ML20126B341

Forwards Responses to NRC Questions Re TMI-1 Operational QA Plan

ML20126B341
Person / Time
Site:	Crane
Issue date:	03/03/1980
From:	Thorpe J GENERAL PUBLIC UTILITIES CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
E&L-2160, NUDOCS 8003110379
Download: ML20126B341 (1)

Text

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s GPU Service Corporation W

e 100 Interpace Parkway Parsippany, New Jersey 07054 201 263 6500 TELEX 136-482 Wnter's Direct Dial Number File: 2259.10 l

l March 3, 1980 ESL-2160 Mr. Harold R. Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

RESPONSES TO INFORMAL NRC QUESTIONS CONCERNING THE QUALITY ASSURANCE PROGRAM Enclosed are responses to the fifty-two subject questions. These responses will be factored into the TMI-l Restart Report after formal NRC questions have been received.

Very truly yours, I

GPU SERVICE I

. ~ ~

J. R. Thorpe Director - Environment, Health and Safety JRT:bj o Enclosures cc:

R. W. Reid H. Silver q

R. H. Vollmer j

l l

I QooD 5/ll ADD:

93 k 1 H.DEalon i

i j

GPU Service Corporation is a subsidiary of General Pubhc Utikttes Corporation 8003110 373 j

..r..

i ON B01 OPI?.ATIO:;A", QU/6:T! A02U?JJi I ?l.4; l

1.

The " Nuclear Safety Evaluation Department" (NSED) described in 2.2.b.3 has been changed to the "Huclear Safety Assessment Department" and is now shown on the revised organization chart.

Section 1 has been revised to reflect the latest organization structure.

2.

The information requested was provided during the meeting held at GPU on Feb'ruary 5 & 6, 1980.

3.

The qualification requirements for the Manager of Quality Assurance have been revised to specify the minimum nuclear QA experience and knowledge of QA regulations, policies, and standards, b.

The terms QA Plan and QA Program are not intended to be interchangeable.

The QA Plan is the document submitted, while the QA Program includes the C,*. Plan plus the implementing procedures. Section 2.1.1 has been revised to clarify this.

5 Section 2.1.2 " Scope" and Appendix C have been expanded to include Begu-latory Guide 1.29 The position on Reg. Guide 1.26 is already included in Appendix C.

Also item '(f) vill be revised to delete Reg. Guide 1.120 and add 3 ranch Technical Fositien As3 9 5-1 " Guidelines for Fire Protection for Nuclear Power Plants".

6.

A representative C.CL vill be ir.cluded as a chan.:e to Section 5 of the T:T Pert 2r Fep:rt. The CC', vi:1 be a cen.rciled docu.ent subject to periodic update and controlled distribution; however, he sample list to be included in the Restart Report vill not be _ controlled or updated.

7 Section 2.2.2 has been revisei to comply with your ce=ent.

8.

Section 2.1.3 has been expanded to cenply with your co=ent by describing responsibilities and guidelines for determining appropriate QA requirements and defining the QA Organizations involvement.

9 The method to be used for determining how and to what extent the three level approach is to be applied vill be contained in implementing proce-Section 6.2.1.2 has been added to amplify how " Plant Monitoring" dures.

is used for activities important to safety.

l 10.

Section 2.2.1 has been revised to comply with your ccmment.

The Operational.QA Plan has been edited to purge the text of ambiguous i

11.

vords; however, where vords like " applicable" or " appropriate" add clarity l

they have been lef t in the text.

Section 2.2.2 has been expanded to identify who is responsible for identifying I l

12.

the quality classification of spare and replacement parts and the extent ofN~.

the QA organization involvement with the classification process.

l

1 I

13 Section 2.2.2 has been expanded to describe the classification of spare or replacement parts.

Ib.

Section 2.2.3 has been expanded to comply with your co==ent.

15 The position vith regard to Reg. Guide 1.26 is stated in Appendix C.

16. The qualification program for on-site and off-site personnel performing activities important to safety is to be covered in implementing proce-dures. Section 2.2.5(b) has been revised to clarify which personnel require qualification.

17 Section 2.2 5(b) has been revised to include requirements for estab-lishment of acceptance criteria.

1 18.

Section 2.2.6 has been added to comply with the co= cent.

19 2ecti:n 3.3.1 har teen revised to cceply with this c:.n=ent.

The requested statement hus been added to Section 3.1.2 af ter (h).

J 20.

21.

Appendix B to the Operational QA Plan describes the QA involvement la reviev, and documented concurrence with procedures which are important te safety.

Clarification has been added to better describe the terms

" reviewed by" and " concurred by".

