ML20133F493
| ML20133F493 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, 05000000, Crane |
| Issue date: | 10/02/1985 |
| From: | Long R GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20133F496 | List: |
| References | |
| RTR-REGGD-01.037, RTR-REGGD-1.037 5211-85-2164, NUDOCS 8510110066 | |
| Download: ML20133F493 (10) | |
Text
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GPU Nuclear NggIgf 100 Interpace Parkway Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:
October 2, 1985 5211-85-21,64 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, Pennsylvania 19406
Dear Sir:
Subject:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
License No. DPR-50 Docket No. 50-289 Oyster Creek Nuclear Generating Station License No. DPR-16 Docket No. 50-219 GPUNC 0QA Plan Revision 1 In accordance with 10 CFR 50.54(a)(3), enclosed please find a complete copy of the "GPUNC 0QA Plan for TMI-l and Oyster Creek" (1000-PLN-7200.01) which contains Revision 1.
Since this change contains an exception (Item 1) to a commitment in the QA Program as previously accepted by the NRC (Ref. I and 2), NRC approval prior to implementation is required (or 60 days after submittal whichever is sooner for that change). All other items (2 thru 7) will be implemented on November 1, 1985. Specific changes to the QA Plan are identified in Attachment 1 and reasons for the changes are itemized below:
1.
An exception tv Reg. Guide 1.37 relating to permissible particle sizes was added to make a commitment consistent with requirements of ANSI N45.2.1-1980 for all particles instead of slivers only.
2.
Removing the requirement for issuing Stop Work on nonconforming materials or activities if "its repetitive failure to comply with program controls constitutes a significant QA Program deficiency" noted under Director, Quality Assurance responsibilities (1.6.1).
However, the Resolution of Disputes (2.9.7) was enhanced to include evaluating deficiencies for trends and the issuance of Stop Work if appropriate corrective action is not taken or planned.
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(i" GPU Nuclear is a part of the General Public Utilities System
7 Dr. T. E. Murley PAGE 2 3.
Organizations, responsibility and/or title changes requested by review comments or to reflect the most recent revision of the GPUNC Organization Plan.
4.
Clarifying exceptions to Regulatory Guides in Appendix C of the document.
5.
Referencing 10 CFR 20 related to radioactive waste in Section 2.2.
6.
Referencing Subpart H of 10 CFR 71 instead of Appendix E in Section 2.2.
7.
. Typographical error on Appendix C, Part 1, Page 115 under Regulatory Guide 1.39. We had a modified position noted; however, the matrix stated full compliance. The matrix has been updated to state the modified position.
This revision of the Operational QA Plan contains two additional changes which are evaluated as "significant" as per 2.3.2.2 of the 0QA Plan but which have been previously approved by the NRC and will be implemented on November 1, 1985. These changes are:
A.
Regulatory Guide 1.33 - Exception to Paragraph 5.2.2 of ANSI N18.7-1976 relating to temporary changes for procedures was added to be consistent with Technical Specifications.
B.
Regulatory Guide 1.58 - Clarifying QA personnel qualification requirements; NDE Level III in particular which was previously approved by the NRC in a letter dated January 16, 1985.
Finally, the revised QA Program as discussed in Revision 1 enclosed, continues to satisfy the criteria of 10 CFR 50 Appendix B and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC. The basis for this determination is that the changes described above in Items 2 thru 7 are, in general, administrative in nature and do not affect the quality or substance of the program as provided in Reference 1.
Items 1, A and B do not affect our satisfying of the criteria of Appendix B, but do alter our comn;itment in Reference 1 to bring it into conformance with other commitments.
Sincerely, R. L. Lor,
Vice Pr ent Nuclear ssurance RLL:gpa 2373f/001
Dr. T. E. Murley PAGE 3 cc: R. Conte NRS Resident Inspectcr Three Mile Island Nuclear Station Unit 1 Middletown, Pennsylvania 17057 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, New Jersey 08731 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Reference 1. GPUN Letter dated 5/23/83 (5211-83-159)
- 2. NRC Letter dated 8/3/83 d
0
F TEXT CHANGED IN 1000-PLN-7200.Oi REV 1-00 GPUNC Operational Quality Assurance Plan for Three Mile Island Unit I and Oyster Creek SEP 051985 PAGE PAGAGRAPH CHANGE
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i A. Added '10CFR20' B. Changed to 'iOCFR71, Subpart H' ii Changed "Vice President" to " Director' v
Page added.
