of nonconformances for compliance with the' requirements of this Plan.
78.0 l
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i h
gy GPUNC OPERATIONAL' QUALITY' ASSURANCE' Numb 2r.
~
I PLAN-FOR THREE MILE ISLAND UNIT 1-1000-PLN-7200.01 AND OYSTER CREEK Revision-No.
Title 8.0 Control of_ Corrective Actions'and Nonconformances 2
[
8.3.2 Director TMI Unit 1 and oyster creek; 1
The Directors THI Unit 1 and OCNCS are each respons'ible for ensuring.
that-nonconformances are reportedJand-corrected; tor'all activities.
within the scope of this plan.
Plant items such as failures, malfunc-tions,-deticiencies, 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.
8.3.3.
Responsible Department Manacer 8.3.3.1 Each Director / Manager is responsible..for the disposition and corrective.
action of nonconformances identified as within the scope-of:his-respons '
ibilities,- In the'epecific_ case of materials, parts,. components, or systems which have not been installedLor accepted as operational-at the Station, the responsible Director / Manager approves.'and the Quality Assurance Department ~ concurs with.the disposition of-nonconformances.
8.3.3.2 Each Director / Manager is responsible for ensuring that nonconforming conditions are identified and controlled.in accordance~with approved procedures.
5 i
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79.0 3
3898L (12/88) 1
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Q gf GPUNC OPERATIONAL QUALITY ASSURANCE Numbar-PLAN!FOR THREE HILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Titles 9.0 CONTROL OF TRAINING 2
9.0 QQNTROL OF TRAINING 9.1 General GPU Nuclear is committed to_the safe. operation of_its nuclear generating stations and the protection of the public health and eafety.
This commitment is accomplished, in parc, by developing or maintaining the 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 developingiand 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 ba based on training need assessment.
The extent to which prior education, training and experience is sufficient toiprovide for the requisite job proficiercy will be considered in deciding whether and what' training will be provided for an. individual. -The:
content of the training provided shall be consistent with. regulatory-requirements and commitments.
9.2 Reauirements 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 Wo keri 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, Abut _the implementation and conduct of training will.be based upon behavioral learning objectives which are linked to job performance-requirements.
i 9.2.3 The documents associated with.the: training programs accredited by.INPO and the. Radiation Worker, Respiratory Protection, Emergency _
t Preparedness, Fire Brigade, _and Security Force Training-Programs shall
_1 be' reviewed, concurred with, and' approved in accordance with the Training Management _ Control Documentation-System procedure to assure that related: regulatory, management,utechnical, and functional
. requirements and. commitments are incorporated.
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y gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r.
PLAN FOR THREE~ MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
3 Titlee 9.0 CONTROL OF TRAINING 4
9.2.4 Technical conter.t review and interface process shall be established between the user department.and the Training and Education Department to aseure programs accredited by INPO and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security Force Training Programs are updated to reflect' job performance, plant modifications, procedure changes, regulation changes, and job scope changes.
9.2.5 The review and approval of the specific training program documents developed and/or implemented by organizations, including contractors 3 and/or vendors, other than Training and Education Department shall.be-delineated in procedure (s) or plan (s).'
The extent of_ Training and, Education review of such training shall be as-defined by a' procedure (s) or plan (e).
)
9.2.6 Procedures shall be established for the qualification and certification'
~
of instructors for programe accredited by INPO and the Radiation Worker, Respiratory Protection,. Emergency Preparedness, Fire Brigade, and Security Force Training Programs.
9.2.7 To assure the integrity of qualification processes which utilize examinatione, procedures for the control of examinatione shall be-used to addrese examination security.-
9.2.8 A program and course evaluation process (e) shall'be used to evaluate' the effectiveness of. training programs and_coursesJin meeting training 1 objectives and in improving job performance.'. Such a process (s) and the extent of ite_ 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 PlanLshall be identified,-generated, maintained,_and retrievable. -These training recorde shall.be. sufficient"to provide evidence of the-content and-objective of the training provided, attendees, :and date of attendance.
9.3 Egeoonsibilities 9.3.1 The Director, Nuclear Assurance is-responsible through the-Training-and Education Director for providing selected.trainingLto CPU-Nuclear and specified contractor personnel as necessary to= prepare them to carry out their assigned duties andLto meet corporats policies, applicable laws, regulations, licenses, and technical requirements.- Specifically, the Traini.ng and Education Director, shall be responsible for the establishment and maintenance of a' training organization tos-4162L (7/90) 81.0
g gge.
CPUNC OPERATIONAL QUALITY ASSURANCE
~ NEmbhr j
PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01
^
AND OYSTER CREEK Revision No.
I
Title:
9.0 CONTROL OF TRAINING 2
, i a.
Manage the training function consistent with regulatory. requirements-and commitments, corporate priorities, and the-Training and Education; Department TSD Process.
b.
Provide personnel with training which supports the development and maintenance of knowledge and skills required to perform activities within the scope of this Plan in a manner that will ensure the safe and effective execution of_their duties.
c.
Assure that the content of training provided-by the Training
.i Department is consistent with and incorporates': appropriate GPUN, local, state and: federal regulatory requirements'and commitments, including timely.requalification.
i 9.3.2 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 consistent with the requirements of-this-section'of.
this Plan.
l 1
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h gf CPUNC OPERATIONAL QUALITY ASSURANCE-Number-PLAN FOR.THREE MILE ISLAND UNIT 1
=1000-PLN-7200.01:
AND OYSTER CREEK Revision No.
Titles 10.0 AUDITS 2-10.0 AUDITS
}
10.1 ceneral A comprehensive and docunented audit system shall be established, implemented and maintained'to ensure that a.
Plans, procedures and instructions define sufficient organizational a
responsibilities, prescribe' methods _and provide results consistent.
O with~ operating License requirements, other regulatory requirements and commitments, technical requirements, contractualrequirements, and this Plan.-
b.
Plans,' procedures and instructionsz are effectively implemented.
c.
Corrective action systems and'managementfreviews provide for timelyE completion of. requisite action for identified deficiencies /
nonconformances/ occurrences / events.
t d.
Corrective action-systems and management 4 reviews-provide effective identification and provention of. recurrent;and/or significant program nonconformances.
e.
Data is provided'for GPUN management to optimize the efficiency of methods utilized to ensure regulatory compliance..
f.
Data is-provided'for the continuing assessment of>:theJeffectiveness of all elements of the CPUN Quality Assurance Plan and'implementingl i
documents.
