ML20133F503

Rev 1 to 1000-PLN-7200.01, Gpu Nuclear Corp Operational QA Plan for TMI-1 & Oyster Creek

ML20133F503
Person / Time
Site:	Oyster Creek, 05000000, Crane
Issue date:	07/19/1985
From:	Fiedler P, Hukill H, Kazanas N GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20133F496	List: ML20133F493 ML20133F503
References
1000-PLN-7200.0, NUDOCS 8510110072
Download: ML20133F503 (157)

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{{#Wiki_filter:" " * * * ' ENuclear oeEaATIONAL QUALITY ASSURANCE AN 1000-PLN-7200.01

• GPUNC Operational Quality Assurance Plan for Three Mile Island Unit 1 and Oyster Creek 1-00 hYPlanhasGPUNC-WideApplicabilityExceptTMI-2 I'uaTItyk$u'rance 6100 This document is important to safety X Yes a No Effective Date List of Effective Pages November 1, 1985 I

See Page v for List of Effective Pages. I l l 05101100720 GOO 2 PDR ADOCK O 99 g PDR l P i Signature Concurnng Organizational E! ament Date l l Onginator /s/ N. C. Kazanas l Director Quality Assurance l 4/24/85 ! Concurred oy; /s/ H. D. Hukil1 j Dir. - TMI-l l 6/1/85 f i /s/ P. B. Fiedler { Dir. - Oyster Creek i 5/17/85 l A/C/[%nm 4e ML(cae l Dir. - Nuclear Assurance i 7/t /B r /s/M.F.Wibon l Oir. - Technical Functions 6/26/85 f M[Nb[44440 i Dir. - Maint., Const. & Facil. I 7/#/W /s/ R. P./jfasulo Dir. - Administration i 5/20/85 h /s/ R. W. Heward Dir. - Rad. A Env. Controls I 5/14/85 ~ /sl R. S. Renzi Sr. Anal. Admin. Proj./Org. Pol.' 5/20/85 f I [ [ b o,4, M Responsible Technical Reviewer 7//p/rf-V ~ a ^ Approv'd DY ((,[ joy Office of the President 7gp/ff-l r

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Nuclear OPERATIONAL QUALfTY ASSURANCE N d er PLAN 1000-PLN-7200.01 Title Revision No. INTRODUCTION 1-00 INTRODUCTION GPU Nuclear (GPUN) 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 assure compliance with 10CFR20; 10CFR50, Appendix B; 10CFR71, Subpart H; and applicable Regulatory Guides during the operation of TMI Unit I and Oyster Creek. This plan replaces the Operational Quality Assurance Plans for TMI Unit I and Oyster Creek. This Operational Quality Assurance Plan is formatted in such a manner as to provide all users with a functionally workable document. It is structured to describe how the Quality Assurance Program is to be functionally implemented with due regard to the safety and health of the public and the personnel on site. The Plan contains a description of the organizations responsible for the implementation of the Quality Assurance Program (Section 1) and an overall description of the Program (Section 2). The remaining sections are structured in a functional manner. The requirements for administrative controls are generic and apply to all subsequent 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 program requirements for those direct and supportive important to safety activities associated with the operation and safety of all plants; construction and/or modifications associated with corrective maintenance, plant improvement, and/or repair; and the processing 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 and 9.0 again apply to all functions covered by the scope of this Quality Assurance Program. Section 8.0 addresses the identification and disposition of nonconformances associated with all aspects of the Program. In addition, this section contains the management controls provided for evaluating collectively all quality nonconformances and determining what corrective actions should be taken to preclude their recurrence. Section 9.0 contains the requirements and administrative controls g applicable to audits. Appendices A, 8 and C contain additional Quality Program requirements associated with the functional areas discussed in the Plan, 7. Appendix D contains the definitions of terms used throughout the Plan. 5 9 2 Supplements to this Quality Assurance Plan are provided for each operating unit. 3 These supplements contain the requirements which are unique to the specific unit and which are in addition to the requirements contained in this Plan. The f Supplements must be used in conjunction with the Plan contained herein, a2 AOOOt050tt 82

/ Number Nuclear PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. TABLE OF CONTENTS 1-00 TABLE OF CONTENTS Page INTRODUCTION i TABLE OF CONTENTS 11 LIST OF CFFECTIVE PAGES/ RECORD OF REVISIONS v 1.0 ORGANIZATION 1.1 President GPUN 1 1.2 Executive Vice President 2 1.3 Office of President 2 1.4 Directors TMI-1, and Oyster Creek 2 1.5 Director Technical functions 3 1.6 Director Nuclear Assurance 9 1.7 Director Administration 18 1.8 Director Radiological and Environmental Contrcls 22 1.9 Director Maintenance and Construction 25 2.0 QUALITY ASSURANCE PROGRAM 2.1 General 33 2.2 Scope 33 2.3 Operational Quality Assurance Plan 35 2.4 Quality Assurance Program Review 41 2.5 Indoctrination and Training 41 2.6 Classification 42 2.7 Regulatory Commitments 43 2.8 Safety Reviews 43 2.9 Responsibilities 45 3.0 CONTROL 0F DOCUMENTS AND RECORDS 3.1 Instructions, Procedures, Drawings and Policies 48 [* 3.2 Document Control 50 3.3 Quality Assurance Records 53 5 s AOOO1050t1 82 L

Number Nuclear OPERATIONAL QUALITY ASSURANCE gtAN iOOO.glN.,200.0i Title Revision No. TABLE OF CONTENTS 1-00 TABLE OF CONTENTS gCONTINUED) Page 4.0 DESIGN CONTROL 4.1 Policy 57 4.2 Requirements 57 4.3 Responsibilities 59 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement 61 5.2 Identification and Control of Materials, Parts and Components 67 6.0 CONTROL 0F STATION ACTIVITIES 6.1 Policy 69 6.2 Control of Inspections 70 6.3 QA Monitoring 73 6.4 Control of Special Processes 75 6.5 Test Control 76 6.6 Control of Measuring and Test Equipment 79 6.7 Handling, Storage and Shipping 81 6.8 Inspection, fest and Operating Status 83 6.9 Housekeeping and Cleanliness 85 6.10 Equipment Control 86 6.11 Control of Construction, Maintenance 87 gPreventive/ Corrective) and Modifications 6.12 Control of Surveillance Testing and Inspection 92 6.13 Radiological Control 93 5 7.0 CONTROL OF RADI0 ACTIVE WASTES k 7.1 Policy 95 5 7.2 Requirements 95 6 7.3 Responsibilities 96 s k o 2 AOOO105011 82 iii l 6

Number Nucler o'ea^r10NAL QUALITY ASSURANCE A" 1000-PLN-7200.01 Title Revision No TABLE OF CONTENTS 1-00 TABLE OF CONTENTS gCONTINUED) Page 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 Policy 99 8.2 Requirements 99 8.3 Responsibilities 102 9.0 AUDITS 9.1 Policy 103 9.2 Requirements 103 9.3 Responsibilities 106 APPENDICES: Appendix A - Comparison Chart of Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regu-lations and Nuclear Industry Standards 109 Appendix 8 - QAD Management Control Requirements for "Important to Safety" Documents 110 Appendix C - NRC Regulatory Guide Commitments and Exceptions 112 Appendix 0 - Terms and Definitions 130 SUPPLEMENTS: I - Three Mile Island Nuclear Station Unit 1 135 II - Gyster Creek Nuclear Generating Station 141 C ?< 5 2 L' 3< e A000105011 82 2.

NUCI68r PERATION3L QUALITY ASSURANCE ptan icoo_ pen _7200.01 Title Revision No. LIST OF EFFECTIVE PAGES/ RECORD OF REVISIONS 1-00 LIST OF EFFECTIVE PAGES Page Rev. Content Page Rev. Content Page Rev. Content Page Rev. Content No. No. Changed No. No. Changed No. No. Changed No. No. Changed 0.0 1-00 35.0 1-00 75.0 1-00 115.0 1-00 1 1-00 36.0 1-00 76.0 1-00 116.0 1-00 I ii 1-00 37.0 1-00 77.0 1-00 117.0 1-00 iii 1-00 38.0 1-00 78.0 1-00 118.0 1-00 iv 1-00 39.0 1-00 79.0 1-00 119.0 1-00 v l-00 40.0 1-00 80.0 1-00 120.0 1-00 1.0 1-00 41.0 1-00 81.0 1-00 121.0 1-00 2.0 1-00 42.0 1-00 82.0 1-00 122.0 1-00 3.0 1-00 43.0 1-00 83.0 1-00 123.0 1-00 4.0 1-00 44.0 1-00 84.0 1-00 124.0 1-00 5.0 1-00 45.0 1-00 85.0 1-00 125.0 1-00 6.0 1-00 46.0 1-00 86.0 1-00 126.0 1-00 7.0 1-00 47.0 1-00 87.0 1-00 127.0 1-00 8.0 1-00 48.0 1-00 88.0 1-00 128.0 1-00 9.0 1-00 49.0 1-00 89.0 1-00 129.0 1-00 10.0 1-00 50.0 1-00 90.0 1-00 130.0 1-00 11.0 1-00 51.0 1-00 91.0 1-00 131.0 1-00 12.0 1-00 52.0 1-00 92.0 1-00 132.0 1-00 1 13.0 1-00 53.0 1-00 93.0 1-00 133.0 1-00 14.0 1-00 54.0 1-00 94.0 1-00 134.0 1-00 15.0 1-00 55.0 1-00 95.0 1-00 135.0 1-00 l 16.0 1-00 56.0 1-00 96.0 1-00 136.0 1-00 1 17.0 1-00 57.0 1-00 97.0 1-00 137.0 1-00 18.0 1-00 58.0 1-00 98.0 1-00 138.0 1-00 19.0 1-00 59.0 1-00 99.0 1-00 139.0 1-00 20.0 1-00 60.0 1-00 100.0 1-00 140.0 1-00 21.0 1-00 61.0 1-00 101.0 1-00 141.0 1-00 22.0 1-00 62.0 1-00 102.0 1-00 142.0 1-00 23.0 1-00 63.0 1-00 103.0 1-00 143.0 1-00 24.0 1-00 64.0 1-00 104.0 1-00 144.0 1-00 25.0 1-00 65.0 1-00 105.0 1-00 145.0 1-00 26.0 1-00 66.0 1-00 106.0 1-00 146.0 1-00 27.0 1-00 67.0 1-00 107.0 1-00 147.0 1-00 28.0 1-00 68.0 1-00 108.0 1-00 148.0 1-00 29.0 1-00 69.0 1-00 109.0 1-00 RECORD OF REVISIONS 5 30.0 1-00 70.0 1-00 110.0 1-00 31.0 1-00 71.0 1-00 111.0 1-00 EFFECTIVE 7. 32.0 1-00 72.0 1-00 112.0 1-00 REVISION DATE 5 33.0 1-00 73.0 1-00 113.0 1-00 34.0 1-00 74.0 1-00 114.0 1-00 0 09/01/82 0A 02/16/83 4

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• INDICATES PAGES CONTAINING CONTENT CHANGES IN THIS REVISION.

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ENuclear Number OPERATIONAL QUALITY ASSURANCE N 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 1.0 ORGANIZATION Policy It is the policy of GPUN to maintain, and operate the THI-l and Oyster Creek nuclear generating stations in such a manner as to ensure the safety and health of the public and the personnel on site. To implement this policy, GPUN will meet the applicable quality assurance requirements of the Nuclear Regulatory Commission as presented in the Code of Federal Regulations and applicable Regulatory Guides, codes and standards; the State of New Jersey's Board of Boiler and Pressure Vessel and Refrigeration Rules, Subchapter 3 (Boiler Construction and Inspection); the ASME Boiler and Pressure vessel Code as applicable to the States of New Jersey and Pennsylvania; other pertinent federal, state and local quality assurance regulatory requirements; and the GPUN corporate policies. To comply with these requirements, the Office of the President has authorized the establishment of a formal and comprehensive Quality Assurance Program. This Program, which is described in the following sections and the attached supplements, shall be implemented through documented and approved policies, procedures and instructions which comply with this Plan. Responsibilities The general structure of the organizational elements responsible for the operation, maintenance, modification, repair, inservice inspection and refueling of the nuclear generating stations is illustrated in Figure 1. This organization chart identifies those functions normally located on site and off site. The GPUN Organization Plan sets forth specific responsibilities and the implementing procedures identify interface requirements. 1.1 President - GPUN The President - GPUN has the overall responsibility for the establishment, implementation and effectiveness of the Quality Assurance Program applicable to TMI Unit 1, and Oyster Creek. This responsibility is administered through his management staff, including: Executive Vice President - GPUN Director - Technical Functions Director - Nuclear Assurance 5 Director - Administration Director - Radiological & Environmental Controls Director - Maintenance, Construction and Facilities 3 Director - TMI Unit 1 3, Director - OCNGS l 1.2 Executive Vice President - GPUN The Executive Vice President - GPUN reports directly to the President - GPUN and shares in the duties and responsibilities of the Office of the 2 Prcildent_ A00010 M 11 82 1.0

gggy 0PERATIONAL QUALITY ASSURANCE Nunter PLAN 1000-PLN-7200.01 Titte Revision No. 1.0 ORGANIZATION 1-00 1.3 Office of the President The President and the Executive Vice President constitute the Office of the President. The two officers work in close cooperation and share the executive duties of GPUN. As used in this plan, the Office of the President means either the President or the Executive Vice President. The Office of the President is responsible for the following major functions: Provide a full-time dedicated management for the purpose a. of conducting all nuclear activities of the system safely and effectively. b. Provide uniform policies and operational criteria for the operation of the nuclear facilities owned by the GPU Subsidiaries. 1.4 Director - TMI Unit I, and Oyster Creek Each of the Directors of the nuclear generating stations reports to the Office of the President. They each give their full support to the quality assurance requirements set forth in this Quality Assurance Plan and its supplements, assuring compliance to the fullest degree by their respective staffs. They are each responsible to operate and maintain their respective generating station in a safe, reliable and efficient manner in accordance with corporate policies and all applicable laws, regulations, licenses and technical requirements. The Division Director - Oyster Creek is the senior GPUN representative at Oyster Creek and as such assures consistent implementation of policies and procedures at the plant and at GPUN off-site facilities in the Oyster Creek area. The Division Director - THI-l is the senior GPUN representative at the TM1 site and as such assures consistent implementation of policies and procedures at the plant and at GPUN off-site facilities in the TMI area. The Division Director - TMI-l can transfer this responsibility to the Director-fMI-2, with his agreement, for specific matters on time periods. The Directors are responsible for the following major functions: j a. Operate the plant. b. Provide and maintain qualified staff. E c. Establish cardinal dates for plant evaluations and outages. h d. Control the scope of work in the plant. g 1 A00010$0tt 82 2.0

l Number gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 1 Revision No. 1.0 ORGANIZATION 1-00 d. Define and astablish priorities for the preventive and corrective maintenance and refurbishment work needed to ensure good material condition. f. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division. I g. Develop, gain approval, and operate within approved annual budget, annual operating plan, and the multi-year strategic plan. h. Establish day to day priorities for plant support. 1. Develop and maintain effective consultation and advise with other Divisions to help assure efficient functioning of GPU Nuclear. The organizational staffs of TMI-l and Oyster Creek and *. heir specific responsibilities are contained in Supplements I and II. 1.5 Director - Technical Functions The Director - Technical Functions reports directly to the Office of the President. He is responsible to provide engineering to assure uniform technical and regulatory adequacy of all aspects of nuclear activities, except TMI-2, to provide safe, reliable and efficient operations in accordance with Corporate Policies and all applicable laws, regulations and licenses. The major functions' of the Technical functions division are as follows: Perforn, manage and direct all out-of-plant engineering, a. design and safety analysis. b. Provide and maintain a qualified staff. Provide technical configuration control for the plants. c. d. Maintain all plant technical basis and configuration control documents. 5 Control and perform interface activities with e. ,~. non-financial regulatory groups. s g f. Perform plant technical monitoring / assessment / productivity analysis, including g mijor equipment failure analysis. l i A00010$0tt 82 3.0 l

OPERATIONAL QUALITY ASSURANCE Number E I PLAN 1000-PLN-7200.01, Title Revision No. 1.0 ORGANIZATION 1-00 g.' Prepare / review and approve all engineering and licensing procedures and licensing document correspondence and f prepare SAR's, Technical Specifications and Environmental specifications. h. Plan, specify and control hardware and software for plant process, simulation and other real time plant computer applications. i. Provide overall fuel management for the plant.

j. Specify, manage, direct all nuclear fuel material, conversion, enrichment and fabrication contractors.

k. Review and assess the safety significance of operating experience from NRC notices, bulletins, industry ( reports, etc. and, provide recomendations for needed actions. 1. Provide and direct operating plant shift technical advisors. m. Review and concur in all plant operating and emergency procedures and selected other procedures for technical adequacy. n. Provide project engineering for Technical runctions' sponsored activities and others, as agreed. o. Review training programs for technical content, as appropriate, and provide technical input for modifications. p. Plan / direct all startup and test activities, q. Prepare /recomend/ control GPU Nuclear capital budget for plant modifications and studies. r. Manage and provide chemistry and metallurgical analytical services for 0.C., TMI and the system GPU g fossil stations. f, s. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division. E t. Develop, gain approval and operate within approved 3 annual budget, annual operating plan, and the multi-year strategic plan, b 1 A0001050t1 82 4.0

Nder OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 u.' Develop and maintain effective consultation and advice with other Divisions to help assure efficient j functioning of GPU Nuclear. v. Take the lead and coordinate the development of a long range plan for the O.C. and TMI-l plants. The Director - Technical Functions and his staff give full support to the Quality Assurance Program described herein, thereby assuring that all work performed under their cognizance will conform to and support the requirements of the Plan. The Director - Technical Functions utilizes the following l management staff members in carrying out his responsibilities: Director - Engineering and Design Director - Systems Engineering Director - Engineering Projects Director - Licensing and Regulatory Affairs Engineering Services Director (, Director - Startup and Test Director - Engineering Assurance l 1.5.1 Director - Engineering and Design The Director - Engineering and Design is responsible for pro-viding a centralized technical capability in the conventional engineering disciplines and is responsible for the technical performance of components and systems in the plants within their area of expertise. The major functions of the Engi-neering and Design department are as follows: a. Provide design drawings and specifications in support of plant modifications. b. Maintain central GPUN technical capability in disci-plines assigned to the department. c. Investigate plant system and equipment failures, retain cognizance over technical performance of plant hardware. O d. Provide Technical Functions review / concurrences of main-tenance programs / procedures, as appropriate. 7; e. Provide Technical Functions review / approval of work performed by outside engineering firms, as appropriate. f. Support plant outages within overall GPUN priorities. 2 A0001050i1 82 5.0

h ENuclear o'eaarto"Al QUAllTY ASSURANCE Number PLAN 1000-PLN-7200.01 i Title Revision No. 1.0 ORGANIZATION 1-00

g. ' Perform GPUN engineering in support of design within technical disciplines assigned to the department.

h. Provide fire protection analyses. 1. Provide the generating stations with chemistry and metallurgical analytical services. J. Provide chemistry requirements, specifications and engineering support. 1.5.2 Director - Systems Engineering The Director - Systems Engineering is responsible to provide special analytical skills in reactor physics, plant dynamics, risk analyses, human engineering, and process computers. He provides full time, in plant capability in support of opera-tions and is a key contributor to the review of operating pro-cedures, plant performance and training programs. The major functions of Systems Engineering are to: a. Analyze overall GPUN plant technical performance, review industry plant data, and advise Plant Director and others of status and potential problems. b. Provide all nuclear fuels, fuel management strategies, and basic core physics capability. c. 8e a principal contributor to and coordinate the review of operating, alarm and emerge.ncy procedures, and the technical content of training programs, d. Provide technical expertise in risk analysis, human factors engineering, radiological engineering, and plant dynamics and simulation. e. Staff, operate, program and upgrade plant process com-

puters, f.