22.

Ar built desvin6: e:11 be centr:;11ed and limited to revised drawings or crrunen;a

.i d cer " ;; ening+s.

Cnances : fun :icnal irsvings,

i.e.

electrica: one line,.eill be i.aintained currer. for users.

23 Paragraph h of page III-5 has been revised to describe approval respons-ibilities for maintend.nce, codificatien and inspectica procedures prior to implementation.

2h.

Ccapliance vita the comment has been accomplished by adding 3.2.2.h.3 25.

Section 2.3.2.2 hac been' c:rpanded to ecm;17 with the ccmment.

26.

Section 3.1.2 hac been revised to require procedures, instructions and/or drawings to be in compliance with the Plan.

27.

The words " major participating organizatiens" in Section 3.3.3 l(a) have been deleted.

ECM's 28.

The purpose and use of ECM's is described in Appendix B to the Plan.

are one form of document covered under the broad heading of design control.

29 Design verification vill be completed prior to making the tie-in to the plant system. This requirement has been added to Section b.2.1(1).

Appendix B identifies the engineering documents that are reviewed, approved' -

30.

or concurred with by RA.

\\.

1

31.

A requirement to implement the OA Plan in the procurement of spare or rtplacem^nt parts has been added to Section 5.1.2.1(a).

32.

See: ion 5.1.2.3(c) has been revised to add QA concurrence of nonconformances di: positioned "use-as-is" or " repair" and to provide follow up of corrective action implementation.

33. The requirements for control of identification of materials, parts and components during the =aintenance and operations phase have been included in Section 6.2.1.6(e) and 6.2.1.11.

34. The comment has been incorporated.

Section 5.2.2.c.2. bas been supplemented to include "as built" drawings.

35. The extent necessary is as detenained by responsible management personnel and reviewed by the Quality Assurance Department. The response.to comment;..J4 '

1. 8 above also addresses this concern.

36. To assure that individuals performing inspecticns are sufficiently independent frce individuals responsible for costs and schedules, the provisions of 6.2.1.1 vill be amplified in the implementing procedures. These procedures vill clar-ify that inspections vill be performed by QA personnel or by individuals under the control of the QA Department.

37 The requirement for QA concurrence of work authorization documents, relating to work important to safety, has been added to Section 6.2.1.1, page VI b.

38.

The seco'nd sentence, fourth paragraph, page V! h has been reviced to read:

"'~h re verificati r of irspection ir being perferned en previously accepted lots, sampling inspection shall be representative and only to the extent necessary to assure adequacy of control".

39 The test program to cover tests associated with technical specifications and inservice inspection is covered in Sections 6.2.1.b(1 thru h) and

6. 2.1. '(.

LO.

A statement has been added that programs for control'of measuring and test eruipmant are sutf ect c ' A_9 ~:niterir7 and auditinc (see 2r.d para-graph, page V:-9) and Secticn 6.2.1.2 has been adied aescribing Plant QA Monitoring.

bl.

This subject is addressed in the description of level I activities in Jection 2.1.3 and in Section 6.2.1.2.:hich describes Plant QA Monitoring.

h2&h3. The QA organization involvement in these areas is described in Section 6.2.1.

hh, The QA organization involvement in these areas is described in Sections 6.2.1 6.2,1 2.

h5 Appendix 3 identifies documents which are reviewed, approved or concurred with by the QAD, and also indicates whether such review, approval or concurrence is

~~

performed prior to implementation.

r.;; -

46.547.

Sections 6.2.1 and 6.2.1.2 describe the involvement of the QAD in these areas.

48.

Section 7.1 has been revised to comply with this co= ment.

49.

Sections 8.2.b and 8.2.e(2) have been modified to require QAD concurrence in the disposition of nonconformances.

The requirement for reinspection and close out is contained in 8. 2.e(4).

50.

Malfunctions resulting from material or manuf acturing deficiencies will be reported via the nonconformance reporting system. Technical Specifi-cations include provisions for reporting designated malfunctions to the Nuclear Regulatory Commission via Licensing Event Reports. These will not normally be duplicated on a nonconf ormance report.

51.

Section 9.2.e includes the requested coverage.

52.

The IMI QA organization is and will be suf ficiently staf f ed and managed to assure proper and effective implementation of the QA Program for TMI Unit 1 through the attention of the Vice President - Nuclear Assurance and the Manager of Q.A. in day-to-day activities at TMI-1.

This effort will assure that the QA staf f and its activities associated with IKI-l will not be diluted or compromised to support other activities and responsibilities outside of TMI-1.