10.2 Recuirements 10.2.1
. A comprehensive system of audits shal'1.txa established :and conducted for both internal and external activities which are within'the scope of this Plan, 10.2.2 Planned and scheduled audits shall verify compliance with the.
following:
-1 a.- operating License conditions, Technical Specification requirements, other regulatory requirements andLcommitments1and the requirements of-this Plan.
i b.
. Regulatory _Gul. des, ANSI Standards, and.othericodes and standards as Kendorsed by Appendix C of this Plan or:other regulatory requirements or commitments.
j 3899L (12/88) 83.0 1
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l AND OYSTER CREEK j
Revision No.
Title 10.0 AUDITS 2
)
c.
Documents which prescribe methods and provide the technical requirements for activities or items within the scope of this Plan.
d.
Contractural requirements associated with external organizations providing nuclear fuel, in-core components and selected technical support and engineering services within the scope of this Plan.
10.2.3 The audit system shall includes Delineation of the authority, responsibility, and organizational a.
independence of those responsible for the management and conduct of audit program.
t.
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.
" allow-up action to be taken based upon individual and collective c.
audit results.
10.2.4 The frequency of conducting scheduled internal audits shall be as specified in the nuclear units' Technical Specifications.
Unscheduled audits may be conducted at any time.
Re-audits shall be scheduled as may be required to assure that corrective action (s) to previous audit results has been effectively implemented.
10.2.5 The frequency of conducting external audits of selected suppliers of technical support, environmental monitoring, radwaste chipping, computer, radioanalytical, and engineering services chall be scheduled once within the life of the activity or every three years depending on the duration of the contractual relationship.
10.2.6 Each audit shall be led by a GPUN certified lead auditor. Audit team members shall be utilized as required and will be classified as either auditors or technical specialists, depending en their function on the audit team.
10.2.7 Those GPUN and external organizations providing items and/or conducting acti'eities within the scope of this Plan are subject to audit consistent with the requirements of this Plan.
3899L (12/88) 84.0
Q gf GPUNC OPERATIONAL QUALITY ASSURANCE Numbar-PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Revision No.
Titles 10.0 AUDITS 4
1 10.2 8 Audits 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.-
10.2.9 Audits shall consist.of reviews of approved documents and records and observation (s) of selected activities in-sufficient detail to determine l
the appropriateness of the documents for use, effectiveness of-implementation and the effectiveness of actions taken to correct previous nonconformances.
10.2.10 Audited organizations shall provide sufficient support to. assure the accuracy-of the audit results, review and response to-audit nonconform--
ances,.and effective resolution / prevention of deficiencies. 'The:
corrective actions required to resolve adverse audit findings shall be defined and implemented in a timely manner.
10.2.11 Audit finding nonconformances shall be followed up'in a timoly manner.
Such adverse audit findings shall typically.not be closed until the effective implementation of corrective action (s) is verified.
10.2.12.
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.
10.3 Resoonsibilities 6
10.3.1 Director - Nuclear' Assurance i
The Director - NuclearIAssurance is responsible through:the Director -
Quality Asqurance tot a.
Estab.ish and implement the: audit program and' assure all required areas-are audited, b.
Provide the auditing organization which meets-the requirements of this Plan.
c.
Evaluate the effectiveness of the. audit program.
d.
Ensure the development and implementation of the audit-schedule.-
e.
' Analyze the results of audits for quality trends and-inform the
-}
~
Office of the President and the affected Division Director _of.the results.
3899L (7/90) 85.0 a-
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-GPUNC OPERATIONAL QUALITY ASSURANCE Numbar PLAN-FOR THREE ' MILE ISLAND. UNIT 1-
-1000-PLN-7200.01 AND OYSTER ^ CREEK Revision No..
j
Title:
10.0 AUDITS-1~
j 10.3.2 Qirectorts) - Audited Orcanizatients)
The' Director (s)-of the audited organization (s) are responsible 1through q
Directors / Managers to ensures a.
Sufficient support is given to the audit 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 if and implemented.
{
c.
Responses to: audit findings are reviewed land-approved by their organizations prior to submittal to_the auditing organization.
d.
Responses to audit finding are nubmitted'to the auditing ^
-organization _in a timely manner as defined in: implementing' plans, procedures and/or instructions..
I c.
Corrective action to resolveLaudit-findings are_taken-in a timely-i manner.
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CPUNC OPERATIONALLQUALITY ASSURANCE
- Number, PLAN FOR THREE MILE 1 ISLAND UNIT-.1-1000-PLN-7200.01.
AND OYSTER CREEK Title Appendices Revision No.
2 APPENDICES' APPENDIX'A
. Comparison Chart of' operational' Quality Assujance; Plan Requirements'with those of various parts.of the. Code.of Federal Regulations and Nuclear' Industry Standards
~
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APPENDIX B QAD Documents Review Requirements-APPENDIX C
. NRC Regulatory Guide Commitments and Exceptions Terms and' Definitions--
1 APPENDIX D 1
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Number PLAN FOR THREE MILE ISLAND' UNIT 1 1000-PLN-7200.01 i
AND-OYSTER CREEK Title Appendices Revision No.
2 j
o APPENDIX.B OAD Documents Review Recuiremente 1
QAD shall selectively review documents which prescribe methods to" implement activities within the scope of this Plan or provide the quality and/or j
technical requirements for items, parts, materials and activities that are j
within the scope of this-Plan.- The purpose of such reviews is to_ verify that' such documents are consistent with the requirements of this plan.
TheJ minimum content of a QA document review,.as appropriate to the document y
reviewed, is provided in Subsections 3.1.2, 4.3.3, 5.1.2.3.(e) and 6.2.2.2.(b) of this Plan.
The types of documents typically reviewed 1 include plans,; procedures and
-instruc*. ions, procurement documents; work authorizing documents, and changes;
+
etc.
Refer to Section 3.2.2.1 for speci'., types.of documents which-will periodically be verified by QA document revtew.
QA review of documents within the ocope of this plan may be conducted before' or after the documents have been approved-for use.
Furthermore, QA_may review all or a sample of specific t'ypes of_dccumente within the scope of-this plan. The timing and scopo of the QA reviews shall be basad'on the-technical and administrative adequacy of'the documents.pr0duced without QA review for concurrence.