Staff and direct Shift Technical Advisors. i g. Support development of plant Quality Classification 7; Lists. 5 k< Eo A000105011 82 6.0

ENuclear Nun 10w OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200,01 Title Revision No. 1.0 ORGANIZATION 1-00 1.5.3 Director - Engineering Projects The Director - Engineering Projects is responsible to manage all operating nuclear station engineering projects to insure completion of every authorized project in a technically compe-i tent manner, on time and at the most reasonable cost consistent with safety, quality and schedule requirements. The major functions of the Engineering Projects department are to: a. Manage, coordinate or direct the engineering effort required for any nuclear station physical plant modifi-cation, addition or major nonroutine repair, b. Manage, coordinate or direct, as appropriate, long term j planning engineering studies or evaluations. c. Provide on-site coordination of Technical Functions division personnel and activitics (except full-time on-site functional personnel directly supporting opera-tions, i.e., startup and test computers, Shift Technical Advisors, plant analysis and licensing). d. Recommend and function in accordance witn approved priorities.for engineering projects. e. Provide project engineering for Technical Functions' sponsored activities and others, as agreed. 1.5.4 Director - Licensino and Regulatory Affairs The Director - Licensing and Regulatory Affairs reports directly to the Director - Technical Functions. He is l responsible to assure the continued licensability of the operating plants and to provide a technically consistent interface with the various regulatory agencies. The major functions of the department are: a. Provide the principal interface with regulatory agencies interfacing with GPUN and manage GPUN participation in licensing hearings. 5 b. Obtain all 1.icenses and permits for nuclear facilities: 7. federal, state and local. 2 c. Prepare and coordinate responses to regulatory agencies, 2 including NRC I&E Bulletins, Circulars, Notices and g ) Inspections. i 2 A000105011 82 7.0

""'"b N w b r' OPERATIONAL QUALITY ASSURANCE N 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 d.' Provide licensing guidance and interpretation for all aspects of GPUN regulated activities, includin coordination with legal counsel, as necessary,g the e. Provide systems for control of licensing basis documents--Technical Specifications, SAR's, Regulatory Guides, Standard Review Plans. f. Negotiate, within limits established by management, with regulatory agencies on requirements, schedules or commitments. g. Coordinate the evaluation and reporting of reportable l items under Technical Specifications, NPOES permits, 10CFR21, 10CFR50 or other regulations or licenses. h. Provide principal interface with NRC's inspection and enforcement inspector, resident inspectors and industry agencies. Resolve issues in apparent conflict with licensing or permit documents or GPUN licensing posi-tions. i. Concur with important to safety design criteria documents from the standpoint of having addressed all applicable regulatory requirements and licensing conunitments. j. Exercise administrative control of amendment requests to the Safety and Environm'ent Technical specifications and the FSAR in accordance with 10CFR. 1.5.5 Engineering Services Director Engineering Services Director is responsible to provide the engineering management tools and systems to the Technical functions Division to permit efficiency of operations and to provide the interface between the Technical Functions adminis-trative systems and those within GPUN. Following are the major functions of the Engineering Services Department: 5 a. Prepare and coordinate all engineering and licensing procedures and standards. 5 b. Provide basic engineering data files. c. Provide technical document release system and configura-l tion control methods. _9 io A0001050I1 82 8.0

E Nder OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 1.0 ORGANIZATION 1-00, d. Perform all GPUN design and drafting and prepare as-built drawings within configuration control { guidelines. 1.5.6 Director - Startup and Test I The Director - Startup and Test is responsible to provide and perform a startup and test function for GPUN during refuelings and major outages to assure new or substantially modified plants, facilities and systems are systematically tested, docu-mented to conform with technical requirements, and turned over to plant operations. The major functions of the Startup and Test Department include: a. Prepare test plans and implementing procedures, b. Direct testing, ensure operations and other supporting personnel have required special training and skills for testing. c. Insure preparation of test documentation, review and compile same for turnover to operations. d. Coordinate technical acceptance of testing. e. Provide and obtain a testibility review of design engineering of plant modifications. 1.5.7 Director - Engineering Assur5nce The Director-Engineering Assurance is responsible to develop and implement GPUN-Wide programs to ensure compliance with fire protection and environmental qualification of equipment requirements, and to develop lists and administrative controls to address quality classification, engineering data and vendor documentation. The major functions of the Engineering Assurance Department include: a. Ensure electrical components required for shutdown are qualified to environmental qualification requirements. D b. Establish and implement system to maintain 10CFR50, ~. Appendix R compliance and overall fire hazards analysis. = 5 c. Establish and maintain a component level quality classification list for each plant. 0 2 k a L h A0001050tI 82

9. 0

Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 1 d.' Establish and maintain a computer oriented GPUN technical data base at the component level, e. Provide a central source for maintaining critical engineering data. f. Establish and develop a system for vendor control. 1.6 Director - Nuclear Assurance The Director - Nuclear Assurance reports directly to the Office of the President and is responsible to ensure that an appropriate Quality Assurance Program whose scope covers all the systems and activities that affect safety and reliability is established, implemented and verified in accordance with Corporate Policies, applicable laws, regulations, licenses and technical requirements; selectively review both nuclear station and Corporate activities with the aim of identifying areas where changes could lead to improvements in the nuclear safety and/or reliability of plant operations; provide training and education of corporation personnel as needed to carry out their duties and to meet Corporate Policies and all applicable laws, regulations, licenses and technical requirements; assure that a high level of emergency preparedness is maintained in accordance with Corporate Policies and all applicable laws, regulations, licenses and technical requirements. The major functions of the Nuclear Assurance Division are as follows: a. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division, b. Provide and maintain qualified staff. c. Develop, gain approval and operate within approved annual budget, annual operating plan, and the multi-year strategic plan. d. Audit, monitor, inspect, evaluate and assure that all activities having the potential for compromising nuclear safety are adequately addressed. 5 e. Develop and implement necessary training programs. k f. Develop the site emergency plans, implement procedures and plan, conduct and evaluate emergency drills. j g. Develop and maintain effective consultation and advice with other divisions to help assure efficient 9 functioning of GPU Nuclear. 3 2 A000105011 82 10.0

) Number Nuchr o'ea^rIONAL QUALITY ASSURANCE 1000-PLN-720 PLAN ~ Title Revision No. 1.0 ORGANIZATION 1-00 The Olrector - Nuclear Assurance gives his full support to the l-quality assurance requirements set forth in this Operational ( Quality Assurance Plan, assuring compliance to the fullest degree by his staff. The Director - Nuclear Assurance utilizes the following l management staff members in carrying out his responsibilities: Director - Quality Assurance Director - Training and Education Nuclear Safety Assessment Director Manager - Emergency Preparedness 1.6.1 Director - Quality Assurance gFigure 2) The Director - Quality Assurance Department gQAD) has the functional authority, independence and responsibility to verify the effective implementation of the administ'*ative controls and compliance to the Quality Assurance Program. The Director of QA0 reports directly to the Director - Nuclear Assurance. Additionally, he 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 provide the Quality I Assurance organization with sufficient independence from the influence of costs and schedules to be able to effectively j assure conformance to Quality Assurance Program requirements. 4 Figure 2 identifies the Quality Assurance Department organizational elements which' function under the Quality Assurance Program. The Director - QA0 has no duties or responsibilities unrelated to Quality Assurance that would prevent his full attention to quality assurance matters. He has the authority and responsibility to: a. Develop and administer the Operationel Quality Assurance j Plan and procedures required to assure that all GPUN activities provide the required high degree of safety and reliability. b. Audit, monitor, inspect and evaluate activities of GPUN 5 to assure that they provide the required high degree of safety and reliability and are carried out in accordance 5 with all applicable laws, regulations, licenses, coroorate policies and other requirements. ~ O c. Identify quality problems and initiate, recomend or 9 l provide solutions through designated channels and verify implementation of resolutions. 0 n 9 0 0 A000t050t1 82 11.0

3 Nuclear OPERATIONAL qualm ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 d '. Perform evaluations on a planned and periodic basis to verify that the Quality Assurance Program is being ( effectively implemented. Stop work on nonconforming materials or activities if: e. 0 it is the only process available to protect the health and safety of the public and/or plant personnel; O its continuance will require significant rework or repair to backfit corrective action; O its continuance may jeopardize nuclear safety. [ f. Initiate unit shutdown recomendations when warranted by a safety concern. ~ j l g. Direct and manage the Quality Assurance Department. ] The major functions of the Quality Assurance Department include the following: g 1.6.1.1 a. Develop the Operational Quality Assurance Plan and pro-cedures necessary to fulfill GPUN QA responsibilities. b. Provide for the monitoring and evaluation of the imple-( mentation and effectiveness of the GPUN QA Program by means of: f Review Surveillance Survey Monitoring Audit Inspection of all organizations, contractors and vendors for all important-to-safety activities. Stop work or further processing, delivery or installa-c. tion or take other warranted actions on nonconforming materials or activities. E d. Initiate unit shutdown recomendations when warranted by a safety concern and obtain unit shutdown with appro- <+ priate upper-management concurrence. o N e. Provide for the review and acceptance of Contractor and l Vendor Quality Assurance Programs within the scope of f the GPUN Quality Assurance Program, a 2 A00ol050tI 82 12.0

Nuniber NWar OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 f'. Provide for the review and acceptance of procedures prepared by other than QA organizations within the scope of the Quality Assurance Program. g. Provide a working interface and line of communication with other divisions and other appropriate industry and regulatory groups for all QA matters. h. Establish with Training and Education Department the scope and content of an indoctrination and training program for QA and QC personnel. 1. Assure QA indoctrination of appropriate personnel out-side of the QA organization is provided. J. Issue periodic reports to the Office of the President and appropriate Uqit Directors on the status of quality ( activities. k. Immediately notify the Office of the President and approoriate Unit Director of an related problem or deficiency. y significant quality l 1. Provide for QA review and acceptance of design and engi-neering documents. m. Provide for QA review and acceptance of procurement documents within the s, cope of the QA program, Provide for and maintain QA records generated by QA0 n. until turnover to document control for storage. The Director - Quality Assurance utilizes the following manage-ment staff members in carrying out his responsibilities: Manager-Quality Assurance Design and Procurement Manager-Quality Assurance Modifications / Operations - TMI Manager-Quality Assurance Modifications / Operations - Oyster Creek g Manager-Quality Assurance Program Development and Audit l Manager-Special Processes and Programs 5 1.6.1.2 Manager - Quality Assurance Design and Procurement 0 0 The Manager - Quality Assurance Design and Procurement is l responsible to: 1 1 A0001050tt 82 13.0 i

NucIear OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Rsvision No. 1.0 ORGANIZATION 1-00 a.* Review and approve contractor and vendor quality pro-grams fo-those supplying important-to-safety services or items. b. Report quality trends to the Director - QA and to the cognizant purchasing or contract manager, Review and accept design control procedures prepared by c. other organizations when these procedures control or exercise an effect upon important-to-safety systems, components or activities. d. Perform the necessary post-award quality related activi-ties, including post-award surveys and source surveil-lance, in compliance with this Quality Assurance Program. ( e. Coordinate with the Site QA Modifications / Operations Sections to assure that dncumentation of manufacturing discrepancies is available to the receiving inspectors and the cognizalt purchasing or contract manager. f. Identify qua;ity prot,lems; initiate, recommend or pro-vide solutions through designated channels; and verify implementation of the resolutions, g. Review engineering specifications and procurement docu-l ments to assure quality requirements are incorporated. I 1.6.1.3 Manager - Quality Assurance Modifications / Operations I A Manager - Quality Assurance Modifications / Operations is assigned to the TMI and Oyster Creek nuclear generating stations. Each Manager is responsible for the following, as applicable to the designated station: a. Monitor the implementation and effectiveness of the Quality Assurance Program on site. b. Establish adequate site monitoring and inspection pro-grams necessary to verify conformance to Quality g Assurance Program requirements. ?. c. Coordinate and' direct QA activities at the assigned 3 nuclear station. 2 2 d. Review engineering specifications and procurement docu-g ments to assure quality requirements are incorporated. O_ 3 A0001050I1 82 14.0 i

) Neer Nder OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 i Title Revision No. 1.0 ORGANIZATION 1-00

e. ' Provide nondestructive examination support for modifica-tions, maintenance and ISI.

f. Notify appropriate station management and the Director - Quality Assurance imediately of any condition, as defined in the appropriate QA0 procedures, that warrants operational shutdown of the unit. g. Identify quality problems; initiate, recommend or pro-vide solutions through designated channels; and verify implementation of the solutions. Each Manager - Quality Assurance Modifications / Operations reports directly to the Director - Quality Assurance and periodically reports on the implementation and effectiveness of the Quality Assurance Program to the Unit Director and the l Director - Quality Assurance. Each Manager-Quality Assurance Modifications / Operations has the authority to stop work on all important-to-safety activities associated with the on-site 'Juality Assurance Program. 1.6.1.4 Manager - Quality Assurance Program Development and Audit i The Manager - Quality Assurance Program Development and Audit is responsible to: 1 a. Coordinate the development and maintenance of the i Operational Quality Assurance Plan and the QA0 pro-cedures. b. Coordinate the development and administration of the QA0 training and certification program. c. Coordinate the QA training and indoctrination provided for GPUN and external organization personnel. d. Develop, implement and maintain a comorehensive system cf planned and periodic audits to verify compliance with all aspects of the Quality Assurance Program. 5 e. Identify quality problems; initiate, recommend or pro-vide solutions _ through designated channels; and verify imolementation of the resolutions. l \\ 1 1 A000l0SO1f.82 15.0

r OPERATIONAL QUALITY ASSURANCE Number Nuclear gun iOOO-ptN-n00.0i Title Revision No. 1.0 ORGANIZATION 1-00 The Manager - Quality Assurance Program Development and Audit [ maintains a fulltime staff of quality assurance engineers and qualified auditors at both the corporate and site offices. The audit activities and the results of the audits are provided to the audited organization and to the Safety Review Groups who provide the independent management assessments of the significance of the audit findings and the effectiveness of the Quality Assurance Program. 1.6.1.5 Manager - Special Processes and Programs The Manager - Special Processes and Programs is responsible to: a. 01 rect and supervise the GPUN organizations which have the responsibility for weld engineering. b. Establish the requirements for weld programs consistent with specification a,nd engineering requirements, in-service inspection of piping and components, NDE, materials support and materials evaluation. c. Develop the ISI programs at each station excluding IST, hydro testing, leak testing and functional tests. d. Provide program support for IST, hydro testing, leak l testing and functional tests. e. Provide welding engineering support. f. Identify quality problems; initiate, recomend and pro-vide solutions through designated channels; and verify implementation of the resolutions, g. Provide support related to manufacturing and systems materials technology problems. h. Provide technical requirements for weld repair and weld repair programs. 1. Develop and implement certification program for GPUN NDE g personnel. f, J. Review and approve contractor NDE programs, procedures and personnel certification documents. 6 k. Prepare and maintain procedures and qualifications for 3 welding. 4 1 A000t050It 82 16.0

N I I PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 1/ Establish the requirements for GPUN nondestructive examination activities consistent with engineering requirements. The Manager - Special Processes and Programs, through a full-time staff of qualified engineering personnel at both the corporate and site offices, establishes the engineering and technical requirements for the welding, Inservice Inspection, and Nondestructive Examination programs for GPUNC. The Special Processes and Programs activities provide effective interfaces and technical support efforts with and for other GPUNC Divisions. 1.6.1.6 Minimum Qualifications of Quality Assurance Personnel The Director - Quality Assurance shall have, as a minimum, a baccalaureate degree in Engineering or Science, with at least five years of QA experience in nuclear power plant operations or supporting activities. Additionally, the Director - Quality Assurance must be knowledgeable in QA regulations, policies and standards. The qualification requirements and experience levels for other key Quality Assurance personnel are such as to assure competence consnensurate with the responsibilities of each position. Quality Assurance Department Section and Sub-section Managers are required to have a degree in Engineering or Science and experience in a position having responsibility for the performance of quality activities. The degree requirement may be waived for personnel with exceptional qualifications and a minimum of seven g7) years of related experience. l.6.2 Director - Training and Education The Director - Training and Education reports directly to the Director - Nuclear Assurance. He has the overall authority and ( responsibility for providing training of corporation personnel, as needed, to carry out their duties and to meet corporate policies and all applicable laws, regulations, licenses and technical requirements. The Director - Training and Education 5 is responsible for the.following major function: ?. Develop and imp'lement all necessary general employee, a. g operator, technician and management training programs. b I A000105011 82 17.0 l

) ""'"D*' Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-M00.01 Title Revision No. 1.0 ORGANIZATION 1-00 1.6.3 Nuclede Safety Assessment Director The Nuclear Safety Assessment Director is responsible for the development, direction and supervision of the Nuclear Safety Assessment Department tNSAD). The primary responsibilities of the Nuclear Safety Assessment Director are to identify problems in nuclear plant design, operations and maintenance which have a potential for compromising overall safety of the nuclear plant, station personnel or the general public and to make recommendations for improvements and assure corrective actions are taken to resolve identified problem areas. The NSAD will have access to documents and reports including those identifying conditions adverse to quality gaudit reports, nonconformance reports surveillance / inspection reports, reportable occurrences,, NRC inspections, etc.). An independent office of Ombudsman is located within the NSAD. This office is available to all members of the corporation having a concern for nuclear or radiation safety. Additionally, NSAD, working with the Technical functions Systems Engineering Department, will evaluate the operational I experience of other nuclear power stations to improve plant operational status and to derive benefits from other stations' experience. The major functions of the NSAD are to: a. Investigate, assess and recommend action for administra-tive or functional controls required to assure overall safety. b. Monitor and evaluate trends in activities having the potential for compromising overall safety. c. Serve as an Office of Ombudsman for all members of GPUN l having a concern for nuclear plant or personnel radia-tion safety. 5 d. Recommend and monitor the establishment of additional controls, criteria and/or procedures which may be 7. required to control the design and operation of nuclear 5 plants in meeting safety considerations. [ } Provide overview and direction of 10SRG to help ensure e. l the technical adequacy of nuclear plant procedures, 0 g operations, technical specification changes, and tests. o A000105011 82 I i 18.0

N"b" gp OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200,01 Title Raision No. 1.0 ORGANIZATION 1-00

f. ' Provide staff support for the General Office Review Board for each of the nuclear plants, as required.