1.0 1.1 Changed "Vice President" to Director *.
Changed " Maintenance and Construction" to
" Maintenance. Construction and Facilities" 2.0 1.3(a)
Changed to reflect GPUNC Organization Plan responsibilities.
1.4 Changed "Vice President" to " Director" Changed to reflect GPUNC Organization Plan responsibitities.
3.0 1.4 Changed "Vice President' to ' Director' Changed to reflect GPUNC Orqanization Plan responsibilities.
5.0 1.5 A.
Changed to ' Engineering Services-Director' B. Added ' Director - Engineering Assurance' 6.0 1.5.1 Former paragraph 1.5.1(k) deleted 1.5.2 Typo ' capability' 7.0 1.5.3(e)
Changed to reflect Organization Plan responsibiLitv.
1.5.4 Chanced "Vice President' to " Director' 8.0 1.5.4(9)
Changed to ' reportable' 8.0 1.5.5 Changed ' Manager - Engineerina Services' to
' Engineering Services Director' 9.0 1.5.7 Paragraph added 10.0 1.6 Changed "Vice President" to " Director" Changed to reflect GPUNC Organization Plan responsibilities.
11.0 1.6.1 Chanced "Vice President' to ' Director' l
12.0 1.6.i(e)
Deleted last subparagraph.
13.0 1.6.1(i)
Chanced 'Vice Presidents' to " Directors' 1.6.i(k)
Chanced "Vice President" to " Director" l
1.6.1.1 Added 'Ouality Assurance' i
l 4
l
15.0 1.6.3 Changed 'Vice President' to " Director" i.6.1.4 Added ' Quality Assurance' 16.0 1.6.1.4 Added 'OuaLity Assurance' 1.6.1.5(d)
Changed to ' program support' Chanced to procedures and personnel certification i.6.1.5(i) documents.'
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1.6.1.5(k)
Paragraph added 1.6.2 Changed "Vice President" to " Director" 17.0 1.6.1.5.(L)
Paragraph added 1.6.1.5(tast)
Paragraph added 19.0 1.7 Changed 'Vice President' to " Director' Changed to reflect GPUNC Organization Plan responsibilities and titles.
21.0 1.7.2 Changed to " Director Security" 22.0 1.7(a)
Revised for clari tY 1.7.3 Revised for clarity 1.7.4 Paragraph added 1.7.5 Paragraph added 23.0 1.8 Changed "Vice President' to ' Director' Changed to reflect GPUNC Organization Plan responsibilities and titles.
24.0 1.8.1 Changed to ' Safety and Environmental Controls Director' and revised for clarity 25.0 1.8.i(q)
Paragraph added 1.8.2 Revised for clarity 26.0 1.8.4 Paragraph added 27.0 1.9 Changed "Vice President' to " Director' Changed to reflect GPUNC Organization Plan responsibilities and titles.
28.0 1.9.1 Changed to " Director Maintenance Construction and Facilities' 29.0 1.9.2 Paragraph added. Paragraphs 1.9.2 thru 1.9.5 renumbered 1.9.3 Changed to ' Director Maintenance Construction and Facilities" 30.0 1.9.4 Changed to " Director Maintenance Construction and Facilities" 1.9.5 Changed to " Director Maintenance Construction and Facilities" 30.0 1.9.6 Changed to " Director Maintenance Construction and Facilities" 32.0 Figure i Revised to reflect current organization 1
r 33.0 Figure 2 Revised to reflect current organization 34.0 2.2 Added
.but is not limited to.'
2.2(c)
Changed ' Appendix E' to 'Subpart H' 35.0 2.2 A. Former paragraph (q) rep laced
~B.
Changed to 'Subpart H' C. Changed to 'The contents of the list will be
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controlled.'