A QA Department-procedure approved by the_ Director, Quality Assurance, shall j
prescribe the process for measuring the adequacy of documents produced _
1 without QA review for concurrence. This measure shall be based.on the comment types and rates-resulting from QA reviews-of such documents.i The procedure shall include requirements for maintaining a database sufficient to provide for the measurement of adequacy.
The procedure shall_also-prescribe periodic adjustments in the timing and, scope of QA reviews.of specific types of' documents based on their measured technical'and administrative adequacy.
This procedure (s) will also ensure that QA; reviews of. documents be consistent-with the followings some-plans, procedures and/or instructions;are-required by this OQA plan o
to bee" reviewed for concurrence" by the Director of'QA. Such documents and changes shall'lua' reviewed by QA prior to implementing approval.
Other plans, procedures,-and/or instruc ;tions;and changes-thereto may be reviewed for concurrence by Quality. Assurance.
These documents shall be identified on the CPUN-Review and Approval: Matrix.
Changes to the quality classification procedure (s)-and the GPUN Review.
o
~
and Approval Matrix shall be reviewed for concurrence by the Director-QA-prior to implementation'of the change.-
Procurement, maintenance' and installation documents and changes shall lx) o reviewed as appropriate by QA prior to authorization for use to provide for the inclusion of inspection hold'and witness points.
89.0 3900L (12/88)
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( t-L/1 Nuder crunc orra^rzouxt ou^tIrr ^ssuanuce nems=r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision No.
1 APPENDIX C OUALITY ASSURANCE PROG W NRC REGULATORY GUIDE COMMITMEl{IA Nf2 EXCEPTIONA i
l This Appendix identifies those Regulatory Guides which contain Quality Assurance Program requirements and identifies the GPUN positions relative to compliance.
Part I of the Appendix is a tabulation of the Regulatory Guides the corresponding 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 tackfitting and/or retroactive complianca.
It is also to be recognized that existing plant conditions, may prevent or i
preclude the satisfaction of all requirements of a specific l
Regulatory Guide.
These conditions will be documented and, along I
with the justification, will be approved by the Director - Quality
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e'PUFC OPERATIONAL QUALITY ASSUPAHCE G
Numb r j-Nudew
^* roa zunte arte zst^"o U"zt 1 tooo-r'"-> oo o2 "NE AND OYSTER CREEK Title Appendiram Revision No.
5 APPENDIX C - PART 2 UPC_ Peculat orv Guide 1. 8, Pev.
1-R, May 1977 Personnel Selection end Training 1.
Guidelines have long been established in the company with re6ptet to awarding jobs to plant maintenance, operations, and other bargaining unit personnel who may be involved in testing, examination and inspection activities.
Personnel kre 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 oven though the individual does not meet the detailed guidance contained in ANSI N18.1 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 an otherwise noted in the Technical Specificaticns.
2.
For the NRC licensed positions of Reactor Operator (RO) and Senior Reactor Operator (SRO), the experience requirements of ANSI /ANS 3.1-1981 will be utilized to determine if candidates meet NRC licensing eligibility requirements, until the applicable site's simulator has been certified in accorcance with 10CFR55.45(b).
GPUN may accept EQ and SRo candidates.into the training programs who do not meet the detailed quicance contained in ANSI /ANS 3.1-1981 provided the oro-orams are INPO-accredited and utilite a plant-referenced simulator certified in accordance with 10CFRSS.45(b).
l NRC Recula(gry Guide 1.26 Rev.
3, February 1976 Ouality Group Classification and_Stanaard for Water, Steam and Radioactive Wnete Containino Components of Nuclear PowpI_ Plants i
Since the original design and construction of THI-1 and Oyster Creek was to different classification criteria than contained in this guide; CPUN will comply with the regulatory position of this guide with the following clarifications l
1.
For modification to existing plant systems, items will be classified by Technical Functions according to the original design basis or this guide.
This classification will not degrade the safety of the system being modified.
93.0
_ _. ~. _ - _ ~. -
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gf GPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r j
PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.03 I
AND OYSTER CREEK l
i Title Appendices Revision No.
2
}
APPENDIX C - PART 2 j
2.
Additlens to existing plant systems will be made to the same code, standard and technical requirements which were originally applied to the system to whicn the addition is to be made or more recent 4
versions of these codes, standards and technical requirements.
The add will not degrade the safety of the system being added to.
construction, the latest applicable code will be utill ed 3.
For v unless such ut111:ation would result in hardship or unusual i
dif ficulty without providing an equivalent level of safety.:
NRC Reaulatorv Guide 1.30. Aucust 1972 Quality Asegrance Reduirements for the Installation. Inspection and Testino of Instrumentat ion and Electric Ecoletant 4
j CPUN shall comply with the Regulatory Position established in this F.agulatory Guide Lu that QA programmatic / administrative requirements 1
included therein ohn11 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 technical requirements or better (e.g., code requirements, 4
material properties, design margins, manufacturing processes, and inspection requirements).
Sections 5.2 and 6.2 of ANSI N45.2.4 list tests which are to.be conducted during the construction phase.
In lieu of this, CPUN utilizes.ite Engineering and/or Maintenance organisations to' establish the.need for specific tests or test procedures during the operational-phase.
NRC Reculatory Guide 1.33. Rev. 2, February 1978 Ouality Assurance Progra,m Recuiremente f0Deration)
The CPUN QA Program complies with the regulatory position of this guide with the following clarifications:
1.
Regulatory Position C.4 of the regulatory guide The frequency of performance and the minimum topical coverage of.
1 internal audits will be consistent with Section 6 of the nuclear i
units'_ Technical Specifications.
Paragraph C.4.4 is interpreted to mean audits will be conducted once each 6 months to. verify that the nonconformance and corrective action program is properly implemented and documented, particularly as related to actions taken.to correct-defielencies that affect items classified as nuclear safety related sor regulatory required.
94.0 3900L (12/88)-
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PLAN FOR THREE MILE ISLAND UNIT 1
'1000-PLN-7200.01
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AND OYSTER CREEK Title Appendices Revision No.
1 a
APPENDIX C - PART 2 1
2.
Paragraph 5.1 of ANSI N18.7-1976 titled " Program Description" 3
This paragraph refers to the compilation of a " summary-document" to identify the sources, index the source documents to the requirements of this standard and to provide a consolidated base for the descrip-tion of the program.
For the purpose of clarity, this "Oper1tional-Quality Assurance Plan for Thre2 Hile Island Unit 1 and Oyster Creek"
]
la the " summary" document required. Appendix A correlates the sections of this Plan to ANSI 18.7-1976.