1.6.4 Manager - Emergency Preparedness The Manager - Emergency Preparedness is responsible to assure that Oyster Creek and TMI Emergency Plans and Preparedness are in accordance with corporate policies and all applicable laws, regulations, licenses and technical requirements. Addition-ally, he is to provide support and guidance in the Emergency Planning area for the Three Mile Island and Oyster Creek stations and to assure the maintenance of a high state of emergency preparedness at the two stations. The Manager - Emergency Preparedness is responsible for the following major functions: a. Coordinate emergency planning between the Three Mile Island and Oyster Creek stations. b. Monitor, evaluate and assure both Three Mile Island and Oyster Creek stations have emergency preparedness pro-grams that are coordinated and maintained current, and assure a high state of preparedness. c. Assure that Three Mile Island and Oyster Creek Stations' Emergency Plans are consistent with the latest require-ments of the NRC and with the FEMA approved Pennsylvania and New Jersey state, co,unty and local emergency plans. d. Interf ace with the Nuclear Regulatory Comission, state and local authorities in emergency planning areas. e. Obtain, review and comment on proposed legislation, industry guidelines and standards in the area of emergency planning. Preparation and submittal of coments will be coordinated through the Technical functions Olvision. 1.7 Director - Administration 5 The Director - Administration reports directly to the Office of the President. He is responsible to establish and implement T. uniform policies and programs in Materials Management, Human 3 Resources, Security, Operations Analysis, Information 2 Management and Strategic Planning to help achieve Company objectives in accordance with Corporate Policies and all { applicable laws, regulations, licenses and technical requirements. The Administration Division is responsible for the following major functions: A0001050 i t -82 19.0

ENuclear Neow OPERATIONAL QUALITY ASSURANCE 1000-PLN-7200 PLAN Title Revision No 1.0 ORGANIZATION 1-00 a'. Provide contracting, procurement, warehousing and inventory control services. b. Provide and maintain a qualified staff, c. Develop and administer the security program. d. Develop and administer a comprehensive Human Resources Management function. e. Provide Operations Analyses, f. Develop and coordinate GPUN's strategic planning process including issue management, and assure its integration with other levels of planning within the company. g. Manage GPUN information management centers and coordinate GPUN policies and procedure system. h. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division. 1. Develop, gain approval and operate within approved annual budget, annual operating plan, and the multi-year strategic plan. J. Develop and maintain effective consultation and advice with other Divisions to help assure efficient functioning of GPU Nuclear. The Director - Administration is assisted in the performance of these responsibilities at the site by individuals with assigned responsibility for security, contracting, procurement, warehousing, and information management services. The Director - Administration gives his full support to the l Quality assurance requirements set forth in this Quality Assurance Plan, assuring compliance to the fullest degree by his staff. 5 The Director - Administration utilizes the following management staff members in carrying out his responsibilities: 3 Director - Materials Management 9 Director Security 2 Manager - Strategic Planning Administrative Pr.ojects l Manager - Information Management Centers g Manager - Operations Analysis = 1 A000t0$0t1 02 20.0

e 1 OPERATIONAL QUALITY ASSURANCE Number E I PLAN 1000-PLN-7200.01 i Title Revision No. 1.0 ORGANIZATION 1-00 1.7.1 Director - Materials Management The Director - Materials Management is responsible to provide contracting and procurement, contract administration, ware-housing and inventory control services to the plants and the Services divisions of GPUN. The Materials Management Department is responsible for the following major functions: a. Sources, bid, review quotations, negotiate and award materials, equipment, fuels and service requirements for all plants and services divisions. b. Administer and expedite performance under these con-tracts and purchase orders. c. Review and evaluate vendor claims for changes, extras, elivs, suspensions and terminations and equitably 5te those found to be valid. d. ceive, inspect, store and issue ordered goods, e. Maintain inventory levels of repetitively procured items at optimum levels. 1.7.2 Director Security The Director Security is respo'nsible to develop and administer security programs directed to creating a safe, convenient and protected environment for GPUN employees and property. The Department is responsible for the following major functions: a. Plant security guard force and surveillance systems and controls including physical security, physical barriers, access requirements, detection aids, comunications requirements, security equipment testing and main-tenance, response requirements, records and reports involving such activities as: G - Insure that the nuclear generating stations are adequately protected against acts of sabotage, arson, .~. thef t and civil disturtiances. 5 0 - Develop and execute plans and procedures for the U physical security of the nuclear stations., h - Provide liaison to regulatory agencies. - Implement company and NRC rules and regulations. A000toloIt 82 21.0

NWar OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 1.0 ORGANIZATION 1-00 - Assure all non-company employees and contractors are properly screened for unescorted acces:i to the facility. - Provide access control through the use of security surveillance equipment. - Provide physical access control and carry out search requirements. - Plan defenses for civil disturbances and demonstra-tions. - Investigate all security incidents. 1.7.3 Manager Strategic Planning and Administrative Projects The Manager Strategic Planning and Administrative Projects is responsible for developing and coordinating GPUN's strategic planning process including issue management, and assuring its integration with other levels of planning within the company. 1.7.4 Manager Information Management Centers The Manager Information Management Centers is responsible for the following major functions:

a. Implement and maintain New Information Systems,

b. Provide records management, documentation and correspondence control to meet Corporate requirements and satisfy ANSI Standards requirement as committed to in Appendix C of this

Plan,

c. Manage Corporate and plant libraries as required,

d. Establisn, maintain and coordinate GPUN Corporate Administrative policies and procedures.

e. Provide configuration control support.

n" 1.7.5 Manager Operations Analysis a The Manager Operations Analysis is responsible for providing operations analysis for Corporate and plant operations. h 1_ i A000109011 42 22.0

OPERATIONAL QUALITY ASSURANCE Number ~ NI PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 1.8 Direct'or - Radiological and Environmental Controls The Director - Radiological and Environmental Controls reports directly to the Office of the President. He is responsible for the establishment and implementation of uniform health, safety, radiological and environmental policies, practices and procedures required to assure safe, reliable and efficient operation in accordance with Corporate Policies and all applicable laws, regulations and licenses. The Radiological and Environmental Controls Division is responsible for the following major functions: a. Establish and maintain Corporate level policies, procedures, standards and practices relating to health, safety, medical, radiological and environmental activities. b. Provide and maintain a qualified staff. c. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division. d. Provide the personnel, procedures and administrative controls to implement the plant health, safety, medical, radiological and environmental protection programs, e. Provide administrative and technical guidance applicable to radiation protection, radioactive materials, resotratory protection *and radiological engineering including ALARA programs and dosimetry control, f. Provide professional medical and radiological guidance. 9 Provide administrative and technical guidance applicable to industrial safety, occupational health, environmental protection, environmental monitoring and NPOES. h. Develop and administer industrial safety programs. 1. Develop, gain approval and operate within approved Q annual budget, annual operating plan, and the multi-year strategic plan. 5

j. Develop and maintain effective consultation and advice with other divisions to help assure efficient 2

functioning of GPU Nuclear. I 4 23.0

OPERATIONAL QUALITY ASSURANCE N e ber E I ( PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 The Director - Radiological and Environmental Controls gives l l his full support to the quality assurance requirements set l forth in this Quality Assurance Plan, assuring compliance to the fullest degree by his staff. I The following management staff is utilized in carrying out the responsibilities of the Radiological and Environmental Controls Division: Safety and Environmental Controls Director l Oyster Creek Radiological Controls Director Manager TMI-I Radiological Controls Oyster Creek Radiological Assessment TMI Radiological Assessment TMI-2 Radiological Controls Director Medical Director 1.8.1 Safety and Environmental Controls Director I The Safety and Environmental Controls Director reports directly to the Director - Radiological and Environmental Controls. He is responsible for all environmental and industrial safety and health matters at Oyster Creek and Three Mile Island. Tnts is accomplished through the implementation of all monitoring and l study requirements of USNRC, USEPA, NJOEP and Pa0EP as contained in Appendix B of the Environmental Technical p Specifications, the National Pollutant Discharge Elimination f System permits, OSHA, NIOSH and other company corm 11tments. 9 The major functions of the Safety and Environmental Controls Department are: a. Perform Radiological Environmental Monitoring Programs to assess impact of radiological releases on surrounding populations. b. Operate and maintain the meteorological towers. c. Assess the impact of plant operation on terrestrial and aquatic life. d. Nonitor depth of water in adjacent rivers and bays to T. nnsure sufficient cooling water and determine if navigability has been affected Sy plant operation. 2 e. Conduct other environmental monitoring and reporting and g j assure corporate compliance with appropriate Environ-mental Regulations and Licensing requirements. l i i A0001010tt 82 24.O L--

~ ~, ENuclear o'ean0"= ouAury AssuuNCe PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00 f. $upport corporate attorneys in civil and administrative environmental hearings. g. Industrial Safety and Health systems, surveys, equipment, training and implementation of policy ) procedures, OSHA, NIOSH and other commitments. 1.8.2 Radiological Controls Departments--TMI-1, and Oyster Creek A Radiological Controls Department is provided at each nuclear station. The departments are managed by a Manager Radiological Controls for TMI-l and a Radiological Controls Director for Oyster Creek who are responsible for the implementation of the Radiation Protection Plan at their assigned plant. In addition, they are each responsible for monitoring and enforcing the implementation of all radiological control policies and orocedures consistent with the requirements of this Quality Assurance Plan and the Radiation Protection Plan in support of the operation and maintenance of the plants. The l major functions of each Radiological Controls Department are as I follows: a. Control external exposure through the administration of a 00simetry Program, b. Control internal exposure through administration of a Respirator Protection, Bioassay and Whole Body Counting Program. c. Control radioactive contamination. d. Control radioactive materials. e. Perform reviews of the Radiological Controls Program. f. Maintain procedures to ensure exposure to workers and the general population is as low as reasonably achievable. g. Support normal plant operation and provide additional 5 support prior to, during and after outages. ~. h. Assure coroorate compliance with appropriate Radio-t j logical Regulations and Licensing requirements. 2 1. Train and qualify radiological technicians in radio-i l logical control procedures and techniques. Approve e radiological training of others. H A00oIO50 4182 25.0

2 OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00

j. ' Provide dosimetry program services.

k. Provide respirator protection, bioassay, and whole body counting services. 1. Maintain and calibrate all radiological equipment used by the Radiological Controls Department. c The last 4 functions gi, j, k, and 1) are performed for the TMI-1 Radiological Controls Department by the TMI-2 Radio-logical Controls Department. 1.8.3 Radiological Assessment Deoartments--TMI and Oyster Creek A Radiological Assessment Department is provided at Three Mile Island and another at Oyster Creek. Each department performs independent analysis of the implementation of the radiological controls program and radiolooical control oractices at their respective location. The maj or functions of each department are to: a. Conduct frequent tours in areas where radiological work is being performed. I d b. Review compliance with federal Regulations, license requirements and radiological control procedures. 1 c. Prepare periodic radiological assessment reports for management. a d. Review radiological work practices for ALARA considera-tions. 1.8.4 Medical Department The Medical department is responsible for the direction of the GPU Nuclear Medical Program. This includes direction of contract physicians and GPU Nuclear medical personnel, as well as provision of professional medical guidance and participation in radiological matters. The major functions of the Medical C Department are to: ~.

a. Recommend sound medical policies for conduct of business of f,

GPU Nuclear Corporation.

b. Direct and implement the GPU Nuclear Medical Program, and g

certify professional qualifications of the medical staff. s 5 I A000105011-82 26.0

g F Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION 1-00

c. Provide medical guidance to the division directors in the medical aspects of radiation exposure and other occupational

hazards,

d. Establish and maintain technically clear and concise medical records.

1.9 Director - Maintenance, Construction and Facilities The Director - Maintenance, Construction and Facilities reports directly to the Office of the President. He is responsible to establish and implement uniform policies, practices and procedures for managing, planning and conducting all maintenance, repair, facilities, transportation and construction activities in accordance with Corporate Policies and all applicable laws, regulations and licenses and technical { requirements; accomplish all plant modifications, maintenance, repair, and construction activities as assigned in accordance with Corporate Policies and all applicable laws, regulations, licenses and technical requirements. The Maintenance, Construction and Facilities Division is responsible for the following major functions: a. Evaluate and assure that maintenance activities at TMI-l and Oyster Creek are being performed in accordance with Corporate Policies, procedures and good maintenance practices, b. Provide and maintain a qualified staff. c. Establish and maintain the necessary Corporate level maintenance and construction procedures, standards and practices for the performance of maintenance and construction activities. d. Develop, issue and report progress against integrated schedules for work at TMI and Oyster Creek consistent with established cardinal dates and the long range plan. e. Plan, schedule and direct plant modifications, plant 5 construction projects and major and specialized maintenance jobs at TMI-l and Oyster Creek, including .~. those special maintenance and construction activities involved in planned and forced outages. 2 f. Develop and maintain effective consultation and advice j with other Divisions to help assure efficient functioning of GPU Nuclear, b s A000tOSO11 82 27.0

& Nuclear open n0Nat avau n aSSunuCe PLAN 1000-PtN.1200.01, Title Anision No. 1.0 ORGANIZATION 1-00 The Director - Maintenance, Construction and Facilities gives l-his full support to the quality assurance requirements set forth in this Quality Assurance Plan, assuring compliance to the fullest degree by his staff. The Director - Maintenance, Construction and Facilities utilizes the following management staff members in carrying out his responsibilities: i Maintenance and Construction Director - Oyster Creek Maintenance and Construction Director - TMI-I Maintenance and Construction Director Facilities Manager, Maintenance and Construction Planning Manager, Maintenance and Construction Methods and Procedures Maintenance and Construction Production Ofrector Maintenance and Construction Administrative Support Manager Staff Assistants 1.9.1 Maintenance and Construction Directors 1 A Maintenance and Construction Director is assigned to each plant. Each Director reports to the Of rector Maintenance, Construction and Facilities and is responsible to implement policies, practices and procedures for all maintenance, repair 4 and construction activities at their assigned plant in ( accordance with corporate policies and direction, as well as applicable laws, regulations and license and technical [ requirements. In addition, each Director is responsible to y direct the conduct of assigned plant modifications, repair and 9 construction activities and accomplish major and specialized o maintenance work in accordance with corporate policies and q direction, as well as all applicable laws, regulations and licenses and technical requirements. Each Maintenance and Construction Director shall orovide, manage and direct required departmental support in the follow-ing functional areas: 4 Planning--workload and control, planning and scheduling, a. estimating and cost analysis. b. Production--project engineering, contractor services, production work; and materials, tools, equipment and 1 a: plant facilities management. W G Technical Support--welding, turbine, valves / pumps, c. 6 methods / practices, and documentation. O ~ g g d. Administrative Support--personnel and management assistance. g O_ b l t A0001050tt 82 28,0

Numer Nder PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 1.0 ORGANIZATION l-00 Each Mai'ntenance and Construction Ofrector is assisted in carrying out his responsibilities by a Manager - Planning, a Manager - Production, a Manager - Technical Support, an Administrative Support Manager and an Outage Manager. 1.9.2 M&C Ofrector Facilities M&C Ofrector facilities - reports directly to the Ofrector Maintenance, Construction and Facilities and is responsible to plan, direct, implement and manage all functional responsibilities of the M&C 01 vision as they relate to the facilities area. To direct and provide oversight / monitoring efforts for each GPUNC location and assure Corporate / Division Policies, Practices and Procedures for facility maintenance, repair, and construction are accomplished as prescribed. The major functions of the M&C Director facilities are as follows:

a. Direct the planning and implementation for all facility construction, repairs, modifications and maintenance.

b. Establish and implement transportation policies and procedures and direct transportation maintenance, repair and I

leasing.

c. Direct activities related to tools, equipment, materials and shops.

d. Direct activities related to telecommunications,

e. Ofrect activities related to mail distribution.

1.9.3 Manager - Maintenance and Const'ruction Planning The Manager - Maintenance and Construction Planning reports directly to the Director - Maintenance Construction and facilities and is responsible to plan,, implement and manage all functional responsibilities of the Maintenance and Construction Division in the planning area and to provide and manage aporopriate oversight / monitoring efforts for each site to assure that corporate policies, practices and procedures for all maintenance, repair and construction activities in the planning area are accompitshed as prescribed. 5 The major functions of the Maintenance and Construction Planning Department are as follows: 5 a. Manage the workload inventory by planning, scheduling y and assignment within the Division and appropriate interface with other divisions, h b. Manage the authorized modification program. I A00010$0tI 82 29.0

gEgNI OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No 1.0 ORGANIZATION 1-00 c.* Manaqe all assigned job planning preparation and scheduling. d. Manage all schedule assessment efforts. e. Coordinate job estimating and cost analysis requirements. 1.9.4 Manager - Maintenance and Construction Methods and Proceduros The Manager - Maintenance and Construction Methods and Pro-ceduros reports directly to the Director - Maintenanco, Construction and Facilities and is responsible to plan, implement and manage all functional responsibilities of the Maintenance, Construction and facilities Division in the methods and procedures area and to provido and manage appropriate oversight / monitoring efforts for each sito to assure that corporato policios, practicos anti proceduros for all maintenance, repair and construction activities in the methods and procedures area are accomplished as proscribed. The major functions of the Maintenance and Construction Methods and Procedures Dopartment are as follows: a. Provido technical support to the Olvision as appropriato, b. Develop and manaqo various programs for improvement which are assigned, such as the rollability proqram, experience transfer proqram, equipment utilization pro-gram and reliability program, c. Develop, oromulgato and audit generic methods and pro-ceduros required by the Olvision, d. Manage and direct preparation of processos and instruc-tions required by the Olvision, e. Manaqo the program related to records, qualification, documentation and document controls. 1.9.5 Maintenance and Construction Penduction ofrector 8 The Maintenance and Construction Production Otractor reports 7. directly to the alrector - Maintenance, Construction and 3 facilities and is responsible to plan, implomont and manago all E. functional responsibilities of the Maintenance, Construction and facilities Division in the production area and to provido ) and manage approorlato oversight / monitoring efforts for each site to assure that corporate polictos, practicos and a i proceduros for all maintenanco, ropale and construction activities in the production area are accomplished as prescribed. Ano0ln y) 11 WJ e 30.0

07 ERAT 10NAL QUAL!TY ASSURANC( Number N r PLAN 1000-PLN-7200.01 i fitte Revision No 1.0 ORGANIZATION 1-00 The dajor functions of the Maintenance and Construction Produc-tion Department are as follows: Coordinate project engineering efforts as directed. a. b. Manage and direct the production workforce -contractors, vendors and company personnel, Manage the services under contract assigned to the c. Division. 1.9.6 Maintenance and Construction Administrative Suooort Manager The Maintenance and Construction Administrative Support Manager reports directly to the Ofrector - Maintenance, Construction and Facilities and is responsible to plan, implement and manage all fonctional responsibilities of the Maintenance, Construction and facilities Olvision in the administrative i support area and to provide and manage appropriate oversight / monitoring efforts for each site to assure that corporate policies, practices and procedures for all maintenance, repair and construction activities in the administrative support area are accompitshed as prescribed. The major functions of the Maintenance and Construction Administrative Support Department are as follows: Coordinate the Olvision's training requirements and a. Interf ace with the Nuclear Assurance Division in the i training area, b. Manage and direct various improvement programs related to personnel. I c. Provide Division support in the personnel area. 0 "o 5 I h I } a l 400010M tI el 31.0

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a NurnMr Nucgser OPERATIONAL QUALITY ASSURANCE i glAN iOOO. gly.7200.0i Revision No. i Title 2.0 QUALITY ASSURANCE PROGRAM l-00 2.0 QUALITY ASSURANCE PROGRAM 2.1 General The GPUN Quality Assurance Program has been established to control the activities performed by GPU Nuclear within the scope of the Program. Adherence to the requirements of the Quality Assurance Program is mandatory for all GPUN organizations and for all external organizations I providing items or services covered under the scope. This Operational Quality Assurance Plan is the highest level document which describes the Quality Assurance Program. The term " Program" as used herein includes subtier implementing policies, procedures and instructions. Any conflicts, which cannot be resolved at the Department or Section level, regarding interpretation or implementation of this Plan shall be promptly reported to the Director - Quality Assurance for resolution. I 1 2.2 Scope The scope of the GPUN Operational Quality Assurance Program includes, but is not limited to, all items and activities applicable to the operation l of TMI-1 and Oyster Creek considered to be "important to safety." This term is broader than " safety-related" and encompasses structures, systems l and components (including nuclear fuel and radwaste) which have been I designated as Safety-Related, Safety Class, IEEE Class IE, - - Equipment I i Environmental Qualification, Seismic Category I or Fire Protection. The scope of the Program includes items covered by the Operating License and Technical Specifications (excluding non-radiological monitoring) and j items required by the following: a. Title 10, Code of Federal Regulations, Part 50, Appendix A q " General Design Criteria for Nuclear Power Plants". b. Title 10, Code of Federal Regulations, Part 50, Appendix B l " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants". 5 c. Title 10 Code of Federal Regulations, Part 71, Subpart H " Quality Assurance for Shipping Packages for Radioactive Material". l b 2 1 I -,m,, o 34.0 l