D. Revised for clarity 2.2.1(c)
Paragraph added 38.0 2.3.1.1 A. Changed to " Maintenance. Construction and Facilities',
B. Changed to " Maintenance, Construction and Facilities",
1 39.0 2.3.2.1 Changed "Vice President" to " Director' 40.0 2.3.2.2 Changed "Vice President" to " Director" l
41.0 2.4 Changed "Vice Presidents' to " Directors' 44.0 2.8.2 Revised for clarity 2.8.3 Changed "Vice President' to
- Director' 45.0 2.8.4 Changed "Vice President" to " Director" 2.9.1 Added 'iOCFR20 and 10CFR71. Subpart H' 46.0 2.9.2 Changed "Vice President" to " Director"
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2.9.3 Changed "Vice President' to ' Director' 47.0 2.9.4 A. Changed "Vice President" to " Director" B. Changed to ' Director of Engineering. Assurance' 48.0 2.9.7 A. Changed "Vice President" to " Director" B. Paracraph added 49.0 3.1.1 Changed to ' drawings of a type appropriate to the circumstances and that...'
3.1.2(e) revised for clarity 31.0 3.2.2.1 Revised for clari ty 53.0 3.2.2.2(d)
Revised for clarity 3.2.3.1 A. Changed 'Vice President" to ' Director' B. Revised for clarity 54.0 3.2.3.2 Changed "Vice President" to " Director' 55.0 3.3.2(e)
Added 'should' 3.3.3.1 Changed "Vice President
- to " Director' 56.0 3.3.3.2 Changed "Vice President" to " Director" 3.3.3.3 A. Changed 'Vice President' to ' Director' B. Changed to "Hanager Information Management Centers" 37.0 3.3.3.4 Added 'or GPUN' 58.0 4.2.2 Revised for clarity l
/
4.2.3 Revised for clarity 60.0 4.3.1 Changed "Vice President" to " Director" 4.3.2 Changed 'Vice President" to ' Director' 4.3.2.1 A. Changed "Vice President" to " Director" B. Added and the Director-Engineering and Design" 4.3.2.1(b)
B. Added and the Engineering and Design Department" 61.0 4.3.2.2 Changed "Vice President" to " Director' 4.3.2.3 A. Changed "Vice President" to " Director" B. Changed to 'and the Director - Engineering Assurance' 4.3.2.4 Paragraph added.
4.3.3 Changed "Vice President' to " Director' 63.0 5.1.2.1(k)
Paragraph added 66.0 5.1.2.3(q.5)
Revised for clarity 5.1.3.1 Changed "Vice President" to " Director" 5.1.3.1(b)
A. Changed to ' requisitioners' B. Changed to ' contract / procurement' 67.0 5.1.3.1(c)
A. Typo ' contractual' B. Changed 'or' to 'and' 5.1.3.2 Changed "Vice President' to ' Director' 69.0 5.2.3.1 Added 'by QAD' 5.2.3.2 Changed "Vice President" to " Director' 5.2.3.3 Paragraph added 73.0 6.2.2.1 Changed "Vice President' to ' Director' 6.2.2.2 Changed "Vice President" to " Director" 75.0 6.3.2.1 Changed "Vice President' to " Director' 77.0 6.5.1.i(c)
Revised for clarity 79.0 6.5.2.1 Changed 'Vice President' to " Director' 6.5.2.1(b)
Paragraph added 6.5.2.2 Changed 'Vice President" to ' Director' 4.5.2.2(b)
Revised for clarity 6.5.2.3 Revised for clari ty 80.0 6.6.1.2(c)
Added ' plant instrumentation and' 82.0 6.6.1.2(i)
Chanced to 'in accordance with the industry code governing its use.'