Section 2.0 provides the
" consolidated" base and description for the program.. Implementing documents are identified in Section 3.0, are required to be consistent.
with'this Plan and Appendix C of this Plan,-and are marked as stated in Section 3.C.
3.
Paragraph 5.2.2 of ANSI N18.7-1976 titled." Procedure Adherence" In accordance with Section 6.8.3 of both the Oyster Creek and THI-1 Technical Specifications, 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 these individuals shall be a member of-facility management or supervision holding a Senior Reactor Operator's License on the facility.
t 4.
Paragraph 5.2.8 of ANSI N18.7 - 1976 titled " Surveillance Testing and f
Inspection" i
In lieu of a " master surveillance" schedule, a technical specification surveillance testing schedule shall be established. reflecting the status of all inplant surveillance tests and inspections ~ required by technical specifications.
f 5.
Paragraph 5.2.15 of ANSI N13.7 - 1976 titled " Review, Approval and Control of Procedures" The third sentence of the third paragraph is interpret'ed to mean applicable procedures.shall be reviewed-following a. reportable incident such as an accident, an unexpected transient, significant l
cperator error, or equipment malfunction.
6.
Paragraph 5.2.17 of ANSI'N18.7.- 1976 titled " Inspections" Not all inspections will' require a separate inspection report.
(
Inspection requirements may be integrated into appropriate procedures or other documents with the procedures or documents, serving as.the record; however, records of'inspecticus will be identified and retrievable.
95.0 3900L
m q
y gf GPUNC OPERATIONAL QUALITY ASSURANCE lNumbor PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendice, Revision No.
2 APPENDIX C - PART 2
[lPC Peculaterv Guide 1. 3 *ldtLCA.J.fA 1973 Quality Aeeuraage Pecuirerente fer, gleanino Fluide Svetems and Associate (
C2rI2nente o[ Water Cod s! Hueleg Power Plante The CPUN Quality Assurance Program complies with the regulatory position of this guide with the following clarifications:
1.
The second sentence of paragraph C.3 should be amended to read:
"The water quality for final fluches of fluid systems and associated componente shall be at least equivalent to the quality required for normal operation.
This requirement does not apply to disolved oxygen or nitrogen limite nor does it infer that chromates or other additiven normelly in the system water will be added to the flush water."
2.
Paragraph C.4 should be amended to add Material such as inks, temperature indicating crayons, labels, wrapping materials (other than polyethylene), water soluble materials, lubricants, NDT penetrant materials and couplants, which contact stainleos steel or nickle alloy material surfaces shall contain no more than '. race elements of lead, aine, copper, mercury or other low melting a.1;ys or compounds.
Maxim;.m allowable levels of water leachable chloride ions, total halogens and sulfur compoundo chall be defined and imposed on the aforementioned materiale.
3.
Section 2.1 of ANSI N45.2.1-1973 states that required planning is frequently performed on a generie basis for application to many installations on one or more projects.
This results in standard procedures or plans for installation and inspection and testing wnich meet the requirements of the Standard.
Individual plans for each item or system are not normally prepared unless tho work operations are unique.
However, standard procedures or plans will be 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 Paragraphe 2 and 3 of ANSI N45.2-1977 which 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.
96.0 3900L (12/88) j i
(/- tJ 1Nular cre"c orta^trou^t ou^ttrv ^ssur^"cr "emd=r PLAN FOR THREE MILE ISLAHD UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision No.
2 APPENDIX C - PART 2 4.
GPUN intende to conf orm to the Cleannese requiremer.ts of Section 3.1 of ANSI H45.2.1-1973 with the exception of permissable particle sites for cleannene Classes B and D.
In these cases, CPUN will conform to the requiremonte of ANSI N45.2.1-1980, Section 3.2.2.1(b) which states, "These shall be no particles larger then 1/32 in, by 1/16 in.
long (0.8 nn by 1.6 nn)" for cleannese 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, ASTH E-ll, Specification for Wire Cloth Sieves for Testing Purposes) or finer filter, or the equivalent." for cleanness Clase D.
b.
Section 3.1.2.1 of ANSI N4b.2.1-1973 states that surfacce shall be examined without magnification under a lighting level (background plus supplementary lighting) of at least 100 foot candles.
GPUN intende to permit the use of neutral 18% gray card with a 1/32" black line for determining acceptabi14&y of illumination in lieu of the 100 foot candles.
6.
Section 4.0 of ANSI N45.2.1-1973 states that items are not to be delivered to the point of installation econer than necessary unless the installation location is considered a better storage area.
The strategy for the storage of items ic based on many factore, 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 ae a potential storage area.
As an alternate to this requirement, items may be delivered to the installation site sooner unan absolutely necessary when determined to be advantageous for other considerations.
Example - reduced handling or easier access, thereby reducing susceptibility to handling damage.
In all such cases, f
equipment stored in place will be protected in accordance with Section
~
$ of ANSI N45.2.1-1973.
7.
Section 6.0 of ANSI N45.2.1-1973 etates that where environmental contamination causes degradation of quality, seale are installed and the item is tagged with identifications and instructions for seal removal.
CPUN utiliten procedural controle which specify the authoritation requiremente for seal removal.
"Tage" are not normally utilized.
97.0 3900L (12/88)
. _ _... -. _ _ -. _ ~ -. _. _. -. _ _
i h
M7 CPUNO OPERATIONAL QUALITY ASSURANCE Number PLAN POR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 j
AND OYSTER CREEK i
)
Title Appendices Revision No.
j 2
)
APPENDIX C - PART 2 8.
Section 7.2 of ANSI N45.2.1-1973 allows piping systems to be flushed only with water.
A water flush of piping systems using other fluide can lead to contamination and/or other problems which would affset the reliability of these systems.
ANSI N45.2.1-1980 provides requirements and recommendations for flushed using fluids other than water.
For flushing of hydraulic instrument, control, lubrication and other non-Water systems, CPUN 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 utillaing thia l
exception must specify, as applicables particulate contaminate levels; water content; water soluble con.aminate levels; organic contaminate levels, flunh time, flush pressure / flow / amount; type of fluid to be used; and,.the restrictiono identified in Sections 3.4.2, 3.4.3, and 3.4.4.