ENuclear Number OeERATIONAt QUALITY ASSURANCE AN 1000-PLN-7200.01 Title Rewsion No. 2.0 QUALITY ASSURANCE PROGRAM l-00 d. Title 10, Code of Federal Regulations, Part 50, Appendix R " Fire Protection Program for Nuclear Power Facilities Operating prior to January 1, 1980". e. United States Nuclear Regulatory Commission Regulatory Guide 1.143 " Design Guidance for Radioactive Waste Management Systems, Structures and Components Installed in Light Water Cooled Nuclear Power Plants". f. U. S. Nuclear Regulatory Commission Regulatory Guide 1.29 " Seismic Design Classification" and the seismic aspects of components which have impact on items important to safety. g. Title 10 Code of Federal Regulations, Part 50.49, " Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants". h. Other items when designated by Technical Functions. Appendix A provides a comparison of the sections of this Plan with the requirements of 10CFR50, Appendix 8; 10CFR71, Subpart H; ANSI N18.7; and ANSI N45.2. The GPUN Operational Quality Assurance Program applies to all items on the Quality Classification List (QCL). The QCL will be periodically updated to include new plant modifications or construction or any changes in classification. The contents of the list will be controlled.* For new design efforts such as plant modifications and new construction, the classification determination is recorded on design criteria documents. New items will be included in the QCL. Documents which control the installation of Important to Safety modifications will be clearly identified as such. 2.2.1 Activities which are Important to Safety shall include, but not be limited to: a. Those activities covered by ANSI N18.7 and Appendix A of C Regulatory Guide 1.33. L b. The requirements of other Regulatory Guides applicable 5 to operations, maintenance, modification, repair and k refueling of a nuclear power plant as identified in Appendix C herein. 2 o c. Those activities related to protection against radiation 3 as covered by Title 10, Code of Federal Regulations, Part 20. A000105011~82 35.0 m

NUChr OPERATIONAL QUALITY ASSURANCE ptan icoo_PtN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 d'. Those activities related to Fire Protection as covered by Title 10, Code of Federal Regulations, Part 50, Appendix R. e. Those activities related to Plant Security as covered by Title 10, Code of Federal Regulations, Part 73.55 " Requirements for Physical Protection of Licensed Activities in Nuclear Power Plants Against Industrial Sabotage." f. Those activities defined by procedures which have been designated during the review cycle as "important to safety." 2.3 Operational Quality Assurance Plan This Operational Quality Assurance Plan is the primary document which establishes the policies, goals and objectives of the Program. This Plan is authorized by the Office of the President and requires that the appropriate levels of manage-ment, as designated herein, implement the Program. This Plan is controlled to assure that only the latest approved revision is implemented. This Plan is implemented through approved detailed procedures and instruction. With the exception of the Organization, Section 1.0, and the QA Program, Section 2.0, each section of this Plan contains three major subsections: Policy--A summary description of the policy of GPUN regarding the specific subject of the section. Requirements--A description of the requirements applicable to the specific subject of the section. Responsibilities--Identification of those organizations and their responsibilities relative to the specific subject of the section. The purpose of this Plan is to establish the principles which, 5 when implemented, will provide that level of quality assurance which is appropriate.to each item or activity important to ~ safety. It is recognized that the degree of management control 5 or quality assurance to be applied varies with different i y systems and activities, and the degree of applicability of any l specific item in this Program will differ from item to item and -j activity to activity. 1 A000f 0501182 l 36.0

4UOiOOI OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM 1-00 2.3.1 Graded Approach The degree to which the requirements of this Plan and _its implementing procedures are applied will be based upon the following: a. The importance of a malfunction or failure of the item to safety. b. The design and fabrication complexity or uniqueness of the item. c. The need for special controls and surveillance or monitoring cf processes, equipment and operational activities. d. The degree to which functional compliance can be demon-strated by inspection or test. e. The quality history and degree of standardization of the item or activity. The quality requirements for items important to safety will be established using approved procedures based on the " General Logic Considerations" listed in the Appendix to ANSI ( N45.2.13-1976. Quality requirements will be established by the C responsible department and concurred with by the Quality Assurance Department for those items which are important to safety. GPUN is committed to a comprehensive Quality Assurance Program consisting of a three-level approach to assure satisfactory and complete implementation of the program commensurate with its requirements for safety and performance. The Program's fore-I most considerations are the protection of the general public's health and safety. 2.3.1.1 Level I - Activities at this level consist of inspections, i checks and tests. First-level activities include inspections, Q checks, or tests performed for the purpose of establishing f acceptance and/or. verification of equipment, systems and T. activities important to safety. Level I activities are / 5 performed by the Quality Assurance, Operations, Plant Main-0 tenance, Radiological Controls, Maintenance and Construction, n and contractor personnel. Where the first-level activities il 9 0 e AOOO 105011 82 37.0 3

Nuclear OPERAT10NAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 invol've independent inspection for purposes of acceptance and/or verification the activity will be performed by the QA Department or by organizations authorized to perform those activities by the QA Department. Operations, Plant Maintenance, Maintenance, Construction and Facilities and Radiological Controls personnel perform activities such as surveillance tests, calibration of instruments, radiation surveys, analyses of samples, valve line-ups, pump and valve maintenance and overhaul etc. Maintenance, Construction and Facilities and Plant l Maintenance personnel perform modification, replacement, repair and overhaul activities. Quality Control personnel perform receipt inspection and checks and inspections of modifications and maintenance activities. Contractors perform inspections as applicable to their i scope of work. t In all cases, the inspection, check and testing activities are i performed by individuals who are knowledgeable of the activity being performed and are qualified to perform the work (refer to Section 6.2). Checklists, weld history records, travelers, etc., are used for documenting the results of the activity and for providing a record of the performance of the activity. 2.3.1.2 Level II - The activities at this level are primarily those of surveillance or monitoring and are performed as deemed necessary by the QA Modifications / Operations or QA Design and Procurement Sections. The level of surveillance / monitoring 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. E At this level, procedures and instructions are established and 5 surveillance records.will be completed and maintained. Such surveillance / monitoring normally includes observation of tests a E and inspections, observation of selected operations, review of 5 records, verifications of test reports, and direct inspection j on a spot-check basis. The organizations performing this I A000105011 - 82 38.0

Nuclear OPERATIONAL QUAllTY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 activ'ity have the levels of authority, the lines of internal and external comunication for management direction, and the properly trained personnel for implementation of these activities. 2.3.1.3 Level III - The purpose of this level of activity is to assure, through a comprehensive program of review and auditing, that the first and second levels of the program are properly func-tioning. The purpose of this level is also to establish that all other crganizations, including Operations, Maintenance, Engineering, Material Management, etc., are properly satisfying all the requirements of the Operational Quality Assurance Pro-gram. At this level, procedures and instructions are established, including the use of comprehensive checklistc for documentation of the audit or third-level activity. The program requirements of ANSI N45.2.12 shall be satisfied. Qualified audit personnel shall be utilized who satisfy the requirements of ANSI N45.2.23. Additional. technical experts, from areas with administrative reporting outside the function that is being audited, will be included as the Audit Team Leader deems necessary. The organization performing this activity has sufficient authority and lines of internal and external comunications for obtaining the necessary management direction. 2.3.2 Operational Quality Assurance Plan. Control 2.3.2.1 Approval This Plan includes a Statement of Policy which is signed by the President - GPUN. The Statement of Policy provides authoriza-tion and evidence of management commitment to the Quality Assurance Program. This plan shall be approved by the Office of the President and shall be reviewed for concurrence by the following: Director - TMI Unit 1 Director - OCNGS 5 Director - Nuclear Assurance Director - Technical Functions 7. Director - Maintenance, Construction and Facilities E Director - Administration 3_ Director - Radiological and Environmental Control l A000105011 82 39.0

Nebw OPERATIONAL QUALITY ASSURANCE gggy PLAN 1000-PLN-7200.01 Revision No. Title 2.0 QUALITY ASSURANCE PROGRAM l-00 2.3.2.2 Revisions The Director - Quality Assurance in conjunction with the ( t Director, Licensing and Regulatory Affairs, shall, for each revision to this Quality Assurance Plan, determine if the changes reduce or do not reduce the comitments previously accepted by the NRC. Revisions to the Quality Assurance Plan that do not reduce the comitments to the NRC shall be approved by the Office of the President with the concurrence of the Director - Nuclear l [ Assurance and submitted by the Director - Quality Assurance as j indicated on an Approvals Page which shall be added to the manual behind the Cover Page. The Cover Page containing 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 issuance, but must be submitted to the NRC at least annually. Revisions to the Quality Assurance Plan that reduce the comit-ments to the NRC shall be submitted to the NRC and receive NRC approval prior to issuance. 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 after a submittal to the NRC whichever comes first. The submittal of the revision to the Quality Assurance Plan must include all 0 pages affected by that change and must be accompanied by a transmittal letter identifying the change, and the basis for j concluding that the revision c6ntinues to satisfy 10CFR50, l Appendix B and the Safety Analysis Report quality assurance program description comitments previously accepted by the NRC i (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 1 years. Revisions of this type shall be approved by the Office of the President, concurred with by the Division Directors and l submitted by the Director - Quality Assurance as indicated by their signatures on a revised Cover Page. 2.3.2.3 Distribution 5 Copies of the Operational Quality Assurance Plan may be dis-T. tributed as " Controlled" or " Uncontrolled" copies in accordance j with the requirements established in Section 3. E I g r i i 8 A000105011 - 82 40.0

ENuclear Number o'ea^rt0NAL QUALITY ASSURANCE PLAN 1000-PLN-7200.0i, Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 2.3.2.4 Effective Date of Implementation Changes to this Plan shall be incorporated in the implementing procedures within 60 days of the issuance date of the Plan unless an interim action plan is defined and approved by the Director - Quality Assurance. 2.4 Quality Assurance Program Review The effectiveness of the QA Program and its 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. In a periodically prepares eva,ddition, the QA Department luation reports on the Program effectiveness. Other divisions provide additional informa-tion / evaluations as requested. In addition to the reviews and evaluations performed by the QA Department, the Office of the President shall have, at least once per year, an independent assessment performed of the QA Program implementation to ensure that the activities meet the regulatory requirements and the policies of GPUN. This assess-ment may be performed utilizing the safety review groups, an [ independent consultant, representatives of other utilities i and/or his own staff. Any cofrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution. 2.5 Indoctrination and Training The GPUN Quality Assurance Program includes requirements for formal indoctrination and training programs of personnel per-forming or verifying activities important to safety. Training departments are established and staffed at the Corporate office and at each plant site. These training departments are each responsible for planning, scheduling and providing training to 5 GPUN personnel. The specific needs and the subject material to be covered in the indoctrination and training programs are established by both on-site and off-site organizational units 5 responsible for the activities. These programs are implemented by appropriate training plans and procedures which assure that: h 9 Eo A0001050 l t -82 I 41.0

Nuclear OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 a'. Personnel are instructed as to the purpose, scope and implementation of manuals, procedures and instructions. b. Personnel are trained in the principles and techniques of the activities being performed. Training require-ments will be established consistent with the importance to safety of the activity requiring qualification. c. Proficiency is maintained by retraining, and/or reexamining. d. The scope, method and objective of the training is documented. e. Records of training sessions are prepared and main-tained, including identification of the content, the attendees, and the date the training was conducted. For personnel performing inspection, examination, and special processes, the qualification criteria shall be delineated to the techniques of inspection or items being inspected and the technical abilities of the person being certified will be con-sistent with the assigned tasks (e.g., electrical inspection, mechanical inspection, etc.). 2.6 Classification 2.6.1 General The significance of an item or activity to an important to safety function shall be considered in its classification. Procedures shall be prepared, at the Corporate and/or Division levels, which establish the requirements for identification and control of classification of important to safety items and activities. These procedures shall be reviewed and concurred with by the Quality Assurance Department prior to issuance. 5 ?. 5 9 0 3 0 A000105011 82 42.0

Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 Proc 6dures, or portions thereof, for controlling important to safety activities shall be identified as such. Systems and major components, but not parts thereof, which are important to safety will be identified on a Quality Classification List (QCL). A QCL will be established and maintained, by Technical Functions, for each plant. The classification of the systems and components on the QCL will be subject to independent design verification by Technical functions. For procurement of spare or replacement parts, where there is a change to a lower classification, the classification will be determined by Plant Engineering or Technical Functions and concurred with by Quality Assurance. The determinations will be documented and retained. 2.7 Regulatory Commitments Records of commitments to regulatory requirements are main-tained by Technical Functions. Appendix C herein lists those Regulatory Guides which contain specific Quality Assurance requirements with the stated Company position, exceptions and/or clarifications. These must be complied with in conjunc-tion with this QA Plan. Appendix C will be revised, as necessary, to reflect any change in the GPUN commitment to the Regulatory Guides. Technical functions, through Licensing and Regulatory Affairs, is responsible for providing GPUN positions and interpretations on all other Regulatory Guides. 2.8 Safety Reviews The safety review program involves five major elements: 2.8.1 The first element of the safety review program shall be a 100% review by someone other than the individual doing the work. This review will be performed by a qualified Responsible Technical Reviewer on all activities important to safety including design work or changes, plant operating, emergency and alarm procedures, radiological control procedures and plant maintenance procedures. 5

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J Number ENuclear oata^rIONAL QUALITY ASSURANCE AN 1000-PLN-7200.01 Titte Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 2.8.2 The s'econd element of the safety review program is an indepen-dent review by qualified independent safety reviewers. These individuals will not have direct responsibility for the perfor-mance of the activities under review, but may be from the same functionally cognizant organization as the individual / group performing the original work. This review will be performed on I all written safety evaluations for design work or changes, test and experiments and procedures as described in the Technical Specifications. i 2.8.3 The third element of the safety review program is the Indepen-dent On-site Safety Review Group (IOSRG). An IOSRG shall be located at each generating station. The IOSRG has no line responsibilities or functions and is devoted solely to safety matters. It is independent of the plant staff and reports off-site to the Nuclear Safety Assessment Department. It pro-i vides, on a selected basis, review of important to safety ~ items, such items as proposed Technical Specification changes, unreviewed safety questions and other items it chooses, or which are referred to it by the functional organizations. Each 10SRG will be staffed by a full-time group of engineers, independent of the unit staff, and located onsite. Each IOSRG g will consist of a Safety Review Manager who reports to the Nuclear Safety Assessment Director and a minimum staff of three 0 members, each of whom shall have an academic degree in g engineering or a physical science field and 3 years of pro-fessional level experience in the. nuclear power field including 0 technical supporting functions or 8 years of appropriate experience. Credit toward experience will be given for advanced degrees on a one-to-one basis up to a maximum of two years. Each IOSRG shall have access to the unit and unit records as necessary to perform its evaluations and assessments. Based on its reviews, the 10SRG shall provide recommendations to the management positions responsible for the areas reviewed. f IOSRG reports of evaluations and assessments shall be prepared, approved, and transmitted to the Nuclear Safety Assessment Director, Nuclear Assurance Division Director, and the l management positions responsible for the areas reviewed. I 7. 3 2 I I 3< l b_ V A000105011 82 44.0

) Nuclear OPEMTIONAL QUAUTY ASSUMNCE PLAN 1000-PLN-7200.01, Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 2.8.4 The fourth 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 - l Nuclear Assurance. In addition to overseeing the 10SRG, the Nuclear Safety Assessment Department, through its headquarters staff, will assess all aspects of GPUN activities as well as developments elsewhere in the nuclear industry. It shall provide the following safety review functions: a. An overview of activities affecting or potentially affecting safety. This is a broadly defined responsi-bility 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 basis i 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 8 investigate such matters, identify any needed action and seek its resolution. The Ombudsman will reply to the individual who raised the matter. c. Staff support to the General Office Review Board. k 2.8.5 The fifth element of the safty review program is the General e Office Review Board. This is a group of senior level indi-viduals 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 Board of Directors. Its charter is broadly defined to encompass all matters potentially affecting safety so as to foresee poten-tially significant nuclear and radiation problems. 2.9 Responsibilities 2.9.1 Office of the President The Office of the President - GPUN is responsible to regu-larly assess the scope, status, adequacy and compliance of the g Quality Assurance Program to the requirements of 10CFR50, Appendix B, 10CFR20, and 10CFR71, Subpart H. This assessment l shall be the combined result of: 2 a. Review of audit reports, periodic status reports, etc. a on the effectiveness and implementation of the Quality g Assurance Program. I A000105011 82 45.0

Number Nefer oFERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 b. Performance at least once a year of an independent assessment of the effectiveness of the Quality Assurance Program to assure that the Program meets regulatory requirements and the policies and directives of GPUN. This assessment may be performed utilizing the safety review groups, an independent consultant, representa-tives from other utilities and/or the President's own i staff. Any corrective action which may be deemed nec-essary as a result of these assessments shall be formally identified and tracked through resolution. 2.9.2 Director - Nuclear Assurance The Director - Nuclear Assurance has overall responsibility for establishment of the GPUN Operational Quality Assurance Plan. He also has overall responsibility for establishment and I management of the Nuclear Safety Assessment Department, the Quality Assurance Department, the Training and Education Department and Emergency Preparedness. He shall provide periodic status reports to the Office of the President on the effectiveness and implementation of the Quality Assurance Program. 2.9.3 Director - Quality Assurance The Director - Quality Assurance has the direct responsibility for verifying the effective implementation of the Quality Assurance Program. He shall establish and implement a formally documented and procedurally controlled program to evaluate and report to the Director - Nuclear Assurance on the adequacy and [ continued effectiveness of the Quality Assurance Program. The basis for the evaluation reports to the Director - Nuclear l Assurance includes reports of audits performed by the Quality Assurance Department or their agents; surveillance / monitoring of station activities performed by the site QA organizations; reports of evaluations, surveillance and audits of vendors; and quality trend analyses based on nonconformance and deficiency reports and reports of inspections, examinations, surveillance / monitoring and audits. 5 se 5 9 5 3< B A000105011 82 46.0

OPERATZONAL QUALITY ASSURANCE Number Nder PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 Corrective actions shall be implemented by responsible management as deemed appropriate when analyses reveal adverse quality trends. These actions may involve specific actions to provide compliance with the Quality Assurance Program and may include follow-up system attribute audits and revision to the Quality Assurance Program. Implementation and close-out of corrective actions shall be effectively monitored by the Director - Quality Assurance to assure timely correction and compliance. The Director - Quality Assurance is responsible for the contents of the Operational Quality Assurance Plan and for ensuring that the 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. The Director - Quality Assurance is responsible for the inspection, monitoring, surveillance and auditing of Quality Assurance Program implementation. He is also responsible to provide the required training and qualification of QA Department personnel and the indoctrination and training of other GPUN personnel in the Quality Assurance Program. 2.9.4 Director - Technical Functions The Director - Technical Functions is responsible, via the Director of Engineering Assurance for development and maintenance of the QCL. HesolicItsinputandcoordinateswith affected organizations to assure a uniform approach to classification of items and activities important to safety. 2.9.5 GPUN - Management Management personnel in each department are responsible for the implementation of the Quality Assurance Program by their division, department or group, including the development of i procedures, training and indoctrination of personnel and implementation of the Program on all important to safety i activities. 5 2 3 b 34 2 8 A003105011 -82 47.0 i