84.0 6.7.2.2 Changed 'Vice President' to " Director' 6.7.2.3 Changed "Vice Presidents" to " Directors" 6.7.2.4 Changed to " Director-Maintenance. Construction and Facilities
- 85.0 6.8.1.2(f)
Added '/ variations' 86.0 6.8.1.2(f)
Added '/ variations' 6.8.2.1 Changed "Vice Presidents' to ' Directors' 87.0 6.9.2.1 Changed "Vice Presidents" to " Directors"
6.9.2.2 Changed 'Vice President' to " Director
- 88.0 6.10.1.2(c)
Added '/ variations' 6.10.1.2(f)
Revised for clari ty 6.10.2.1 Changed "Vice Presidents" to " Directors" 90.0 6.11.1.4 Revised for clari ty 6.11.1.5 Changed to "as designed"
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6.11.1.6 Changed to 'as designed' 91.0 6.11.1.9 A. Changed "Vice President" to " Director" D. Changed to " Maintenance, Construction and Facilities" C. Changed to 'the Authorized Inspection Agency' 6.11.2.1 Changed "Vice Presidents" to " Directors" 92.0 6.11.2.2 Changed 'Vice President' to " Director' 6.11.2.3 Changed to " Director-Maintenance Construction and Facilities' 93.0 6.11.2.4 Changed "Vice President" to " Director" 6.11.2.4(a)
Added 'or eq uiva lent work-rela ted documents' 94.0 6.12.1.3 Revised for clarity 6.12.2.1 Changed "Vice Presidents' to " Directors' 95.0 6.13.1.2 Revised for clari ty 6.13.2.1 Changed "Vice Presidents' to " Directors' 6.13.2.2 Changed "Vice President" to " Director" 96.0 7.1.1 Added ' Title 10. Part 20' 7.1.2 Changed to 'Subpart H' 7.2.1(b)
Revised for clari ty 97.0 7.2.1(c)
Revised for clarity 7.2.1(e)
Added 'and 10CFR20' 7.2.i(f' Added 'iOCFR20' 98.0 7.3.1 Chanced "Vice Presidents' to " Directors' 7.3.1(a)
Added '/ manifests' 7.3.2 Changed "Vice President" to ' Director' 7.3.3 Changed "Vice President" to " Director" 99.0 7.3.3(b)
Revised for clari ty 101.0 8.2.4 Changed to ' Licensee Event Reports require an Independent Safety Review.'
8.2.5(d)
Revised for clarity 102.0 0.2.5(f)
Revised for clarity 0.2.5(h)
Added 'mothod, verification' 8.2.6 Changed ' reinspected" to ' inspected' O.2.7 Revised for clarity 8.2.8 Deleted 'and adequacy' 103.0 0.3.1 Changed "Vice President" to " Director" 8.3.2 Changed 'Vice Presidents' to ' Directors' 8.3.2 Changed to
...are reported and corrected for all
Important to Safety activities.'
104.0 9.1(e)
Deleted 'utillize/'
106.0 9.2.7 Typo ' Audit' 107.0 9.3.1 Changed "Vice President" to " Director" 9.3.1(e)
Changed 'Vice President' to " Division Director'
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9.3.2 Changed "Vice Presidents" to " Directors" 110.0 App. A Replaced section for 10CFR71. Appendix E with section for 10CFR71, Subpart H 111.0 Revised for clarity 112.0 Revised for clarity 114.0 R.G.
1.8 Typo '1971' R.G.
1.29 Added 115.0 R.G.
1.39 Changed to 'See attached comments' 116.0 R.G.
1.143 Added 117.0 R.G.
1.8 Changed to ' ANSI /ANS 3.1-1978' 118.0 R.G.
1.33 Paragraph 2 added 119.0 R.G.
1.37 Added '-1973' 120.0 R.G.
1.37 A. Paragraph added B.
Paragraph added C. Added '-1973' D. Deleted last sub paragraph 123.0 R.G.
1.39 Typo
'of' Former para 3 deleted 125.0 R.G.
1.58 Revised to reflect ASME Code Cases.
131.0 Added definition of ' CALIBRATION' from MIL-STD-109D dated 1969 138.0 1.0 A.
Changed 'Vice President' to " Director' D. Added' Manager - Plans and Programs' 1.1 A. Changed "Vice President' to " Director' 139.0 1.0(J)
Paragraph added 1.2 Changed 'Vice President' to " Director' 1.3 Changed "Vice President" to " Director" 140.0 1.3(a)
Revised for c,larity 1.4 Paragraph added 141.0 Revised to reflect current organization 144.0 1.0 A.
Changed "Vice President" to " Director" D. Changed to ' Manager - Plant Materiel'
C. Changed to ' Manager - Plans and Programs' i.1 Changed "Vice President" to " Director
- Former paragraph 1.2 deleted 145.0 1.2 Changed "Vice President' to " Director' 1.2(k)
Paragraph added 1.2(L)
Paragraph added 1.3 Changed "Vice President" to " Director" 146.0 1.3(c)
Revised for clari ty 1.4 Paragraph added 147.0 1.6 A. Changed "Vice President' to " Director' B. Changed to ' Plans and Programs' i.6(d)
Revised for clari ty 148.0 Revised to reflect current organization
- - Significant Changes i-
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