NRC Reaulatorv Guide 1.38. Rev. 2,'Hav.1977 Ouality Aesurance Reauiremente for Packacino, Shiocino, Receivina, Storace and Handlina of Ytems for Water Cooled Nuclear Power Plents a
The CPUN Quality Assurance Program complies with the regulatory position of this guide with the following modifications or clarifications to ANS! N45.2.2-1972:
1.
Section 2.4, Personnel Qualifications.
As a point of clarification,' personnel who perform the audit (s) described in Section 2s4. will not be 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 Ite03.
The four-level classification system for storage of items will be followed, however, the designated classification level may not be explicitly identified on the item..The classification level will, however, be traceable through the pro-curement documents.
Classification differing from section 2.7 will be considered acceptable provided no degradation is assured; for example,. electric motore 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-systemfor packaging of items may not be used explicitly.
For. commercial grade items j
standard commercial grade packaging requirements may be specified.
i 4.
Section 3.6 concerns prevention of halogenated materials.from con-tacting stainless steel or nickel alloy materials.
The clarifications applicable to Regulatory Guide 1.37, identified previously, also apply to this section of ANSI N45.2.2.
5Property "ANSI code" (as page type) with input value "ANSI N45.2.2.</br></br>5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Section 3.7.1 Cleated, sheathed boxes will be used up to 1000 lbs. rather than.500.1bs. as specified. This type of box is safe for, and has.been tested for, loads up to 1000 lbs.
Other material standards-(i.e., FED' Spec..
-PPP-8-601) allow this. Special qualification testing shall'be required for loads in excess of'1000 lbs.
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AND CYSTER CREEK j
Title Appendices Revision No.
2-
?
I APPENDIX C - PART 2 6.
Section 5.5, correction of Nonconformances. This section.provides for
~
rework" and "useams is" dispositions for nonconforming items.
As an-a alternato, the " repair" disposition (as defined'in ANSI N45.2.10-1973) will also be used.
'I l
7.
Section 6.2.1 For storage of level D items access will be controlled and limited by posting. Other positive controls such as fencing or-j posting of guards will be provided for higher storage levels.
-l 8.
Section 7.4 states that a system should be established to indicate acceptability of all equipment and rigging.after each inspection, specify control of nonconforming lifting equipment, and supplement periodic inspections with special visual and nondestructive-examina-tions and dynamic load tests.- In lieu of-this, CPUN does perform dynamic load tests on new equipment, preventive maintenance on cranes, nondestructive ermnination of lif ting hooks annually, and a visuali inspection 6t~ lifting equipment prior to use.
9.
Appendix A.3.4.1 The last sentence of A.3.4.lg4)~ and (5) should be'
{
corrected as follows:
(4) "Howevor, 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 shallI be indicated to fae'111-tate 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 dry 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 sulphur limitiot 0.30s by weight instead of 0.10s as specified in A.3.5.2(1)(a).
This limit is reasonable based upon-the chemical content of commer-ela11y available tapes. _ Tapes will. be of a contrasting color ~ rather than " Brightly Colored" as required by A;3.5.1(3).
- 12. Appendix A 3.7.1 In lieu of A.3.7.1(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 joints shall be sealed with not less than-2-inch wide, water resistant tape.
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2
)
APPENDIX C - PART 2 NRC Reculatorv Guide 1.39. Rev. 2.-Seotember 1977 Housekgeeino Recuirements for Water' Cooled Huclear Power Plante Endorses ANSI N45.2.3 - 1973 4
?
The QPUN Quality Assurance Program complies with this guide with the i
following clarification to ANSI N45.2.3-1973.
i a
1.
Sections 2.1 and 3.2 The Nuclear Stations-will-not utilize the five' level zone desionation system referer.ced in ANSI;N45.2.3, but will i
utilize standard janitorial and work practices to maintain.a' level =of cleanliness commensurate with. company policy in the areas of.
housekeeping, plant and personnel safety, and fire protection.
cleanliness will be maintained, consistent with the work'being performed, so as to prevent the entry of foreign material-into' systems within the scope of this plan. This will include as a minimum documented cleanliness inspections which will be. performed immediately.
prior to system closure, control of' personnel,' tools,. equipment,:and supplies will be established when major' portions of the reactor system are opened for inspection, maintenance or repair.'
3 Additional housekeeping requirements will be implemented as required for 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,.0 PUN has established positions or commitments relating to fire safety or protection.
NBC Peculatorv Guide 1.54, June 1973 Ouality Assurtnee Recuirements for Protective Coatinos Aeolied'to Water Cooled Nuclear Power Plants The CPUN Quality Assurance Program complies with this guide with the following clarification 1.
OPUN will 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 were not inL ef fect
{
originally.- Technical requirements associated'with maintenance and
)
- modifications (e.g., code requirements, material properties, design margins,' manufacturing processes, and. inspection ~ requirements);sha111 be the original requirements.or' better.
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1 l
APPENDIX C - PART 2 2.
The 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 cottings, except those noted in 3 below, applied to surfaces within containment are tested to demonstrate that they can withstand LOCA conditions.
These tests are performed in accordance with Section 4 of ANSI N101.2, Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities, under LOCA conditions which equal or excoed those described in the TSAR.
The quality assurance program is applied for Protective Coatings consistent with the nature and scope of work specified in the technical specifications.
The following elements are included (a) Preparation of coatings specification and procedutes for generic coating materials / systems.
(b) Hoview and evaluatien cf coating manufacturers' demonstration test data and quality assurance measures for control of manufacture, identification, and performanco verification of applied coating systems.
(c) Review and evaluation of supplier quality assurance measures to control storage and handling, surface preparation, application, touch-up, repcir, curing and inspection of the coating systems.
(d) Training and qualification of inspection personnel in coatings inspection requirements, i
(e) Supplier surveillance inspection.
The coatings qualification program and the associated quality assurance requirements are necessary only for coatings whose failure or failure mechanism would have a significant effect on safety.
3.
Regulatory Guide 1.54 is not imposed fort (a) Surfaces to be insulated.
(b) Surfaces " contained" within a cabinet or enclosure (for example, the interior surfaces of ducts).
101.0 3900L
@ gf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN TOR THREE MILE ISLAND UNIT 1 1000-PLU-7200.01 AND OYSTER CREEK Title Appendices Revision No.
3 APPENDIX C - PART 2 (c) Tield repair on any Q-class coated item less than 30 square inches of l
surface area such as:
Cut ends or otherwise damaged galvanising.
o o Bolt heads, nutsi and miscellaneous fasteners.