ENuclear OeERATIONAL QUALITY ASSURANCE """' b" PLAN 1000-PLN-7200.01 Title Revision No. 2.0 QUALITY ASSURANCE PROGRAM l-00 2.9.6 External Organizations Quality Assurance Programs and implementing procedures for suppliers or contractors providing materials and services for GPUN which are covered under the scope of this Quality Assurance Program shall be subject, when specified in procurement documents, to review and acceptance by the Quality Assurance Department prior to the consnencement of any important to safety activity. 2.9.7 Resolution of Disputes and Escalations Resolution of disputes involving quality arising from a difference of opinion between QA/QC personnel and other organization (engineering, procurement, manufacturing, construction, operation, maintenance, etc) personnel shall, if' possible, be accomplished.at the level at which such disputes occur. If this is not possible, the difference of opinion shall be escalated through supervisory / management levels until resolution is achieved. The Director - Quality Assurance shall make the decision on matters concerning inspection and acceptance to established requirements. The Director - Technical functions shall make l the decision on matters concerning interpretation of technical requirements or design changes. The Director-Quality Assurance shall be responsible for evaluating deficiencies for trends. Significant or repetitive failures to comply with administrative, technical or operational Quality Assurance controls will be further evaluated to determine the safety significance of the condition. In these cases, management 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. 5 .C 5 1< A000105011 82 48.0

ENuclear N e ber OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL 0F DOCUMENTS AND RECORDS 1-00 3.0 CONTROL OF DOCUMENTS AND RECOROS 3.1 Instructions, Procedures, Drawings and Policies 3.1.1 Policy The GPUN Quality Assurance Program requires that activities important to safety be prescribed by documented procedures, instructions, and/or drawings of a type appropriate to the circumstances and that these activities be accomplished in accordance with these documents. All user personnel must be indoctrinated to the above prior to implementation. 3.1.2 Requirements Procedures, instructions, drawings, and/or policies which pre-scribe the performance of activities important to safety shall comply with the requirements of this Plan. To accomplish this these documents shall: a. Include quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workman-ship samples) acceptance criteria sufficient for deter-mining that important to safety activities have been satisfactorily accomplished. I b. Require approval and concurrence of responsible per-sonnel prior to the initiation of the important to safety activity, c. Describe the action to be accomplished, d. Define the responsibilities and authorities of personnel performing the activity. e. Describe interfaces with other company elements or other organizations that impact on or are impacted by the activity described in the procedure. f. Be distributed in a controlled manner to preclude the 5 use of obsolete documents and with sufficient number of copies to assure availability to responsible personnel. 5 g. Require that changes be documented and approved prior to E being implemented. ( c a_ c 3 3 A000105011 - 82 49.0 j

OPERATIONAL QUALITY ASSURANCE Number Nuclear PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL 0F DOCUMENTS AND RECORDS 1-00 h.* Require that revisions be reviewed and approved by the same organizations that performed the original review and approval or by organizations designated by the { originating organizations. I Measures shall be established to control and coordinate the approval and issuance of instructions procedures and drawings including changes, which prescribe important to safety activities. These measures shall include the requirements for review of the documents by the Quality Assurance Department. This review is to provide an independent verification that: the documents have been prepared and reviewed in accordance with established policy and program controls; they contain the necessary policy and program requirements including the inspection and verification requirements where applicable; and they contain clear descriptions related to the extent of documenting results of completed actions when required. These documents include operating and special orders, operating procedures, test procedures, equipment and material control procedures, maintenance or modification procedures and refueling procedures. Plant procedures shall be reviewed by an individual knowledge-able in the area affected by the procedure no less frequently than every two (2) years to determine if changes are necessary or desirable. A revision of a procedure may constitute the above review provided the results of the review are documented. 3.1.3 Responsibilities 3.1.3.1 Department Managers The Director / Manager of each department performing activities important to safety is responsible for the preparation, approval and implementation of procedures, instructions and/or drawings necessary to effectively implement this Plan. They are responsible to assure that provisions are made for inter-face controls for internal and external lines of communications among participating organizations and technical disciplines. Where references are required to implement the procedure, they 5 shall be so indicated along with the identification of the specific requirements.of the references which are applicable to 7 the procedure, i_ 2 0_ A0001050tt 82 50.0 .J

Nehr PERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL OF DOCUMENTS AND RECORDS 1-00 3.1.3.2 QualityAssuranceDepartment(QAD) .r The QAD shall review those administrative policies, procedures, and instructions which delineate the methods of complying with the requirements of this Plan. When specified in procurement documents, contractor and vendor Quality Assurance Plans / Manuals, special process procedures, and inspection and test procedures shall be reviewed and approved by QAD prior to releasing the contractor or vendor to start work. Compliance shall be verified through the audit, I surveillance / monitoring and inspection programs. 3.1.3.3 External Organizations Those activities important to safety which are performed by contractors, suppliers, or vendors shall be delineated by docu-mented, approved, and controlled procedures, instructions or H drawings. 3.2 Document Control 3.2.1 Policy Measures shall be established and documented to control the issuance of documents, such as program documents, design docu-j ments, instructions, procedures, and drawings, including changes thereto, which prescribe activities as defined in Section 2.0 of this Plan. These measures shall assure that documents, including changes, are reviewed for adequacy and d approved for release by authorized personnel and are distri-buted to, and used at, the location where the prescribed t activity is performed. 3.2.2 Requirements 3.2.2.1 Written document control procedures shall be established to provide for control of all important to safety activities. These procedures shall address the following documents as a minimum: C a. Drawings g j b. Quality Assurance Plans / Manuals, and Procedures f E h l k 0: 8 0 acooicw n u 51.0 _N

t Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL 0F DOCUMENTS AND RECORDS 1-00 c. Op'erating Procedures & Instructions d. Maintenance Procedures & Instructions e. Design Documents (e.g., calculations, drawings, specifications, analysis) including documents related to computer codes. f. Manufacturing, Construction Modifications, Installation, Test, and Inspection Procedures and Instructions g. Procurement Documents h. FSAR ar.d Related Design Criteria Documents

i. Nonconformance Reports J.

Design Criteria Documents and Specifications k. Test Specifications 1. Operating and Special Orders m. Equipment & Material Control Procedures I n. Refueling Procedures o. QCL p. GPUN Topical Reports 3.2.2.2 All procedures established for document control shall meet the following requirements:

a. Review, approval and issuance criteria for documents and their revisions shall be specified to assure adequate technical and quality requirements are met prior to issue.

b. The organizations or positions responsible for U

reviewing, approving and issuing documents and their revision shall.be specified. [

c. Changes must be documented and approved prior to being implemented.

O 2 3 e A000105011 -82 52.0

Nmnber Nahr OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL OF DOCUMENTS AND RECORDS l-00 d.' Revisions shall be reviewed and approved by the same organizations that performed the original review and approval or by organizations designated by the origi-nating organizations except for documents originated by organizations outside GPUN. In this case, GPUN may designate the review and approval organizations. Approved changes shall be promptly transmitted for incorporation into documents and obsolete or superceded documents shall be eliminated from use.

e. Document distribution must be sufficient to assure that the documents are readily available, at convenient loca-tiens, to responsible personnel prior to commencement of work.

f. The user of 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. Master lists which identify current revision number of documents will be maintained to assist users. As an alternative to master lists, documents may be issued as controlled documents, and as such, shall be stamped " Controlled Copy".

Holders of controlled documents or master lists are responsible for maintaining their assigned copies in a current status. Documents distributed for information only will not be considered to be current, and, as such, will not be used in performing an activity important to safety.

g. In the special case of documents containing information pertaining to plant security, provisions shall be made to prohibit unauthorized disclosure of certain safe-guards information. These provisions shall include identification of the documents, restrictions on their distribution and storage in locked security storage containers.

3.2.3 Responsibilities E 3.2.3.1 Director - Administration ~ Responsible via the Manager Information Management Centers to -j develop, maintain and administer GPUN Policies, Procedures and Plans including procedures for the control of documents and to establish and implement the GPUN Document Control P.rogram. 2 AOOO105011 82 53.0

bCMF OPERATIONAL QUALITY ASSURANCE 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL OF DOCUMENTS AND RECORDS 1-00 l l 3.2.3.2 Director - Nuclear Assurance I Responsible via the Director - Quality Assurance for the review and approval of GPUN Document Control Program procedures for quality assurance requirements and document control measures; and to evaluate the overall document control system effectiveness through review and audit. 3.2.3.3 All functional Managers Responsible for specific document control procedures, as required, which meet the corporate document control policy. Responsible to ensure that documents are available when required; to properly review and approve documents such as procedures, instructions, specifications, drawings, etc. to ensure that changes to documents are 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. 3.3 Quality Assurance Records 1 3.3.1 Policy 1 Quality Assurance records for items and activities covered under the scope of the GPUN Quality Assurance Program shall be identified, reviewed, retained, and retrievable. These requirements are imposed on all organizations performing activities important to safety. Quality Assurance record systems shall be described and controlled by approved written procedures and instructions. 3.3.2 Requirements The procedures established for the generation, collection, storage, maintenance, and retrieval of Quality Assurance records shall meet the following minimum requirements: 5

a. Design specifications, procurement documents, and GPUN 5

procedures shall specify the records to be generated, 2 supplied and maintained by or for GPUN including reten-1 g tion times. Typical records to be specified include a operating logs, maintenance and modification procedures and related inspection results, reportable occurrences, i inspection and verification procedures (excluding com-pleted checklists when results are documented in a 3 8 A000105011 82 %.O

Number Nuclear PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 i Title Revision No. 3.0 CONTROL OF DOCUMENTS AND RECORDS I-00 separate report), results of reviews, inspections, tests, audits, and material analysis; qualification of personnel, procedures, and equipment; other documentation such as calculations, 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 quality of items or activi-ties important to safety.

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. Identification of any conditions adverse to quality. 4. Inspector or data recorder identification. 5. Evidence as to the acceptability of the results. 6. Action taken to resolve any discrepancies noted.

c. Documented and approved measures shall be established for complying with the requirements of codes, standards, and procurement documents regarding record transmittal, retention, and maintenance subsequent to completion of Work.

d. Record storage facilities shall be established and utilized to prevent destruction of quality records by fire, flooding, theft and deterioration by environmental conditions such as temperature or humidity in compliance with the standards, codes and regulatory guides endorsed in Appendix C of this Plan.

e. All records shall be legible and should be capable of 5

being reproduced on coninonly found copying equipment. 3.3.3 Responsibilities y 3.3.3.1 Director - Nuclear Assurance l The Director - Nuclear Assurance is responsible via' the Director - Quality Assurance, for: g AC00105011 82 55.0

Number Nuclear OPERATIMAL QUAUTY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 3.0 CONTROL OF DOCUMENTS AND RECORDS 1-00 I

a. Reviewing procedures for GPUN departments who perform activities related to the maintenance of Quality Assurance records.

b. Establishing a program for the identification, storage, retrieval, and maintenance of Quality Assurance records generated by QAD, until they are turned over for storage.

c. Performing planned and periodic audits to verify adequacy and implementation of Quality Assurance records requirements by both GPUN internal organizations and external organizations.

3.3.3.2 GPUN Division Directors Each Division Director is responsible for:

a. The initiation, collection, maintenance, and storage of records in accordance with approved written procedures which conform to the requirements and policy of this section until such time as they are transferred to the Director-Administration for storage.

i

b. Providing procedures which ensure the maintenance of records sufficient to furnish objective evidence that activities affecting quality are in compliance with the standards, codes and regulatory guides endorsed by this Plan.

3.3.3.3 Director - Administration The Director - Administration is responsible, via: The Manager Information Management Centers, for:

a. The collection, maintenance, and storage of records in accordance with approved written procedures and instruc-tions which conform to the requirements and policy of this section.

b. Providing procedures which ensure the maintenance of a

records sufficient to furnish objective evidence that 5 activities affecting quality are in compliance with the y standards, codes and regulatory guides endorsed by this g Plan. 4 i

c. Establishing and implementing the GPUN Records Control g

System. a 2-AOOO1050 t 1-32 %n +

Number Nuhr OPERAT10NAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 i Title Revision No. 3.0 CONTROL OF 00CUMENTS AND RECORDS 1-00 3.3.3.4 External Organizations Records generated by contractors shall be controlled according to contractor or GPUN procedures until such time as they are turned over to the QAD for review, acceptance, and transmittal to the permanent records file. Purchased equipment records shall be retained by the vendor until the equipment is released for shipment at which time the records required by procurement documents are to be submitted to GPUN. When required by the procurement documents, contractors and vendors shall establish procedures to control Quality Assurance records. Implementation of these procedures shall be assured by performance of source surveillance, monitoring and audits performed by QAD. Records to be submitted with the shipment or retained by the vendor will be specifically identified in procurement docu-ments. These records will be reviewed as necessary by QAD and/or Engineering to provide the required degree of confidence in the adequacy of compliance of the vendor with the require-ments of this section. 5 ?e 3 2 0 34 2 8 AOOO105011 82 57.0

ENuclear Nume.r o'ea^rt0NAL QUALITY ASSURANCE 1000-PLN-7200.01 Title Revision No. 4.0 DESIGN CONTROL l-00 4.0 DESIGN CONTROL 4.1 Policy Measures shall be established and documented to assure that the applicable specified design requirements, such as design bases, regulatory requirements, codes and standards are correctly translated into specifications, drawings, procedures or instructions. Tnese measures shall 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 Requirements Design control measures require that: 4.2.1 The organizational structure be defined, and authority and responsibility of personnel involved in preparing, reviewing, approving and verifying design documents be delineated. 4.2.2 The design bases, safety analysis, design regul~ations, codes and standards and Plant Technical Specifications including all amendments will be reviewed in the design process. They can only be changed with specific approval of the NRC. 4.2.3 The materials, parts and processes selected by design are reviewed to assure that they are suitable for the intended application, including compatibility of materials, accessi-bility for inservice inspection, maintenance and repair, ALARA considerations, personnel safety, fire hazards analysis, associated computer programs, and quality standards. The review will also evaluate suitability with regard to human factors which may effect safe operation and the suitability of comercial grade materials, parts and equipment to the applica-tion. 4.2.4 Internal and external design interface controls, procedures, and lines of comunication among participating design organiza-tions and across technical disciplines are established and D_ described for the preparation, review, approval, release, dis-tribution, and revis. ion of documents involving design inter-3 faces. = 5 4.2.5 Errors and deficiencies in approved design documents, including design methods (such as computer codes) that could adversely Q 2 8 A000to$0it 82 58.0

Nuclear OPERATIONAL QUALITY ASSURANCE Number gtAN icoo. gen.7200.0i Title Revision No. 4.0 OESIGN CONTROL l-00 affect items and activities important to safety shall be docu-mented, and action shall be taken to assure that these errors or deficiencies are corrected. In addition, any errors or deficiencies resulting from the application or use of the design documents shall be identified and corrected. 4.2.6 Deviations in specified quality standards shall be identified and procedures shall be established to assure their resolution and control. 4.2.7 Review of standard "off the shelf" commercial materials, parts, and equipment for suitability of application to structures, systems, and components important to safety shall be conducted prior to selection. 4.2.8 Design verification methods (design review, alternate calculations or qualification testing) shall be established. 4.2.9 Design verification procedures shall be established which assure the following: a. The verifier is qualified and is not directly respon-sible for the design. b. Verification shall be complete prior to turnover of the component or system to Operations, c. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, system design descriptions, and drawings, including flow diagrams, piping and instrument diagrams, system diagrams, facility drawings showing equipment locations and site arrangements. d. The responsibilities of the verifier, the areas and features to be verified, and the extent of documentation shall be identified in procedures. 4.2.10 When verifications are to be accomplished by test: a. Prototype, component or feature testing shall be pe.- formed prior to installation of the equipment, or prior 5 to the point when the installation would become irrever-sible. g 2 b. Verification by test shall be performed under conditions 3 that simulate the most adverse design conditions as determined by analysis. ~ AGOO10M 11 82 59.0

Nder "^ "^' "^" " ^S5""^" PLAN 1000-PLN 7200.01 Titt* Revision No. 4.0 DESIGN CONTROL 1-00 4.2.11 Proce'dures shall be established to assure that computer codes, and changes thereto, are verified, certified and controlled to prevent unauthorized changes. 4.2.12 Design and specification changes, including field changes, will be subject to design control measures commensurate with those applied to the most recently verified design. Design changes shall be reviewed and approved by the o.ganization responsible for the original design or by another organization with compar-able expertise designated to review and approve changes. 4.2.13 Messures shall be provided to assure that responsible plant personnel are made aware of design changes and/or modifica-tions, which may affect the performance of their duties. 4.3 Responsibilities 4.3.1 Director - THI Unit 1, and Oyster Creek The Directors - TMI Unit 1, and Oyster Creek are each responsible through their respective Plant Engineering Directors for the implementation of design control measures in j accordance with approved Technical Functions proceduros. I 4.3.2 Director - Technical Functions i The Director-Technical Functions is responsible for the development and implementation of the design control measures utilized by Technical Functions and Plant Engineering depart-ments. 4.3.2.1 The Director-Technical Functions is responsible through the Director-Engineering Projects and the Director Engineering and Design for coordination and direction of plant modification projects which are outside of the scope of Plant Engineering. To fulfill these responsibilities, the Ofrector-Engineering l Projects and/or the 01 rector Engineering and Design will: l a. Control and coordinate the activities of all contractors with design responsibility. 8 b. Coordinate the efforts nf the System Engineering Depart-T. ment and the Engineering and Design Department on design g reisted projects. 2 c. Review and approve, as appropriate, baseline design l documents such as selected design criteria, flow a diagrams, system descriptions, arrangement drawings, one-line diagrams and logic diagrams. 1 A00010$011 82 60.0

Nahr OPERATIONAL QUALITY ASSURANCE Nurnber PLAN 1000-PLN-7200.01 Title Revision No. 4.0 DESIGN CONTROL 1-00 o Note: This design review does not replace or eliminate the need for design verification by the organiza-tion who performed the design. d. Ensure Quality Assurance review and concurrence of applicable design criteria documents and specifications, and changes thereto. 4.3.2.2 The Director-Technical Functions, through the Director-Systems Engineering, is responsible for: a. Providing conceptual and analytical engineering service to other engineering groups as required. b. Technical administration of nuclear fuel-related engineering 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 Engineering Services Director and the Director-Engineering Assurance, for providing, respectively, cetailed design and drafting services and for the preparation and maintenance of the Quality Classification List (QCL). 4.3.2.4 The Director - Technical Functions is respcnsible through the Director Engineering and Design for oroviding centralized technical capabilities in conventional engineering disciplines as required to produce engineering documents for plant modifications and for the technical performance of components and systems within the nuclear plants. 4.3.3 Director - Nuclear Assurance The Director - Nuclear Assurance is responsible through the Director Quality Assurance for providing Quality Assurance review of desian and engineering documents to assure that appropriate quality requirements have been included. In addition, Quality Assurance will perform planned and periodic 5 audits of responsible design organizations to verify implemen-tation of design control measures. 3 9 i A000105011 82 61.0

