ML20069B071

Forwards 10CFR50.54 Analysis & Revised Oqa Plan Pages That Were Inadvertently Omitted from Original Submittal

ML20069B071
Person / Time
Site:	Oyster Creek, Three Mile Island
Issue date:	05/20/1994
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20069B074	List: ML20069B071 ML20069B113
References
C321-94-2074, NUDOCS 9405270059
Download: ML20069B071 (7)

Text

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9' GPU Nuclear Corporation l Nuclear  :::en:r3ee Forked River, New Jersey 08731-0388 -

i 609 971-4000 Writer's Direct Dial Number: i l

C321-94-2074 May 20,1994 U.S. Nuclear Regulatory Commission 1 Attn: Document Control Desk Washington, DC 20555

Dear Sir:

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Subject:

Oyster Creek Nuclear Generating Station l Docket No. 50-219 )

Technical Specification Change Request (TSCR) No. 215 '

l Additional Information l

The purpose of this correspor dence is to provide you with the 10 CFR 50.54  !

analysis and revised OQA plan pages as detailed in the cover letter for TSCR 215. i These enclosures were inadvertently omitted from our original submittal dated --

April 15, 1994.

If you should have any questions or require further information, please contact Brenda DeMerchant, Oyster Creek Licensing Engineer at (609) 971-4642.

1 Very trpl < urd / -

A j J hn J. Barjon ice President & Director Oyster Creek JJB/BDEM:jc cc: Administrator, Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Manager TMI-1 Sr. Project Manager 9405270059 940520 hDR ADOCK 050002.19eda cu % GPU Nuclear Corporation is a subsidiary of General Pubhc Uhhties Corporation i

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- F LlNuclear memorandum sua m 10CFR50.54 Review of Audit ou March 4,1994 Related Changes rmm. S. N. Tiwari - Engineer Sr. I tocanon: Morris Corp. Center 6161-94-034 To. M. W.12ggart - Mgr., Corporate Licensing A Technical Specification Change Request (TSCR) is being initiated to transfer the frequencies of audits from Plants' Technical Specifications to the GPU Nuclear's Operational Quality Assurance Plan (OOA Plan). The following verbiage changes in the OA Plan have been proposed to facilitate this transfer:

1. 10.2.4 The areas to be audited are listed in the Nuclear Units' Technical Specification. The frequency of internal audits is based on performance. These frequencies are listed in Appendix E to this Plan.

2. APPENDIX 'C' The frequency of performance and minimal Reg. Guide 1.33, Section 1 topical coverage of internal audits will be consistent with Appendix E of this plan.

3. APPENDIX 'C' The frequency of performance and minimal Reg. Guide 1.144, Section topical coverage of internal audits will be C.3.a(1)and C.3.a(2) consistent with Appendix E of this plan.

As apparent, the changes revolve around the proposed Appendix E. This appendix is attached as Attachment 1 to this letter. Attachment 2 provides the comparison between proposed and existing audit frequencies.

Analysis of Changes and 50.54 Determination The key elements of this proposed change in OOA Plan constitute of the 2 distinct aspects of proposed Appendis E; one, the Audit Schedule Performance Review, and two, the changed audit frequencies.

A numerical comparison of the existing frequencies prescribed in the Units' Technical-Specifications with the proposed frequencies indicates that the frequencies for audits associated with Fire Protection program are not changed. Also not changed are the frequencies mandated by regulations, such as, those for Security Plan and Emergency Plan.

Frequencies of other audits have been proposed to be reduced.

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, , . 10CFR50.54 Review of Audit Related Changes

, Page'2 If the premise of commitment is the numerical frequency of the audit (s), the proposed numerical reduction in audit frequencies constitute an apparent reduction in GPU Nuclear commitment. It should, however, be noted that this quantitative reduction does not compromise the quality of GPU Nuclear's oversight of its operations. In fact the proposed controls, such as the Audit Schedule Performance Review and the inclusion of Corrective Actions as an item in all audits, enhance the quality of the oversight.

The proposed Audit Schedule Performance Review is the annual review of the performance of the topical area (s) by a group of managers including appropriate plant or i

corporate management to decide if more frequent audits will.be needed, To make this l decision. this yearly review will consider such salient performance data as deficiency trends. 1 mdustrv events. notice of violations and licensee event reports. This important database '

and the conduct and frequency of this review focuses critically on the performance of the area audited and not merely on the prescriptive duration between two audits. This position

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n consistent with NRC's Regulatory Review Group's (RRG) Recommendations, which among other things, recommends a performance based and graded quality assurance.

(Refer to the topical area titled 'Ouality Assurance' of the implementation Plan of SECY-l ua.003 of Januar 7.1904, and associated RRG's recommendation 4.1.1 ). This yearly '

performance review combined with the inclusion of Corrective Action as an item for all audits is a significant step towards enhancing the efficiency and quality of oversight.

Based on the above analysis. it has been determined that the proposed change constitutes a reduction in commitment, although it improves the quality of oversight.