Damage resulting from spot, tack, or stud welding.
o 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,.lounspeakers, etc. where special painting requirements would be inpracticable.
-f (e) Stainless steel or galvanized surf aces.
(f) Coating used for the banding of piping.
(g) Strippable coatings used for cleanup.
4.
Quality Assurance documer.tation may not be similar to records and documents listed in Section 7.4 through 7.8 of ANSI N101.4 but will be evaluated to assure that they provide at least the same degree of documentation as required-by this standard..
NRC Reculatory Guide 1.58, Rev.
- 1. Sectember 1980 Oualifications of Nuclear Power Plant Insoection. Examination, and Testina Personnel The CPUN Quality Assurance Program complies with this guide with the followine clarification 1.
The guidance of-Regulatory Guide 1.58 shall be followed as it pertains to the qualifications-of QA inspection personnel who verify conformance of work activities to quality. requirements.
The qualification of other QA personnel shall be in accordance with GPUN established requirements.
The qualifications of plant operation-personnel concerned with day-to-day' operation, maintenance, and certain technical services shall conform to Regulatory Guide 1.B.
The qualification of nondestructive testing personnel shall be in accordance with the requirements and recommendations of ASNT Recommended Practice No.
SNT-TC-1A, 1980-Edition.
In addition, SNT-TC-1A shall be used in conjunction' with the additional provisions of the applicable ASME Boiler and Pressure Vessel Code.
Later editions.of SNT-TC-1A may-be utilized as referenced in Section XI of the code provided.that the' edition of the Code has:been.
Incorporated by reference;into' Title 10 of the' Code of Federal-Regulations, Part 50.55a.
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PLAN POR THREE MILE ISLAND UNIT 1 lOOO-PLN-7200.01 AND OYSTER CREEK i-Title Appendices
. Revision No.
2 l
APPENDIX'C - PART 2 i
j 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 j
interval recommended by SNT-TC-1A, 1980.
2.
Plant operation personnel may be utilised to perform the visual. leakage l
examinations required by the edition of ASME Section IX and related codes currently committed to for the conducted of inservice: inspections.- 'such I
personnel shall be qualified consistent with these ASME-code requirements.
The selection and qualification of such perconnel'shall be prescribed by a procedure (s) which is reviewed and concurred with by the Quality Assurance Department.
3.
Not all personnel whos j
1 A.
Review and approve inspection and testing procedures, 1
B.
Evaluate the adequacy of activities to accomplish the inspection and test objectives, 4
C.
Evaluate the adequacy of specific programe used to train and. test J
inspection and test personneli t
D.
Certify Level III individuals in specific categories or classes, i
will be certified as meeting the Level:III capability requirements of ANSI-I N45.2.6 - 1978.
Rather these personnel will be determined by management through evaluation of their education, experience, and training to be fullyf qualified and competent'to perform these' functions.. The basis for the-determination will be documented.
NRC Reculatorv Guide 1.64. Rev.
2.
June 1976 t
Ouality Assurance Recuirements for the Desion of Nuclear Power Plants GPUN will 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 were not in effect originally.
Technical requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and: inspection' requirements) associated with maintenance and modifications shall be.the original requirements
~
or better.
The Quality Assurance Program complies with this guide:with the following.
- 1arifications -
103.0 3900L (12/88)
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I 2
APPENDIX C - PART 2 1.
Regulatory Position C.2(1) of the Regulatory Guides If the designer's innediate Supervisor is the only technically gcalified individual available,-this review can be conducted by the Supervisor, providing that s (a) the other provisions of the Regulatory Guide are satisfied, and (b) the-justification is individually documented and approved in advance by the Supervisor's management, and (c) quality assurance _ audits cover frequency and effectiveness of use of Supervisors as design verifiers to guard against abuse.
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 designe..
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 clarifi-cation with regard to " field changes," the effect-of the' field change will.be independently evalvated.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 field change.
If the review determines that the field change does have an effect on the previously approved design'then a design verification of the resolution of that specific field change will be conducted.
Also, field chang:s that are " minor" as described in paragraph'7.2 of
~
the standard will not_be design verified.- Procedural r9quirements i
shall be provided to identify when such field 7 changes are " minor" in the context of paragraph 7.2 of the-standard.-
NRC Reculatory Guide 1.88 -Rev.
2, October, 1976 l
Collection, Storace, and Maintenance of Nuclear Power Plant Availability Assurance Records l
CPUN will comply with the intent of this regulatory guide by compliance with the requirements of ANSI /ASME NQA-1-1979, Supplement 17S-1 and Appendix 17A-1 including. Appendix 17-1, NQA-1A-1981..
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AN* SYSTER CREEK Title Appendices Revision No.
2 APPENDIX C - PART 2 NRC Reculatory Guide 1.94. Rev.
- 1. Acril 1976 Quality Assurance Recuirements for Installation. Insceetion and Testino of Structural Concrete and Structural Steel durina the Construction Phase of gyelear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification (s):
(1) QA programmatic / administrative requirements included in the Regulatory Guido 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 botter (e.g., code requirements,. material properties, design margins, manufacturing processes, and inspection requirementa).
(2) Section 5.4 of ANSI N45.2.5-1974 specifies the calibration frequency and method of automatic cut-off impact wrenches used to make un and-inaccet high strength bolted connections; and, the calibration frequency of hand held torque wrenches used to inspect high strength bolted connections.
Section 5.2.6 of ANSI 18.7 as well as 6.6 of this plan also specify controle 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 wrenches and hand held torque wrenchen used to mahe up and/or inspect high strength bolted connections.
The method of calibration will be consistent with the manufacturer's recommendation (s).
NRC Reculatory Guide 1.116, Rev.
0-R.
May 1977 Ouality Assurance'Recuirements for Installation. Insceetion and Testino of Mechanical Eautoment and Svetems The GPUN Quality Assurance Program complies with this guide with the following clarification e
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).-
MuchLof N45.2.8 applies to construction and pre-operational testing.. As a result, many of the listed tests are not appropriateLin an operational plant.
'In lieu of this, GPUN utilizes its Engineering and/or Maintenance
~organisations to establish the need for specific tests or test procedures during the operational phase.
105.0
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hhgf CPUNC OPERATIONAL QUALITY ASSURANCE Numb 3r PLAN TOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision No.
2 APPENDIX C - PART 2 NRC Reculatorv Guide 1.123. Rev.
1.