I ] l I Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. l 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 I f ' 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement 5.1.1 Policy 5.1.1.1 Procurement of material, equipment and services which are con-sidered important to safety shall be performed in accordance } with written policies, procedures and instructions which shall establish methods for preparation, review, approval, and con-trol of procurement documents and shall provide measures to comply with applicable regulatory requirements. Appropriate measures shall be established to evaluate procurement sources, monitor the activities of consultants, vendors and contractors, and confirm that purchased items and services conform to pro-curement document requirements. The proncams of all partici-pants shall be in accordance with the applicable requirements of the GPUN Operational Quality Assurance Program. 5.1.1.2 The general and specific requirements for the Quality Assurance Program of all vendors and contractors, including their subvendors and subcontractors supplying material, equipment, or services which are considered important to safety, shall be delineated by procurement documents. These quality program requirements shall be commensurate with the degree of com-plexity, the uniqueness, and the importance to safety of the items and services being performed. 5.1.1.3 Quality Assurance measures shall apply to the procurement of materials including new and spare parts, replacement parts, commercial grade items and consumables. Procurement of spare or replacement parts for structures, systems, and components shall be subject to current Quality Assurance Program controls and to codes, standards, and technical requirements equal to, or better than, original technical requirements as superseded byregulatorycommittmentssuchasenvironmentalqualification testing, or in accordance with an approved engineering document. l 5.1.2 Requirements 5.1.2.1 Procurement Documents '2 The requirements for the preparation, review, approval and 3 control of procurement documents shall be delineated in detailed procedures. These procedures shall delineate require-i ments to assure that procurement documents: S 9 e A000105011 82 62.0

UIUI OPERATIONAL QUALITY ASSURANCE Nun 1bw g PLAN 1000-PLN-7200.01 Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 a. Specify the technical and quality assurance requirements ' comensurate with the requirements of this Plan. b. Require applicable quality program requirements to be imposed on subvendors and subcontractors. c. Specify or reference design basis technical require-ments, including applicable regulatory requirements, material, and component identification requirements, drawings, specifications, 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 submitted for review, approval and record informa-tion as applicable, e. Include an identification of those items and activities important to safety. I f. Identify those records which vendors or contractors shall retain, maintain, and control; and those which / vendors or contractors shall deliver prior to use or } installation of the item. u g. Include right of access to vendors or contractors and their subtier vendor and contractor facilities and n records for source inspection and/or audit. I h. 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 implementing procedures which require owner approval prior to obtaining such approva.l. J. Require design organizations performing design activi-ties for GPUN to have and implement quality programs l which include design control provisions equivalent to 5 those provided in the GPUN Quality Assurance Program. T. k. Identify the programs, procedures, activities or g conditions that require GPUN approval and/or release. h f U Measures shall be established for the review, approval, and i release of procurement documents and subsequent revisions. The reviews shall assure the inclusion of the applicable technical, quality, and administrative requirements in procurement docu-a ments prior to their use. 63.0

Nuclear OPERATIONAL QUALITY ASSURANCE Number gLAN icoo.gty.,200.0i Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 Review of procurement documents shall be documented to provide objective evidence of their approval prior to their release. 5.1.2.2 Qualification and Selection of External Organizations Evaluations of prospective suppliers shall be conducted and documented to demonstrate qualifications based upon one or more of the following criteria: a. Review of performance histories which provide records of suppliers' previous capability to provide similar pro-ducts or services. b. Review of the external organization's capability to comply with the GPUN Quality Assurance Program, as applicable to the items or services to be supplied. c. A pre-award survey of the external organization's facilities and Quality Assurance program to determine his capability to supply the items or services that meet the design and quality requirements of the specification. Procedures shall be established to accomplish the evaluation and selection of external organizations. Contracts or purchase orders for material, equipment or services covered by the scope of the Quality Assurance Program shall be awarded either to: d. External organizations who have been qualified by the QAD as having a Quality Assurance program commensurate with the equipment or services to be provided, or e. The external organization will be required, by procure-ment documents, to work under the direct control of the GPUN Quality Assurance Program. In these instances, the supplier will not be required to have a separate quality assurance program. When GPUN's approval of an external organization's quality assurance program is required, it shall be reviewed and approved by GPUN prior to initiation of the activity affected 5 by their program. ~. In the case of " commercial grade items" the supplier does not 5 have to be evaluated; however, the procurement documents shall [ specifically describe the items to be provided to ensure the appropriate quality is maintained. il 6_ A000105011 82 64.0

Nuciear OPERATIONAL QUALITY ASSURANCE Number geAN ioco.g<y_,200.0i Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 5.1.2.3 Manufacturing Assurance Measures shall be established to provide control of manufac-turing activities of vendors. These methods shall be described in detailed written procedures. The attributes of the manufacturing assurance program shall include: a. Provisions for the review and approval of the vendor's drawings, Quality Assurance manual and manufacturing and quality procedures prior to fabrication. When specified in procurement documents vendors may not implement pro-cedures until written notice of GPUN approval is received. b. Established vendor inspection plans that delineate, as rer tired the hold and/or witness points in the manufac-to.ing process for specified review, inspection, verifi-cation and test. c. Methods for resolution of nonconformances where the vendor's suggested disposition is "Use-as-is" or " Repair". Such nonconformances require approval by the responsible engineer and approval of the responsible Quality Assurance organization. QAD will also provide followup of corrective action implementation. d. Planned and systematic audit and surveillance of vendor quality activities. Scope of coverage and frequency shall be determined by the criticality of the furnished items and the evaluated results of vendor qualifica-tions, including pre-award surveys and quality procedure reviews. Revisions to audit and surveillance plans shall be made as warranted by vendor performance. e. Control of vendor document package including review for completeness and acceptability. Inadequate records which render the quality status of item (s) furnished indeterminate shall be sufficient cause for rejection of 5 this item (s). 3 f. Assessments o' vendor control of quality shall be made f 5 at a frequency and depth commensurate with the impor-tance, complexity and quantity of the items furnished. } These assessments shall utilize the qualitative and e AOOO 105011 -82 65.0

ENuclear ~ e-e., OeERAT10NAt auALrTv AssuaANCe PLAN 1000-PLN-7200.01 Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 ' quantitative information provided by vendor noncom-pliance documents; surveillance, inspection and audit reports; and receiving inspection and test records. g. Material acceptance procedures that assure: 1. The material, component, or equipment is clearly identified and that the identification and quantity correspond to the information on the shipping documents and quality records. 2. The item's handling and shipping requirements have been met by the vendor and maintained by the carrier. 3. The item's quality record package or compliance certificate is complete and adequate. 4. The material, component or equipment meets the technical requirements specified in the procure-ment documents, inspection plans, checklists or other special engineering documents. 5. Items delivered which are not in compliance with requirements are documented in accordance with the nonconformance procedure, tagged (As item configuration or storage conditions permit. 1 Additional administrative controls shall be used if tagging is not possible.), segregated (if possible), and prevented from being inadvertently issued for installation or use. 6. Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for t installation or further work. 5.1.3 Responsibilities l S.1.3.1 Director - Administration B The Director - Administration is responsible through the Director - Materials Management for the: 3 a. Administration and operation of contracting, procurement and warehousing activities of GPUN. 3 b. Assurance that the technical and quality requirements, as established by requisitioners, are incorporated into ] contract / procurement documents without revision. 2 A0001050tt 82 66.0

N m ber ENuclear wea^rt0NAL QuAUTY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 c '. Assurance that the contractual, legal and commercial requirements are incorporated into the procurement docu-ments in a manner which will enforce the technical and quality requirements. d. Assurance that documents and records, as required by procurement documents are submitted in a timely manner and that they are complete and legible. e. Assurance that purchase orders and contracts for important to safety items and services are issued to external organizations that have been evaluated and meet the requirements of this QA Plan. 5.1.3.2 Director - Nuclear Assurance The Director - Nuclear Assurance is responsible through the Director - Quality Assurance to: a. Assure that QA0 procedures for the control of purchased equipment, material and services are established, approved, implemented and effective. b. Approve all GPUN procedures necessary for the control of purchased e~quipment, material, and services within the scope of the GPUN Quality Assurance Program. \\ c. Approve supplier Quality Assurance Programs to the extent required in the' procurement documents. d. Review and accept supplier record packages, e. Establish and implement an adequate program of source inspection, surveillance and receipt inspection to assure supplier compliance with contract requirements. f. Review and concur with the adequacy of quality require-ments to determine that they are correctly stated, inspectable and controllable, that there are adequate acceptance / rejection criteria and that the procurement 5 documents have been processed in accordance with established requirements. 5 g. Establish and maintain a Supplier Quality Classification 3 List (SQCL) which documents the results of the evalua-tions of prospective suppliers. 3< i e A000105011-82 67.0

ENuclear o'ea^tto"Al ouALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00 5.2 Identification and Control of Materials, Parts and Components 5.2.1 Policy Measures shall be established to provide for the identification and control of materials, parts and components important to safety. These measures shall assure that incorrect or noncon-forming items are identified and controlled in order to prevent their inadvertent installation or use. Where required by design documents, the system established shall provide trace-ability 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 and 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 Requirements 5.2.2.1 Identification and traceability requirements shall be included in specifications and drawings. 5.2.2.2 Material, parts, and components, including partially fabricated subassemblies or subdivided materials shall be identified to preclude the use of incorrect or defec-tive items. 5.2.2.3 Materials and parts important to safety shall be identi-fled so that they can be traced to the appropriate docu-mentation, including, but not limited to: a. Specifications b. Drawings (including as-builts) c. Procurement Documents d. Physical and Chemical Test Reports 5 e. Nonconformance Reports ~ 7. f. Inspection Reports and Checklists 3 3 ( g. Storage Maintenance Instructions j h. NDE Reports 0 o s ( A000105011 82 68,0 i

Nular OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 5.0 PROCUREMENT AND MATERIAL CONTROL l-00

i. Vendor Certificates of Compliance

~ 5.2.2.4 The location and method of identification shall be specified so as not to affect the form, fit, function or quality of the item being identified. 5.2.2.5 Correct identification of materials, parts and com-ponents shall be verified prior to release for fabrica-tion, shipping, installation, and testing. 5.2.2.6 Where physical identification is either impractical or insufficient, physical separation, procedural control, or other approved means may be employed. 5.2.2.7 A receipt inspection shall be performed at the site to verify that identification for received items is complete and accompanied by appropriate documentation. 5.2.3 Responsibilities 5.2.3.1 Responsible Department Manager Each Department Manager is responsible for ensuring that pro-curement 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 QAD are used. 5.2.3.2 Director - Nuclear Assurance The Director - Nuclear Assurance is responsible through the Director - Quality Assurance for: Quality Assurance review and concurrence of procedures a. for maintaining identification in accordance with the requirements of this section, b. Verification of identification during receipt inspection. Monitoring and conducting inspections, surveillances and c. B audits to verify conformance to the requirements of this section. g 5.2.3.3 Director - Administration The Director - Administration is responsible through the l Director - Materials Management for assuring that correct identification of materials, parts, and components are verified p 8 prior to release for fabrication, shipping, installation and g testing. A000105011 82 69.0 J

T ENuclear Number o'ea^TIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL 0F STATION ACTIVITIES 1-00 6.0 CONTROL OF STATION ACTIVITIES 6.1 Policy 6.1.1 Station activities considered important to safety shall be conducted in accordance with the requirements of this Plan. These activities include but are not limited to design changes, procurement, fabrication, handling, shipping, storage, cleaning, erecting, installation, inspection, testing, opera-tion, maintenance, repair, refueling and modification. 6.1.2 The Quality Assurance requirements for station activities are contained in this Plan and include compliance with applicable USNRC Regulatory Guides and ANSI Standards indicated in Appendix C. These requirements shall be implemented in appropriate procedures governing station activities. The requirements of this Plan apply to all organizations or positions performing functions which affect the quality of structures, systems, components, or activities important to safety. 6.1.3 The following subsections discuss typical activities which are representative of the broad scope of administrative controls and quality assurance requirements that are applicable to station activities. The organizational structures and func-tional responsibilities governing station activities shall be structured so that attainment of the objectives of this Plan is accomplished by those who have been assigned or delegated responsibility for performing t'he work; and verification of conformance to established requirements is accomplished by qualified personnel who do not have direct responsibility for performing or directly supervising the work. Quality Assurance Department activities such as inspection, monitoring, surveillance, reviews and audits are performed to independently verify conformance to this plan, applicable station administra-tion controls, and applicable regulatory and licensing commit-ments. These independent verifications are applied to station activities on a graded approach to the extent necessary to provide adequate confidence that structures, systems, components, and personnel perform satisfactorily to maintain 5 the safety of the station. Station work functions such as routine and abnormal operations, maintenance, repair or rework, i T. in-service inspections, Technical Specification compliance, 5 fuel handling, radwaste handling, radiation protection, y, chemical analysis, housekeeping and cleanliness, fire protec-tion, security, training, environmental requirements, health l physics, and other activities considered important to safety which are discussed in this Plan are controlled to an extent o 3 consistent with their importance to safety. 2 A00010501I-82 70.0

@ Nuclear Number OPERATIONAL ALITY ASSURANCE 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.2 Control of Inspections 6.2.1 Requirements 6.2.1.1 A program for performance of inspections of important to safety activities shall be established and executed by, or for, the organization performing the activity to verify conformance to the documented instructions, procedures, and drawings for accomplishing the activity. Design specifications, drawings, procedures, or instructions shall include the necessary requirements for performance of inspections. These require-ments include acceptance criteria and reference to codes, standards, and regulatory documents. These requirements shall be further translated into procedures, instructions, or check-lists which shall contain, as required, the following: a. Identification of characteristics and activities to be inspected. b. Methods to be used including necessary measuring and test equipment and the accuracy requirements. c. Identification of organization responsible for performing the inspection, d. Acceptance and rejection criteria, e. Identification of required procedures, drawings and specifications, including the applicable revisions. f. Documentation of inspection results including identifi-cation of the individual performing the inspection. 6.2.1.2 Inspectors (including NDE personnel) shall be qualified in accordance with applicable codes, standards and GPUN training programs and their qualification and certification shall be kept current and documented. 6.2.1.3 Individuals performing inspections shall be other than those g 2 who performed or directly supervised the activity being inspected and shall not report directly to the imediate super-2 visors who are responsible for the work activity being 8 inspected. If the individuals performing the inspections are 5 not part of the responsible Quality Assurance organization, the s procedures and personnel qualification criteria shall be re-S viewed and concurred with by the responsible Quality Assurance 2 A000105011 82 71.0

r i Number Neler OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 organization prior to the initiation 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 individuals not assigned first line supervisory responsibility, are not intended to dilute or replace the clear responsibility of first line super-visors for the quality of work performed under their super-vision. When inspections associated with normal operations of the plant (such as routine maintenance, surveillance and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group (reporting to different supervisors), the following controls shall be met: a. The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item. b. The qualification criteria for the personnel are reviewed and found acceptable by the Quality Assurance organization prior to initiating the inspection. 6.2.1.4 Work authorizing documents used to implement work in the field considered important to safety shall be reviewed and concurred with by Quality Assurance Department personnel to determine the need for:

a. Inspection

b. Identification of organization, performing the inspection

c. Identification of witness and hold points

d. Documenting results 6.2.1.5 When QA Hold Points have been established, either con-tractually, by procurement, or internally by plant procedures, work may not proceed beyond the Hold Point until either inspec-tion 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 o or by an approved, documented, engineering and QA alternate. Where verification of inspection is being performed on ~ Q previously accepted lots, sampling inspection shall be e A000105011 82 72.0

Number ENuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVIT'S 1-00 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 equipment and tools, which are calibrated as necessary, and controlled to assure that accuracy requirements are satisfied and that inspections are complete. 6.2.1.7 Inspection 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 docu-mented. 6.2.1.8 Records shall be kept in sufficient detail to provide adequate confirmation of an inspection program. 6.2.2 Responsibilities 6.2.2.1 Director - Technical Functions The Director - Technical Functions is responsible for ensuring that requirements for inspections are included in design specifications, drawings, procedures and instructions and that these requirements include acceptance criteria and, as 1 applicable, references to codes, standards and regulatory docu-ments. 6.2.2.2 Director - Nuclear Assurance The Director - Nuclear Assurance, through the Director - Quality Assurance, is responsible for: a. Assuring that inspectors are qualified in accordance with applicable codes, standards, and GPUN training programs. b. Reviewing and concurring with procedures and work authorizing documents for inclusion of inspection and test requirements and QA Hold Points. c. Reviewing and concurring with the personnel qualifica-2 tion criteria of individuals performing inspections, E including those who are not part of the QA organization. c.j d. Identification of inspection plans to be used for verification of inspections on previously accepted lots. a_ i A000105011-82 73.0

Number gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL 0F STATION ACTIVITIES 1-00 6.2.2.3 Respohsible Department Manager Each responsible Department Manager performing work requiring inspections is responsible for: (a) Notifying the QA Department of the work being performed. (b) Obtaining QA concurrence with the procedure and/or work authorizing document. (c) Assuring that established QA Hold Points are not bypassed without prior QA authorization. (d) Assuring that all information, records or copies of records associated with their work are made available to QA personnel. Each responsible Department Manager performing inspections is responsible for: (e) Assuring that the personnel performing the inspection is qualified in accordance with applicable codes, standards, training programs and procedures. (f) Assuring that the results of all inspections are properly documented and the results are evaluated by designated personnel. 6.3 QA Monitoring 6.3.1 Requirements 6.3.1.1 A program for QA Monitoring of activities affecting important to safety items or processes shall be established and executed by the QA Department. 6.3.1.2 Monitoring is used to establish adequate confidence levels that important to safety activities are being performed in accordance with the QA Program requirements and plant adminis-trative controls. Monitoring will be performed on a graded 5 approach and the degree of monitoring performed shall be based typically upon the status and safety importance of activities, ~. extent of previous experience, thoroughness of overall 5 coverage, uniqueness of testing or operating activities and { trending data. O A000105011-82 74.0

Nder PERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.3.1.3 Monitors shall be qualified in accordance with a documented QA Department procedure that ensures.that Monitors are knowledge-able in the activities they are monitoring to the extent that they can readily verify compliance of the activity being per-formed. 6.3.1.4 Monitoring reports shall contain as a minimum the following: Identification of activity being monitored including a. specific reference to the program or procedural require-ments governing the activity. b. Indication of compliance. c. Identification 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 when such nonconformances exist and are identified as a result of the monitoring. 6.3.1.5 Records shall be kept in sufficient detail to provide adequate documentation of a monitoring program. 6.3.2 Responsibilities 6.3.2.1 Director - Nuclear Assurance The Director - Nuclear Assurance through the Director - Quality Assurance, is responsible for: a. Establishing the requirements for QA monitoring of activities affecting important to safety materials, f parts, components and practices. t b. Assuring that QA Monitors are adequately trained and are qualified to perform their duties. 2 c. Assuring that. reports of the monitoring activities have T. sufficient details and provide adequate confirmation of ~ the monitoring program. 2 3< 2 A000105011 82 75.0

Nuclear OPERATIONAL QUALITY ASSURANCE Number PLAu ioco. gly _,200.0i Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.4 Control of Special Processes 6.4.1 Requirements 6.4.1.1 Special processes are those that require interim in process controls in addition to final inspection to assure quality including, but not limited to, such processes as welding, heat treating, chemical cleaning, and nondestructive examination. 6.4.1.2 Measures shall be established and documented to assure that special processes are accomplished under controlled conditions in accordance with applicable codes, standards, applications criteria, and other special requirements including the use of qualified personnel and procedures. 6.4.1.3 Procedures for special processes shall be established to meet the requirements of applicable codes and standards 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 pro-cesses. Procedures and instructions for the control of special processes shall be reviewed and approved by qualified personnel. Procedures, equipment, and personnel performing special processes shall be qualified in accordance with applicable codes, standards, and specifications. Organiza-tional responsibilities shall be delineated for the qualifica-tion of special processes, equipment and personnel. Qualifica-tion records of personnel, equipment, and procedures associated with special processes shall be established, maintained and kept current. For special processes not covered by the existing codes or standards, or when item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures and equipment shall be defined in the procedure. 6.4.2 Responsibilities 6.4.2.1 Responsible Department Manager Each responsible Department Director / Manager performing special 5 processes is responsible for: Assuring that'the established program requirements for a. 5 controlling and accomplishing special processes are i implemented. 3 b. Assuring that the procedures, including changes, are l reviewed, approved and qualified prior to use. O AOOO 105011 82 76.0

gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 c.' Assuring that personnel and equipment used in the per- ~ formance of special processes are qualified and the records of qualification are maintained. 6.5 Test Control 6.5.1 Requirements 6.5.1.1 A documented test program shall be established to assure that all testing required to demonstrate that the structure, system or component considered important to safety will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test pro-cedures which incorporate or reference the requirements and acceptance standards contained in the applicable design docu-ments. The extent of testing shall be based on the complexity of the modification, replacement, or repair.