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bb S. N. Tiwa t

Extension 7433 1

References:

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1. 10CFR50.54

2. 1 NRC SECY 44-003 January 7.1994. Quality Assurance and associated RRG recommendation 4.1.1

Attachment 1 Operational QA Plan Appendix E Maximum Frecuency TM1 Ref. OC Ref. Descrintion (See Note 1) 6.5.3.1 ( A) 6.5.3.1 (A) The conformance of unit operations to 24' Months provisions contained within the Technical Specifications and applicable license conditions.

6.5.3.1 (B) 6.5.3.1(B) The performance, training and qualifications 24 Months of the entire unit staff.

6.5.3.1 (C) 6.5.3.1 (C) The verification of the nonconformances and 24 Months corrective actions program to be properly (See Note 2) implemented and documented as related to action taken to correct deficiencies occurring in unit equipment, structures, systems or methods of operation that affect nuclear safety.

6.5.3.1 (D) 6.5.3.1 (G) The performance of activities required by the 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.

6.5.3.1 (E) 6.5.3.1 (D) The Emergency Plan and implementing 12 Months (Reg.

procedures. Req'd. Frequency) 6.5.3.1 (F) 6.5.3.1 (E) The Security Plan and implementing 12 Months (Reg.

procedures. Reg'd. Frequency) 6.5.3.1 (G) 6.5.3.1 (F) The Fire Protection Program and 24 Months implementing procedures 6.5.3.1 (II) 6.5.3.1(1) The Offsite Dose Calculation Manual and 36 Months implementing procedures.

6.5.3.1 (1) 6.5.3.1 (J) The Process Control Program and 24 Months implementing procedures for solidification of radioactive wastes.

Attachment i Operational QA Plan Appendix E Maximum Freau.cnn D11 Ref, O C iter. Description (See Note 1) 1 6.5.3.1 (J) 6.5.3.1 (H) The performance of activities required by the 24 Months Ouality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977.

6.5.3.1 (K) 6.5.3.1 (K) Any other area of unit operation considered As Requested appropriate by the IOSRG or the Office of the President-GPUN.

6.5.3.2 ( A) 6.5.3.2 ( A) An independent fire protection and loss 12 Months prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.

6.5.3.2 (B) 6.5.3.2 (B) An inspection and audit of the fire protection 36 Months and loss prevention program, by an outside qualified fire consultant.

Note 1: All frequencies except for those at 36 months can be extended for an additional 25%

to allow for schedule flexibility. The 25% will not he used on two consecutive audits of the same area.

Note 2: Corrective action will be a standard audit scope item for individual audits throughout I the annual audit schedule. l l

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Attachment 2 .

Comparision of ExistinLand Proposed Audit Frequencies '.

TMI _Qf Existine Proposed Freauency Tech. Spfc. Tech. Spec Freauency (See Note 1)

Ref. Ref. Description 6.53.1 ( A) 6.53.1 ( A) The conformance of unit operations to 12 months 24 Months provisions contained within the Technical Specifications and applicable license conditions.

6.53.1 (B) 6.53.1 (B) The performance. training and qualifications of 12 Months 24 Months the entire unit staff.

6.53.1 (C) 6.53.1 (C) The verification of the nonconformances and 6 Months 24 Months corrective actions program to be properly (See Note 2) implemented and documented as related to action taken to correct deficiencies occurring in

- unit equipment, structures, systems or methods of operation that affect nuclear safety.

6.53.1 (D) 6.53.1 (G) The performance of activities required by the 24 Months 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.

6.53.1 (E) 6.5.3.1 (D) The Emergency Plan and implementing 12 months 12 Months (Reg. Reg'd.)

procedures.

6.53.1 (F) 6.53.1 (E) The Security Plan and implementing 12 Months 12 Months (Reg. Reg'd.)

procedures.

6.53.1 (G) 6.53.1 (F) The Fire Protection Program and implementing 24 Months 24 Months c procedures 6.53.1 (H) 6.53.1 (I)- The Offsite Dose Calculation Manual and 24 Months 36 Months implementing procedures.

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Attachment 2 - -

Comparision of Existine and Proposed Audit Frecuencies .

TN11 OC. Existing Proposed Freauency Tech. Sper. Tech. Socc Frecuency (See Note 1)

Ref. Ref. Description 6.53.1(1) 6.53.1 (J) _ The Process Control Program and 24 N1onths 24 N1onths implementing procedures for solidification of radioactive wastes.

6.53.1 (J) 6.53.1 (II) The performance of activities required by the 12 Months 24 Months Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977.

6.53.1 (K) 6.53.1 (K) Any other area of unit operation considered As As Requested appropriate by the IOSRG or the Office of the requested President-GPUN. .

6.5.3.2 (A) 6.53.2 (A) An independent fire protection and loss 12 Months 12 Months prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.

6.53.2 (B) 6.53.2 (B) An inspection and audit of the fire protection 36 Months 36 Months and loss prevention program, by an outside qualified. fire consultant.

Note 1: All frequencies except for those at 36 months can be extended far an additional 25% to allow for schedule flexibility. The 25% will not be used on two consecutive audits of the same area.

Note 2: Corrective action will be a standard audit scope item for individual audits throughout the annual audit schedule.

freq.tbl i

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