July 1977
)
Qgality Assurance Recuirements for Control of Procurement of Items and Servlegg for Nuclear Power Planta The CPUN Quality Assurance Program complies with this guide with the following clarifications 1.
Section C.3.
A corrective action system may, depending upon i
complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.
2.
Section C.4.
Applicable information concerning 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 N45.2.13-1976.
When evaluation of a supplier la based solely on historical supplier data, these data will primarily include records that have been accumulated in connection with previous procurement actions.
Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be used if available.
4 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 documents shall contain requirements specific to the item being procured.
5.
Section 7.5.
As a point of clarification, personnel who perform the audit (s) as described in Section 12.0 will not be qualified in accordance with ANSI N45.2.6.
Such personnel are qualified in accordance-with RegulatoryJ7uide 1.146, dated 8/80.
6.
Section 10.2.d of ANSI N45.L 13-1976. The requirements of this section are interpreted as follows:
The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.
7.
Section 10.2.1, Verification of the Validity of Supplier Certificates and the Effectiveness of the certification System, is as follows:
The verification of the validity of supplier certificates and-the effectiveness of_the certification system are accomplished as an integral part of the total supplier control and product acceptance program, and no separate CPUN system exists that addresses itself solely to such verification.
The degree of verification required will depend upon the type of~ item'or service and their safety 106.0 i
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2 APPENDIX C PART 2-importance. The means of verification may include source witness / hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete _ components; and tests after installation on selected components and systems. -All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not-a certification system is effective.
NRC Reculatory Guide 1.142. October 1981 Safetv-Related concrete Structures for Nuclear Power Plants (Other Than Reactor j
vessels and containments)
-l GPUN shall comply with the Regulatory. Position established:in this
)
Regulatory Guide as augmented by ANSI N45.2.5, ANSI /ANS 6.4-1977 and i
ANSI /ACI 318-77 for the design and construction of new Nuclear Safety Related or Regulatory Required structures and additions to existing
' Nuclear Safety Related or Regulatory Required structures.
Inspectors will be qualified according to either. ANSI N45.2.6 or Appendix VII of Section-III, Division 2, of the ASME Boiler and Pressure Vessel Code.
NRC Reculatorv Guide 1.143. October 1979 Desion Guidance for Radioactive Waste Manacement Systems. Structures and comoonents Installed in Licht-Water-cooled Nuclear Power Plante l
Since the original design and construction of TMI-l and Oyster Creek.was to different classification criteria than contained in this guide; OPUN-will comply with the regulatory position of this guide with-the following clarifications:
1.
For modification to existing plant systems, items will be classified by-Technical Functions according to the original design basis or.this guide.
This classification will not degrade the safety _of the system being modified.
2.
Additions to existing plant systems will be made to the same code, standard and technical requirements which were originally applied to' i
the system to which the addition is to be made or _more 'recent versions of these codes, standards and technical requirements.
The addition will not degrade the safety of the system being added to.
3.. For-new construction, the latest applicable code will be utilized unless such-ut111:ation would result in hardship or unusual diffi-culty without providing an equivalent level of. safety.-
107.0 3900L (12/88)
Nuder di GPuNe oPtRxTzoNit ouAt Tr assuR>.NcE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision No.
2 APPENDIX C - PART 2 NRC Peculatory Guide 1.144. January 1979 Auditino of Ouality Accurance Procrams for Nuclear Power Plante GPUN is in boele agreement with the position set forth in the Regulatory Guide subject to the following commente 1.
Sectione C.3.af1) and c.3.a(2)
Minimum scheduling frequency and topical coverage of the GPuN internal audit program will be ao defined in Section 6 of the nuclear unite' Technical Specificatione.
2.
Section C.3.bf1).
Source surveillance will be utilized in lieu of or in addition to receipt inspection.
As permitted, external audits of such procurement actions will typically not be scheduled.
3.
Section C.3.b(2)
External audits of selected suppliers of services which are within the scope of thle Plan will bu ocheduled and conducted at least once within the life of the actielty or everv three years.
Rofer also to 10.2.5 of this plan.
An annual evaluation of suppliers of items, parte, materiale and ser'cices will be conducted.
These evaluations will be conducted utilizing the results of source surveillance, source inspection, receipt inspection and/or audita; and, other factore. These evaluations will determine the need to conduct audits of suppliers of items, parts or materiale; or, increase the frequency of conducting audits of suppliere of services.
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Title Appendices Revision No.
2 APPENDIX D a
Terms and Definitions This Appendix centains certain terms and their definitions that are important to a uniform understanding-of the requirements _of the GPUN operational Quality Assurance Program.
AN81 N45.2.10-1973, as endorsed by I
Regulatory Guide 1.74, and NQA-la-1981 contain terms and definitions applicable-to the nuclear industry.. The terms and definitions found in these documents are applicable to the GPUN operational Quality 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 HQA-la-1981 are identified by-footnote (1).
Cortain exceptions to 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).
)
ACQEPTANCE (as used in relation to acceptance of a document):
Generally approved, believed or recognized.
Does not require signature of person accepting.
ACCEPTANCE CRITERIA:
Specified limits placed on characteristics of an item, process, or service defined in codes, standards, or other documents. _ (1)
ADMINISTRATIVE CONTROLS:
Rules, orders, instructions, procedures, policies,.
practices and designations of autherity and responsibility.
ALARA:
(Acronym for As Low As Reasonabiy' Achievable) - a method'of analysis of the performance of activities in radiological areas to determine specific methods for reducing man-rem exposure.
APPROVAL An act of endorsing and adding positive authoriaation (signature)fto a document by the person (s) respon,1ble for the document. (2)
{'
ARCHITECT / ENGINEERING (A/E):
.A K.rm under contract to_ provide engineering or, design services.
AS-BUILT DATA: Documented data that describes the condition actually achieved in a product. (1) hyD1T A formal, independent activity conducted with the intent to verify conformance with established'requircesnts.
This activity is performed in accordance with written procedures or checklists to verify, by examination and l
evaluation of objective evidence, that documents.and. activities within the scope of this Plan are consistent with requirements, are being effectively implemented and provide results which are consistent with technical require--
I-ments. The terms " source et//el? lance", " source inspection", " inspection" "survuillance/ monitoring." and "-;urvey" are=not synonymous or equivalent to the
. term " audit "
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AND OYSTER CREEK i
Title Appendices Revision No.