Testing, including proof tests prior to installation, hydro testing.

Inservice Testing (IST) and preoperational tests, necessary to demonstrate that structures, systems and components will per-form satisfactorily in service, shall be accomplished in accordance with written approved procedures. These procedures shall be based on requirements and acceptance limits contained in 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 the test, including caution or safety notes in sufficient detail to avoid operator interpretation, Test prerequisites such as calibrated instrumentation, c. adequate test equipment and instrumentation including accuracy requirements, completeness of item to be tested, suitable and controlled environmental con-ditions, and personnel to be provided to conduct testing under the direction of a qualified test engineer. 5 d. Provisions for data collection and storage. ~ T. l Acceptance and rejection criteria as specified in design e. y and procurement documents. ~ 2 b \\ 1 3! A000105011 82 77.0

N d er Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 f. Methods of documenting or recording test data and results, in sufficient detail to prevent misinterpreta-tion. g. Mandatory hold or witness points for inspection by GPUN Quality Assurance and/or other designated personnel. h. Provisions for control of jumpers, lifted leads and jurisdictional or safety tags, i. Provisions for returning a system to normal configura-tion upon completion of the test, including verification. J. Provisions for assuring test prerequisites have been met. 6.5.1.2 Test results shall be documented, evaluated, and their accept-ability determined by a responsible individual or group. 6.5.1.3 The test program shall cover all required tests including: a. Preoperational tests of components or systems to demon-strate 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 opera-tion) to confirm compliance to design criteria. c. Tests during the operational phase to provide assurance that failures or substandard performance do not remain undetected and that the required reliability of systems Important to Safety is maintained, d. Tests during activities associated with plant main-tenance during the operational phase and to demonstrate satisfactory performance following plant maintenance or procedural changes. 6.5.1.4 Tests performed following plant repairs or replacements shall be conducted in accordance with the original design and testing 5 requirements or approved, documented alternatives. Testing shall be sufficient to confirm that the changes reasonably produce expected results and that the change does not reduce safety of operations. 0 2 9 Accologott 82 78.0

N **' ENuclear oaEuTIONAL QUAUTY ASSUMNCE f PLAN 1000-PLN-7200.01l Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.5.2 Responsibilities 6.5.2.1 Ofrectors TMI Unit 1, and Oyster Creek The Director of the nuclear generating stations are each responsible for assuring that testing performed at their assigned station is performed in accordance with the require-ments of this Plan including, as a minimum, the following: a. Assuring that testing is performed in accordance with written, approved and controlled procedures, b. Assuring that coerations personnel have the required special training and skills, c. Assuring that the test results are documented and are evaluated for acceptability by a responsible individual or group. d. Assuring that identified discrepancies are addressed, resolved and reported as required by the Operating License and Technical Specifications of the Unit. 6.5.2.2 Director - 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,ll include: facilities and systems are tested. These responsibilities sha a. Preparing test plans and implementing procedures. b. Directing testing and assuring test engineers have the required special training and skills, c. Ensuring that test documentation is completed, as required, and reviewed prior to turnover to Operations. d. Coordinating technical assistance of testing. 5 6.5.2.3 Director - Maintenance Construction and Facilities I' The Of rector - Maintenance, Construction and Facilities, j through the applicable station Maintenance and Construction Director, is responsible for: l a. Assuring supporting personnel have the required special g training and skills. 1 A0001099It-82 79.0

3 Neer Nuclear OPERATIONAL QUALITY ASSURANCE { PLAN 1000-PLN-7200.01 i l Titf8 Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 b. Assuring that all construction testing performed as part of maintenance and modifications, including hydrotesting, is performed, documented and the results acceptable prior to turnover. 6.6 Control of Measuring and Test Equipment 6.6.1 Requirements 6.6.1.1 Measures shall be established to assure that tools, gauges, instruments, and other measuring and testing devices used in activities affecting the function or quality of structures, systems, and components, including operations, maintenance, modifications, plant chemistry and radiological and environ-mental control activities, covered under the scope of the QA Program be properly controlled and calibrated or adjusted at specified periods to maintain accuracy within specified limits. Additional measures shall be established to ensure that the range, type and accuracy of the measuring and test equipment conforms to the specified requirements. 6.6.1.2 Requirements for each control program shall include inspection and verification of accuracy upon receipt of equipment, identi-fication of all gauges and instruments, calibration and scheduled recall for calibration and traceability to an accepted Standard. These activities shall be subject to QA0 monitoring and auditing. Procedures shall be established to implement the following requirements: a. Establish the calibration technique and frequency requirements, maintenance requirements, and controls for all measuring and test equipment which are used in the measurement, inspection, and monitoring of com-ponents, systems, and structures covered under the scope of the Quality Assurance Program (instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive examination equipment). b. The identification of measuring and test equipment traceable to the calibration test data. 5 c. Installed plant instrumentation and operations measuring and test equipment requiring calibration shall be 7. labelled, tagged or otherwise controlled in accordance with written approved procedures to assure that 2 approved calibration intervals are not exceeded. 2 Portable measuring and test equipment may be similarly l controlled; but shaII, as a minimum, be clearly labelled to indicate the date on which the current calibration 0 expires. Measuring and test equipment that has exceeded the approved calibration interval shall not be used for ~ f measurements or tests. ( A000f090tt 82 f 80.0 i

e gggy OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title t'avision No. 6.0 CONTROL OF STATION ACTIVITIES 1 -m d' Establish calibration frequency for measuring and test equipment based on required accuracy, purpose, degree of usage, stability characteristics, and/or any other condition which may affect the measurement. A calibra-tion recall system shall be implemented to assure recalibration within the required period for each piece of measuring and test equipment covered under the scope of this program. e. Establish methods for determining the validity of previous inspections performed when the measuring and test equipment 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. f. Measuring and Test equipment (M &TE) used to calibrate instruments and gages (flowmeters, pressure gauges, level indicators, etc.) shall have been calibrated against working standards with accuracies at least four times greater than that of the equipment being cali-brated. The instrument or gage calibration accuracy in reference to the M & 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 1:1 and the secondary standards used to calibrate the working standards shall have an accuracy of four times greater than that of the working standards. When the above requirements cannot be met, the standards used shall have a precision and repeatability that assures the equipment being calibrated will be within the required tolerance. The basis of acceptance will be documented and authorized by the supervisor of the calibrating organization. l 5 g. A status of all measuring and test equipment under the calibration program is to be maintained. 5 h. Utilization of reference and transfer standards trace-y able to nationally recognized standards. Where national standards do not exist, provisions shall be established -j to document the basis for the calibration, ij A0001050If 82 81.0 s

l Number Nuc br oaea^rr0NAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 l Title Revissort No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 \\ f. NDE equipment shall be controlled and calibrated in accordance with the industry code governing its use. ( 6.6.2 Responsibilities 6.6.2.1 Responsible Department Manager Each Department Manager utilizing tools, gauges, instruments and other measuring and testing devices in activities affecting the function or quality of structures, systems, components and activities important to safety shall assure that the equipment is controlled in accordance with an approved calibration con-trol program which complies with the requirements of this Plan. 6.7 Handling, Storage and Shipping 6.7.1 Requirements 6.7.1.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, packaging, and preservation of items important to safety in accordance with established instructions, procedures, and drawings to prevent damage, deterioration or loss. The requirements for handling, storage, packaging and shipping of radioactive wastes are contained in Section 7.0 of this Plan. 6.7.1.2 Procedures shall be established to control the cleaning, j handling, storage, packaging, and shipping of materials, com-j ponents, systems in accordarice 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 limited to, the following: a. Packaging and preservation procedures to provide 4 assurance of adequate protection against corrosion, contamination, physical damage or any effect which would lower the quality of the items or cause deterioration during shipping, handling or storage. Special protec-g tive environments, special coverings, inert gas atmos-pheres, mois.ture contents, and temperature controls T. shall be specified as required and their existence verified and documented. I 1 1 A00010$0ll 82 82.0 1

Number h d g g' OPERATIONAL QUALITY ASSURANCE 1000-PLN-7200.01 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES l-00 b.' Cleaning methods to provide assurance that necessary cleaning operations are carried out prior to packaging, storage or installation. The level of cleanliness required, and verification and documentation require-ments shall be specified in the procedures. c. Detailed handling methods for all items that require special handling. 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 established intervals to ensure their reliability and availability for use. d. Storage practices to provide for methods of storage and the control of items in storage which will minimize the possibility of damage or deterioration during storage. Periodic inspections of storage areas shall be performed and documented to verify compliance with storage pro-cedures. Release of items for installation shall also be procedurally controlled. e. Provisions to assure that proper marking and labeling of items and containers is accomplished to provide identi-fication and necessary instructions during packaging, y shipment and storage. f. Provisions for documen' ting and reporting nonconformance to handling, and shipping requirements. g. Provisions for the storage of chemicals, reagents, lubricants and other consumable materials which will be used in conjunction with systems which are important to safety. h. Provisions for " Limited Life" requirements (including " Shelf Life" and " Service Life" for applicable materials). 6.7.2 Responsibilities 3j 6.7.2.1 Responsible Department Managers j Each responsible Department Director / Manager is responsible for i, identifying in procedures, drawings, specifications or procurement documents those handling, storage and shipping g Q requirements necessary to assure compliance with the require-8 ments of this Plan. 2 i e AOOO105011-82 0 83.0 N

ENuclear ~~., we=TI0nat ouAuroSsuuNCe \\ PLAN 1000-PLN-7200.01l Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.7.2.2 Director - Administration ~ The Director - Administration, through the Director - Materials Management, is responsible for: a. Providing the procedures applicable to receiving and storage of materials, parts and components, b. Assuring that the personnel responsible for the handling and storage of mate-ials, parts and components are adequately trained in the performance of their duties and that they implement the procedures properly. c. Providing adequate storage of important to safety materials, components and parts. 6.7.2.3 Directors TMI Unit 1, and Oyster 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 per-formed in accordance with the requirements of this Plan. 6.7.2.4 Director - Maintenance, Construction and Facilities The Director - Maintenance, Construction and Facilities is responsible for assuring that the handling, cleaning and storage requirements of tnis Vlan are incorporated in the procedures and are properly implemented on all maintenance and modification projects performed at the generating stations. 6.8 Inspection, Test, and Operating Status 6.8.1 Requirements 6.8.1.1 Measures shall be established and documented to ensure that the required inspections and tests are performed and that the acceptability of items with regard to inspection and tests performed is known throughout manufacturing, installation, and operation. Status of items covered by the scope of this Plan T. shall be controlled in accordance with approved procedures. 5 These procedures shall include the use of appropriate tags, E markings, lists, logs, diagrams, electrical and mechanical jumpers, or other suitable means, to assure that required l inspections and tests are satisfactorily completed to prevent l 5 A0001050t1 82 84.0 i

Number Nuclear o = rto"AL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 inadvertent bypassing of required inspections and tests and to prevent inadvertent operation. 6.8.1.2 The requirements for an acceptable inspection, test and operating status program for structures, systems, and com-ponents throughout fabrication, installation, test and opera-tion include: Design and quality documents which address the require-a. ments for the identification of inspection, test, and operating status of structures, systems and components. b. Procedures which include controls for the application and removal of inspection and welding stamps, and other status indicators such as tags, jumpers, markings, labels, and stamps, Procedures for controlling the bypassing or altering of c. the sequence of required inspections, tests or other critical operations are procedurally controlled with concurrence by the Quality Assurance organization. The procedures shall provide for the identification of items which have satisfactorily passed such inspections and tests, where necessary to preclude inadvertent bypassing of required inspection and tests. d. In cases where documentary evidence is not available to confirm that an item has passed required inspections and tests, that item shall be considered nonconforming until such evidence becomes available. Affected systems shall also be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions. Procedures requiring identification of the operating e. status of systems, components, controls, or support equipment in order to prevent inadvertent or unauthor-ized operation. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status. Independent B verification shall be required ensure that necessary measures,, where appropriate, to such as tagging equip-ment, have been implemented correctly. = f. Methods which ensure temporary modifications / variations l shall be controlled by approved procedures which include l a requirement for independent verification. A log shall D_ 1 A000 05011 82 85.0

Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Totie Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 ' be maintained of the current status of such temporary modifications / variations. l g. Methods which ensure that nonconforming services and inoperative or malfunctioning structures, system, com-l ponents or materials shall be identified in accordance with the requirements of this Plan. 6.8.2 Responsibilities 6.8.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for assuring that the appropriate requirements for controlling the inspection, test and operating status, including independent verification, are incorporated in the procedures used on all fabrications, installation, test and operation activities performed at their respective stations. 6.9 Housekeeping and Cleanliness 6.9.1 Requirements 6.9.1.1 Good housekeeping practices shall be utilized at all times t.o maintain the facilities ir, 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 important to safety parts of the nuclear plant. 6.9.1.2 Housekeeping encompasses all activities related to the control of cleanliness of facilities, materials and equipment; fire prevention and protection including disposal of combustible material and debris; control of access to areas, protection of equipment, radioactive contamination control; and, storage of solid radioactive waste. 6.9.1.3 Housekeeping practices shall assure that only proper materials, equipment, processes, and procedures are utilized and that the quality of the item is not degraded as a result of housekeeping D practices or techniques. During maintenance activities, cer-tain portions of safety-related systems or components may be subject to potential contamination with foreign materials. To 5 prevent such contamination, control measures, including measures for access control, and tool accountability shall be established. Additionally, immediately prior to closure of g system (s)orcomponent(s),aninspectionshallbeconductedand 1 A000105018 82 86.0 1

M Nuclear OPERATIONAL ou4u r o SSuRANce Number 1 PLAN 1000-PLN-7200.01 Title 3 Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 documented to ensure cleanliness. Special housekeeping considerations shall be made for maintenance of radioactively contaminated systems and components. 6.9.2 Responsibilities 6.9.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining programs and practices for housekeeping and cleanliness control of all work activities performed by the plant site staff, support organiza-tions and contractors in accordance with the requirements of the GPUN QA Program. 6.9.2.2 Director - Nuclear Assurance The Director - Nuclear Assurance, through the Director - ) Quality Assurance is responsible for monitoring the house-keeping and cleanliness practices at the nuclear generating stations and for identifying problems and initiating, reconsnending or providing solutions through designated channels. 6.10 Equipment Control 6.10.1 Requirements 6.10.1.1 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 opera-tional 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 without specific advanced approval by the designated Operations management personnel in each instance. The procedures for controlling the removal from service and the placement back into service of 9 equipment shall require: { Control measures such as locking or tagging to secure a. ,j and identify equipment in a controlled status. /, 2 Q Independent verifications when necessary to ensure that C s b. 4 measures, such as tagging equipment, have been g implemented correctly, s acooioso it s2 I on n ]

Nder OPERATIONAL LITY ASSURANCE Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 c.' Control measures for temporary modifications / variations, l such as temporary by-pass lines, electrical jumpai5, lifted electrical leads, and temporary trip point settings. Included shall be a requirement for independent verification of installation and removal (A log shall be maintained of the current status of temporary modifications / variations.) 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. e. When equipment is ready to be returned to service, operating personnel shall place the equipment in opera-tion and verify and document its functional accept-ability. f. The equipment shall be adequately identified on the l documentation to assure traceability. 6.10.2 Responsibilities 6.10.2.1 Directors TM! Unit 1, and Oyster Creek The Ofrectors of the nuclear ger.erating 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 proper implementation. 6.11 Control of Construction, Maintenance (Preventive / Corrective)_ and Modtrications 6.11.1 Requirements 6.11.1.1 Construction, maintenance or modifications which have the potential to affect the functioninn of structures, systems or components important to safety shall be performed in a manner ,;i to ensure quality at least equivalent to that specified in the original design bases and requirements, materials specifica-tions and inspection requirements. A suitable level of con-i fidence in structures, systems or components on which main-k_ tenance or modifications have been performed shall be attained 1 1 A000tol0tt82 88.0 J

Nuclear OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Iltle Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 by aphropriate inspection and performance testing. Construc-tion, maintenance or modification of equipment shall be pre-planned and performad in accordance with written procedures, ) instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria. in this regard, modification 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 advanced approval by the designated Operations management personnel in each instance. 6.11.1.2 Detailed step by step procedures are not required for all main-tenance 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 purs, replacing fuses or tightening valve 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. 6.11.1.3 Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure but are subject to general administrative procedural controls that govern or define the following areas: a. Methods for obtaining p6rmission and clearance for operation personnel to work and for logging such work, b. Factors to be taken into account, including the necessity of maintaining occupational radiation exposure as low as is reasonably achievable (ALARA). c. Method for identification of what procedural coverage is necessary for the maintenance, construction and modifi-cation activity. d. Considerations for system / equipment cleanliness control. B c. Method for Identification of post maintenance, construc-tion or modification, testing, including 3 system / equipment functional capability to meet opera-y tional requirements in all resNets. 4 1 A00010591l92