3 2
I l
APPENDIX D BAsrLINE ENGINEERING DOCUMENTS:
Includes but is not limi*ed to safety evaluation, design criteria documents, flow charts, System Design Descriptions, general arrangement drawings, single-line diagrams, and logic diagrams which show or define basic plant parameters.
For instance, control Panel, Layout and Control Room arrangement drawings are baseline documents.
g&gic CoMPOSIRI:
A term defined in 10CFR21, a " basic component" means a plant structure, system, component or part (including design analyses), necessary to assure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shutdown the reactor and maintain it'in a safe shutdown, or (3) 4 the capability to prevent or mitigate the consequences of accidents that could result in potential off-site exposures comparable to those referred to in 10CFR100.11.
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 GRADE 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).
EQII: The technical requirements set forth in the published product-description must match the requirements needed'to satisfy the design function i
of the item.
Commercial grade items, when used as a basic component, must be j
dedicated prior to operation.
CONCURRENCE:
Written agreement that the provisions in a document for which j
review has been requested are acceptable for~ implementation within, or from the-standpoint of, the reviewer's area of responsibility.
CONDITION ADVERSE TO OUALITY:
An all' inclusive term used in reference to any of the following failures, malfunctions, deficiencies, defective items, and nonconformances.~ A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or operability.
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CONTRACTOR: Any organization under contract for furnishing items or services.
l It includes the term Vendor, Supplier, Subcontractor, Fabricator and i
subcontractor levels, where appropriate. (1)
CONTROLLED DOCUMENT:
A document which is assigned and distributed to an individual, organization or location and requires that individus1 or organization to be accountable for the document.--The distributing-agent is responsible for providing the recipients with current revisions to the document.
C2 ERECTIVE ACTION:
Heasures taken to rectify-conditions adverse to quality and, where necessary, to preclude repetition. (1)
DEDICATION: The process by which a commercial grade item is designated for use in a nuclear safety-related application (s).
It includes a point in time, i
typically after veceipt, when *he party designating the item assumes deficiency reporting responsibility associated with such use.
QEgION BASES:
That documented information which identifies the specific functions to be performed by a structure,--system,-or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design.
DETAILED DESIGN DOCUMENTS: Engineering design documents derived from the Baseline Engineering Documents that provide the detail of design sufficient to fabricate, install and test a modification or system.
This includes but is not limited to Procurement, Material, and/or Test Specifications, Installation Specifications, Fire Hazard Analyses, construction drawings, fabrication-drawings, Bill of Haterials, etc.
t DOCUMENT: Any written, pictorial, graphical or other reproducible media-information describing, defining,-prescribing, specifying, reporting, or certifying activities, requirements,-procedures or-results.
A document is not considered to be a record until it is completed and contains the-required signatures. (2)
ENGINEERING (Encineeris This term refers to the technical responsibilities of-Technical Functions, Plant Engineering or A/E's.
EXTERNAL ORCANIZATION.Es Any organization participating in the. project which is I
not a part of CPUN.
This term includes vendors, A/E's.and contractors.: This term is synonymous with the term supplier.
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2 APPENDIX D IIEg Any structure, system, or component of a nuclear power plant including nuclear fuel and radwaste systems.
This item also includes licensed radwaste shipping containcre.
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 instrumen-tation items shall include electrical, distribution, instrument and control panels, cabinete, switchgear, motor control centers, non-panel mounted instrumente, transformere and meters.
This term does not necessarily include parts of components.
LItD AUDITOR:
An individual qualified to organizo and direct an audit, report audit results, and evaluate corrective actione.
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 requiremente by direct observation or record review.
Generally, monitoring is performed on site and surveillance le performed at a vendore's facility.
NUCLEAR SAFETY RELATED:
Structurse, cystems and componente designed to remain functional for all design basis conditione necessary to ensure the following safety functions:
- 1) The integrity of the Reactor coolant Pressure Doundary.
- 2) The capability to shutdown the reactor and maintain it in a safe (hot) shutdown condition; or
- 3) The capability to prevent or mitigate the consequences of accidents which could result in potential offeite exposures comparable to the guideline exposures of 10CFR100.
PROCUREMENT DOCUMENT:
Purchase requisitions, purchase ordere, drawings, contracts, specifications or instructione used to define the quality and technical requiremonte for purchase. (1) 112.0 3900L (12/68)
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1 OA PLAN SCOPE:
This term is a designator used on the coversheet of approved documents which prescribe the method of performance of activities or tasks identified in Section 2.2.2 of this Plan.
OUALIFICATION (Personnel):
The characteristics or abilities gained through education, training or experience, as measured against established requirements, i
auch 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)
OUALITY CLASSIFICATION:
A process for identifying the technical and quality I
requirements of structures, systems, and components based upon regulatory requirements and commitments, safety function and/or reliability consideration.
OUALITY CLASSIFICATION LIST fOCL): The approved and controlled document used to record the identification of structures, systems and components that are within the scope of this Plan.
RECORD A completed document wh8ch has been authenticated which furnishes i
evidence of the acceptability of an item, part, material, or activity, etc.
within the scope of this Plan.
I REGULATORY REOUIREQ Those items which are not nuclear safety related but which must meet NRC 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 eloc--
trical equipment, seismic response capabilities, licensed shipping containers to the extent' committed by CPUN, generic letters, IE Bulletins, 10CFR50.54(f) correspondence, certain NUREO documents, etc.
REVIEW FOR CONCURRENCE.
A review of a document conducted prior to that docu-ment being approved for use. A review conducted by someone other than the individuals who prepared; or, will approve the document for use.
SPECIAL PROCESSI A process,_the results of which are highly dependent on-the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product. (1) l SUPPLIER: A firm which provides items, parts,-materials:or services from an offsite facility and operates-under the requirements of their own QA program.
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APPENDIX D SUPPLIER OUALITY CLASSTFICA'f f 0N LIST iSOCLit A approved and controlled list of suppliers who have been evaluated by the GPUN Quality Assurance. Department'for their espabilities to produce or provide items or services or both within the scope of this Plan.
TRACEABILITY: The ability to trace the history, application, or location of an item and like items or activities by means of recorded information. (1)
TREND ANALYSIS A quantitative method of collecting and analysing nonconformance/ deviation events with the goal of systematically determining-programmatic / procedural weaknesses.
VENDOR:
A firm which manufactures items at offsite facility'and operates-under the requirements of their own qualit
.surance program.
VERIFICATIQHe An act of confirming,_ substantiating and assuring that an activity or condition has been implemented in conformance with.the specified requirements. (1) i 4
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