NucIear OPERATIONAL QUALITY ASSURANCE Number gun iOOO-etN-n00.0i Title ' Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 l 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 qualifications 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 identify the inspection and test status of items to be used in maintenance, modification, and j construction activities. 6.11.1.5 A corrective maintenance program shall be developed to maintain structures, systems and components important to safety at the quality required for them to perform their intended functions. Corrective maintenance shall be performed in a timely manner to ensure that important to safety items are adequately maintained in the original, as designed, functional status. 6.11.1.6 A preventive maintenance program including procedures as appropriate for structures, systems, and components important to safety shall be established wnich prescribes the frequency and type of maintenance to be performed. In all cases, main-tenance shall be scheduled and planned so as not to compromise the safety of the plant. Planning shall consider the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Preventive maintenance shall be performed in a timely manner to ensure that important to safety items are adequately maintained in the original, as designed, functional status. 6.11.1.7 Proposed modifications shall be reviewed, approved and con-trolled in accordance with the applicable requirements of the Operating License and Technical Specifications and procedures 8 governing the design, procurement, construction, testing and Inspection. Modifications to structures, systems and com-7. ponents important to safety shall be reviewed and accepted in 3 accordance with the requirements of Section 2.8 of this Plan. 9 2 4 A0001090tt 42 90.0

l Nebr OPERATIONAL QUALITY' ASSURANCE Number PLAN 1000-PLN-7200.01 l 'itle Revision No. I 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.11.1.8 Design, procurement, construction, testing and inspection of i all modifications shall be performed in accordance with the applicable portions of this Plan. 6.11.1.9 Modifications and repairs, including design and procurement, may be performed by plant engineers without the direct involvement of Technical Functions. The scope and limits of responsibility of plant engineering shall be described in implementing procedures which have been reviewed and approved l by the Director - Technical Functions. Upon completion of the design phase of a modification, Technical Functions turns the project over to Maintenance, Construction and Facilities for installation with a document t package which includes the necessary specifications and drawings. Procurement of the required materials, parts and components is generally initiated by Technical functions, but may be initiated by other organizations as necessary. ) Maintenance, Construction and Facilities prepares the necessary l installation procedures in accordance with the design requirements, completes the installation and construction testing and compiles the records 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. Maintenance, Construction and Facilities shall notify Quality Assurance and, where applicable, the Authorized l Inspection Agency shall be notified of all witness and hold f points in sufficient time for performance of the inspection. Witness and hold points may be waived only with prior written i authorization from the QA Department. 6.11.2 Responsibilities 6.11.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for: 5 a. Establishing and implementing preventive and corrective ~ maintenance programs to maintain the station in a safe, reliable and efficient condition. N b. Ensurino that maintenance and modification activities are performed in accordance with the requirements of l this Plan and the applicable Operating License and g Technical Specifications. 1 A00010$0tI 8J 91.0

l EiUI OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 I Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 c.' Establishing adninistrative control procedures for j maintenance and modification work performed at his i assigned station. 6.11.2.2 Director - Technical Functions The Director - Technical Functions is responsible for: a. Reviewing and approving the procedures which define the scope and limits of responsibilities of plant l engineering with regards to minor modifications and repairs. b. Ensuring that design and procurement activities associated with plant modifications are implemented in accordance with approved procedures. c. Providing the drawings and specifications used for plant modifications. d. Preparing and issuing as-built drawings of plant modifications, as appropriate. 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, engineering and Technical Functions initiated procurement records in accordance with the QA Records requirements of this Plan, g. Providing the design and engineering support d'Jring installation and testing of plant modifications including the resolution of engineering problems identi-fled during installation. h. Maintaining control of technical configuration of the plants and maintaining the associated drawings current. 6.11.2.3 Director - Maintenance, Construction and Facilities C The Director - Maintenance, Construction and Facilities. through the applicable station Maintenance and Construction g Director, is responsible for: 2 a. Reviewing the requirements of the modification packages l and preparing the appropriate installation procedures and supporting documentation. 1 A0006060tt 82 92.0

gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 b. Providing the supervision and labor necessary to ~ complete the modifications. c. Ensuring that the modifications are installed in accordance with the engineering requirements. Deviations from approved specifications are not author-ized except as specifically approved by Technical Functions and concurred with by QA, in advance. d. Providing Technical Functions with the information necessary to prepare and issue as-built drawings, e. Preparing and filing installation records in accordance with the QA Records requirements of this Plan. 6.11.2.4 Director - Nuclear Assurance The Director - Nuclear Assurance, through the Director - Quality Assurance, is responsible for: a. Review and concurrence with installation procedures or equivalent work - related documents. b. Performing inspections and examinations required for completion and acceptance of the installation. c. Concurrence with the quality requirements in fabrication and installation specifications. 6.12 Control of Surveillance Testing and Inspection 6.12.1 Requirements 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 that important to safety structures, systems, and components will continue to operate, keeping parameters within normal bounds, or will act to put the plant in a safe condition if they exceed normal bounds. 2 6.12.1.2 Provisions shall be made for performing required surveillance testing and inspections, including inservice inspections. Such 3 provisions shall include the establishment of a master 3 surveillance schedule reflecting the status of all planned inplant surveillance tests and inspections. Frequency of g surveillance tests and inspections may be related to the _a results of reliability analyses, the frequency and type of service, or age of the item or system, as appropriate. A000105011 82 Q1.O

ENuclear Neen OPERATIONAL QUALITY ASSURANCE f PLAN 1000-PLN-7200,011 Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 6.12.1.3 Addi'tional control procedures shall be instituted, as necessary, to assure timely conduct of surveillance tests and inspections and aporopriate documentation, reporting, and evaluation of the results. Procedures shall be established to assure proper review of surveillance test data and the return of systems to an operable status following the completion of testing. These procedures shall include provisions for the documentation of authority, conduct, responsibility, and verification involved in returning the system to an 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 Oyster Creek The Directors of the nuclear generating stations are each responsible for: 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 requi,rements for Surveillance Testing and Inspection are completed as required. 6.13 Radiological Control 6.13.1 Requirements 6.13.1.1 A radiological controls program shall be established and implemented at each station to: a. Control radiation hazards b. Avoid accidental r;diation exposures 3 c. Maintain exposures to workers and the general population as low as reasonably achievable (ALARA) and within a 3 regulatory requirements. d. Provide guidance and specify appropriate methods or g techniques to ensure that the performance of activities i e A000105011 82 94.0

gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01, Title Revision No. 6.0 CONTROL OF STATION ACTIVITIES 1-00 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 applicable activities of each and every phase of operations at the nuclear generating stations. 6.13.1.3 Procedures shall be provided for the implementation of the radiological controls program. These procedures shall contain the requirements for implementation of the program by the Pcdiological Controls Depcrtment and the requirements for inclusion of radiological controls in the plant operation, maintenance and testing procedures. 6.13.1.4 The radiological controls program includes the acquisition of data and provision of equipment to perferm necessary radiation surveys, measurements 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 requirements of the radiological controls program as applicable to their activities are adequately included in procedures and that the procedures are implemented properly. 6.13.2.2 Director - Radiological & Environmental Controls The Director - Radiological & Environmental Controls is responsible for: Establishing and maintaining the radiological controls a. program. b. Providing the personnel, procedures and administrative controls to implement the radiological controls program. 5 c. Providing tdministrative and technical guidance applicable to radiological controls, radioactive T. materials, respiratory protection and radiological 5 engineering including ALARA programs and dosimetry [ control. 2 !e-A000:050tt 82 95.0

"^ "^' "^ " ^5S""^"'E Nular l PLAN 1000-PLN-7200.01 Title Revision No. 7.0 CONTROL OF RADIOACTIVE WASTE l-00 7.0 CONTROL OF RADIOACTIVE WASTE 7.1 Policy 7.1.1 Measures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71, Title 10, Part 20, and Title 49, Parts 100 through 199 applicable to the packaging and transporting of radioactive wastes are satisfied. 7.1.2 Subpart H to 10 CFR 71 identifies the quality assurance l criteria applicable to the control of radioactive waste. The portions of this Plan that relate to the criteria in Subpart H l to 10 CFR 71 describe to a large extent the administrative controls and quality requirements to be applied in the control, packagino and transportation of radioactive material. A comparison of the requirements of 10 CFR 71, Subpart H and the l applicable sections of this Plan are listed in Appendix A. These sections of this Plan will be implemented to. satisfy the requirements of Subpart H to 10 CFR,71. l 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 be implemented to verify compliance with Title 10, Part 61.55 (Waste Classification) 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 Requirements 7.2.1 Procedures and administrative controls shall be developed and implemented to cover the following: a. Processing of radioactive wastes including the collec-tion, handling and preparation for shipment of radio-active liquids and solids. These procedures shall be 5 consistent with the ALARA program and shall clearly identify the administrative controls and organizational T. responsibilities. 5 b. Training and qualification of personnel operating radio-2 active waste processing equipment, health physics inoni-toring, packaging and shipping (which includes Waste Classification and establishment of Waste Characteristics) and other operations deemed appropriate by management. A000105011 82 96.0

u. o., MNuclear 0?enari0nAt auAtzrr assurance PLAN 1000-PLN-7200.01 Revision No. nue 7.0 CONTROL OF RADI0 ACTIVE WASTE l-00 c.' The activities associated with the packaging of radio-active 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, Radiological 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, 10CFR71, and 49CFR. d. Movementofradioactivematerialswithinandoutsidethe protected area to assure personnel protection at all timet. e. The shipment of radioactive material from the Station to be in accordance with the regulations of the U.S. Department of Transportation for the transportation of hazardous materials (49CFR) and of the NRC (10CFR71 and 10CFR20). f. The packaging used for transporting of radioactive wastes, whether purchased from an outside supplier or designed by GPUN, shall meet the applicable requirements of 10CFR20,10CFR71 and 49CFR. l 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 basis of their experience, knowledge of DOT regulations, 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, stowage control, reporting of incidents and security. 5 7.2.3 Radwaste operations shall be controlled to minimize personnel exposures or environmental contamination consistent with ALARA. 7 5 7.2.4 Operations procedures relating to radwaste shi:. ping and y packaging shall be reviewed by QAD to establish any necessary witness or hold points or activities to be monitored. S l B_ A0001050ti 82 1 97.0

Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 g Revision No. 7.0 CONTROL OF RADI0 ACTIVE WASTE 1-00 7.3 Resp'onsibilities 7.3.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations, thru their on-site staffs shall develop and implement procedures for minimizing the generation of radwaste materials and the pro-cessing of radioactive waste and movement of radioactive materials. These procedures shall include the following: 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 rags, papers, boots, gloves, etc. and have them moved to the Radwaste facility for packaging. d. Selection of the proper packaging for the specific con-tents to be shipped, taking into consideration the radiation levels, contamination 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 l seal and advises the carrier that the shipment is ready. e. Review and acceptance of carrier procedures specified by the procu,rement documents covering the acceptance of I radioactive waste materials for shipment. f. Review and acceptance of the designs of packaging l purchased from an outside supplier. 7.3.2 Director - Radiological and Environmental Control The Director - Radiological and Environmental Control is responsible, for monitoring all radiological activities 2 associated with the processing and handling of radioactive wastes and for providing advice on radiological matters relating to processing, packaging and shipping. = j 7.3.3 Director - Nuclear Assurance l The Director - Nuclear Assurance is responsible, thru the Director-Quality Assurance: 2 a A000105011 82 98.0

Nuclear oeea^rIo"^' oud'rtv AssuaANCE I PLAN 1000-PLN-7200.01 Titte Revision No. 7.0 CONTROL OF RADI0 ACTIVE WASTE l-00 For review and concurrence with procedures describing a. control of radioactive waste. b. To monitor, inspect and audit radioactive waste processing operations and radioactive material packaging and shipping to the extent necessary to verify they are performed in accordance with established procedures, applicable administrative controls and regulatory requirements. 7.3.4 Responsible Department Managers Each manager shall establish the requirements for personnel 1 qualification and institute training and indoctrination to satisfy these requirements. Training requirements shall be comensurate with the importance and complexity of the activity performed. 1 s l I 5 5 i 3 i l 2 A0001050tt 82 QQ n 1

gggy OPERATIONAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 1-00 8.0 CORTROL 0F CORRECTIVE ACTIONS AND NONCONFORfMNCES 8.1 Policy 8.1.1 Nonconforming materials, parts, components, services or activi-ties within the scope of the GPUN Quality Assurance Program shall be identified and controlled to prevent their inadvertent utilization. Measures shall be established which ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances be promptly identified and corrected. The cause of significant conditions adverse to quality shall be determined and appropriate action taken to prevent recurrence. The identification, cause, and actions taken to correct sig-nificant 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. 8.2 Requirements 8.2.1 Nonconformances include both hardware problems involving ma-terials, parts, components or systems which do not comply with established requirements and non-hardware problems such as failure to comply with the Operating License and Technical Specifications, procedures, regulations and/or other estab-lished requirements. 8.2.2 It is the responsibility of all organizations and individuals involved with the TMI-l and Oyster Creek Nuclear Stations to identify and report all nonconformances that affect important to safety structures, systems, equipment, materials, parts and components. These nonconformances may be of a minor nature as a result of work activities, inspections, monitoring or re-views; 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. 5 8.2.3 Activities such as examinations or checks performed to assess the condition of equipment or its operation are not considered to be nonconformances until it has been determined that it does 5 not comply with established acceptance criteria. These activities shall, however, be documented on an appropriate form AOOO 105011 82 100.0 1

r ""^no"^t ouAun aSSuR, Nee Numeer & Nuclear f PLAN 1000-PLN-7200.01 Title Revision No. 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 1-00 to c6ntrol 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 inadvertent use prior to correction. 8.2.4 Procedures shall be established which detail and implement the following corrective action system measures: a. Conditions adverse to quality shall be evaluated to determine the need for corrective action. b. Corrective action documentation of significant deficien-cies shall include identification, cause, and actions taken to correct and to preclude the similar recur-rence. QAD concurrence is required for corrective action disposition for all QAD identified nonconform-ances. Licensee Event Reports require an Independent Safety Review. c. Follow-up activities shall be conducted to verify imple-mentation of corrective actions and to close out cor-rective actions in a timely manner, d. Significant deficiencies, nonconformances and defects which are potentially reportable to the NRC shall be identified to appropriate management levels for evalu-action and reporting to the NRC, as appropriate. 8.2.5 Procedures shall be establi:hed which detail and implement the requirements for identification and control of nonconforming items and activities and for the identification of the cause of the conditions and the actions to be taken to correct the con-ditions to prevent recurrence. These procedures shall include requirements for the following: a. Identification of the form to be used for reporting the nonconformance, b. Description of the nonconforming item or activity and date of identification. 2 c. Identification of the initiator of the nonconformance 7; report. = 2 d. Description of the nonconformance, including 2 identification of the requirement violated. 3< A000105011 82 101.0

gggy OPERATIONAL QUALITY ASSURANCE Nwnb3 PLAN 1000-PLN-7200.01 Title Revision No. 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMNCES 1-00 e '. Identification of nonconforming items by appropriate means (tags, labels, etc.) and segregation, if prac-tical, until disposition of the nonconforming item has been determined. f. Disposition of nonconformance. The disposition shall be determined by the organization responsible for the nonconformance. Rework and scrap dispositions are made by the material user without engineering review; use-as-is and repair dispositions require concurrence and justification of cognizant engineering organizations. QA concurrence is required for all dispositions. g. Notification to the affected organizations of the non-conformance. h. Verification method, verification and close out.

i. 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 Engi-neering and Quality Assurance. All inspection, testing, re-work, and repairs shall be by approved procedures and the re-suits documented. 8.2.7 Prior to the initiation of a preoperational test on a safety related item all nonconformances shall be evaluated for sig-nificance or impact on further testing or operation and shall be dispositioned as appropriate. The evaluation / disposition shall be documented. 8.2.8 Nonconformance reports shall be periodically analyzed to show 5 quality trends. Such analysis will be based upon severity, number, frequency of.nonconformances, the causes of the non-conformances and the timeliness of the reporting and resolution 5 of nonconformances. The results of analyses shall be 2 periodically reported to management for review and assessment. 2 When significant conditions are identified or when actions are 3 required by upper management to correct problems, such as a j generic problem identified by the trend analysis or repetitive failure to disposition nonconformances, these problems shall be g elevated to upper levels of management for resolution. o A00010501i.82 102.0

Nun e OPERATIONAL QUALETY ASSURANCE ) gggy PLAN 1000-PLN-7200.01 i i Title Revision No. 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 1-00 8.3 Respodsibilities 8.3.1 Director - Nuclear Assurance The Director - Nuclear Assurance through the Director - Quality Assurance is responsible for the following: a. Review and concurrence of all procedures for reporting and controlling of nonconformances for compliance with the requirements of this Plan. 8.3.2 Director TMI Unit I and Oyster Creek The Directors TMI Unit 1 and OCNGS are each responsible for ensuring that nonconformances are reported and corrected for all Important to Safety Activities. Plant items such as failures, malfunctions, deficiencies, deviations and defective materials, parts or components are handled in a manner consistent with their importance to safety and reviewed in accordance with appropriate procedures and the applicable Technical Specification. 8.3.3 Responsible Department Manager 8.3.3.1 Each Director / Manager is responsible for the disposition and corrective action of nonconformances identified as within the scope of his responsibilities. In the specific case of mater-ials, parts, components, or systems which have not been instal-led or 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 non-conforming conditions are identified and controlled in accordance with approved procedures. 5 k = ~ as 5 2 g 2 8 A000105011 82 103.0

Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 9.0 AUDITS 1-00 w 9.0 AUDITS 9.1 Policy A comprehensive and documented audit system shall be estab-lished and implemented to ensure that: a. Policies, plans, procedures and instructions define sufficient organizational responsibilities; and, methods consistent with regulatory requirements and this Plan. b. Policies, plans, procedures and instructions are imple-mented. c. Corrective action systems and management reviews provide for timely completion of requisite action for identified d e fi c i en c i e s /n on-con fo nnan ce s /o ccurren ces /ev en ts. d. Corrective action systems and management reviews provide effective identification and prevention of recurrent and/or significant conditions adverse to quality. 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 appraisal of the effectiveness of all elements of the GPUN Quality Assur-ance Program. 9.2 Requirements 9.2.1 A comprehensive system of audits shall be established for both internal and external functions which affect structures, sys-tems, components, operations and activities covered by the scope of the GPUN Quality Assurance Program. 9.2.2 Planned and scheduled audits shall verify compliance with the following: 5 a. GPUN Quality Assurance Program. } b. Code of Federal Regulations. s 3 c. Regulatory Guides, ANSI, and other codes and standards as endorsed in this Plan or other GPUN licensing based j documents. I s A000105011 82 104.0

" *"D*' gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 9.0 AUDITS l-00 d.' Operating License and Technical Specifications, e. Policies, plans, procedures and instructions affecting important to safety items and activities, f. Contractural requirements associated with external organizations providing important to safety items and services. 9.2.3 Audits shall include an objective evaluation of quality related practices, procedures and instructions including an objective review of activities, items and records which demonstrate ef-fective and proper implementation. 9.2.4 Audits shall be performed in accordance with pre-established written procedures and checklists, and shall be conducted by trained and qualified personnel having no direct responsi-bilities in the areas being audited. The audit program shall include: a. Audit schedules, b. Procedures for preparation, performance and reporting of audits. c. Analysis of audit data and reporting results to ap-propriate levels of management, d. Follow-up action to be taken based upon individual and collective audit reports. e. Qualification of auditors. f. Delineation of the authority, responsibility, and organ-izational independence of those responsible for the audit program. 9.2.5 Audits shall be regularly scheduled based upon the status and safety importance of activities being performed and shall be initiated in a timely manner to assure the effectiveness during design, procurement, manufacturing, construction, installation, inspection, testing and as required by the Technical Specifi-5 cations of the Stations. In addition, audits shall be sched-5 uled and performed as required by management or the safety E review groups for special evaluations. Implementation of cor-rective action shall be verified in a timely manner. Un-l scheduled audits may be conducted at any time on any aspect of this Plan. 1 2 f AOOO105011 82 105.0 )

Nuclear OPERAMONAL QUALITY ASSURANCE f PLAN 1000-PLN-7200.01 i g, Revision No. 9.0 AUDITS 1-00 9.2.6 Both DPUN and organizations providing important to safety items and/or services are subject to the audit requirements of this Plan. 9.2.7 Audits will be performed by the Quality Assurance Program Development and Audit Section. / 9.2.8 Audited organizations shall provide sufficient support to assure the accuracy of the audit results, review and response to audit non-conformances, and effective resolution / prevention { of deficiencies. The corrective actions required to resolve audit findings and observations shall be addressed in a timely manner. 9.2.9 Audit frequencies shall be based upon the status and safety importance of activities, degree of previous experience, thoroughness of overall coverage, unique testing / operating activities, and follow-up of previous audit findings. In plan-ning and scheduling audits the areas which should be included are activities associated with: a. The determination of plant features and activities which affect plant safety, including taking systems out of service for maintenance and modifications and turning them back over to Operations. b. Preparation, review, approval and control of procurement activities. i c. Indoctrination and training. d. Interface control among the various Divisions of GPUN and between GPUN and contractors / vendors. e. Corrective action, calibration and nonconformance con-trol systems. f. Regulatory commitments. g. Activities associated with computer codes. 5 9.2.10 Sufficient record types shall be maintained to provide docu-I T. mentation of audit system scope, individual audit coverage 5 (i.e. checklists or equivalent), audit results, audit team leader certifications, follow-up and verification and results of trending / analysis. t 3 A00010$0I1-82 106.0 I t i

Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No 9.0 AUDITS 1-00 9.2.11 Audits shall be performed by personnel who are trained and qualified to the requirements defined in ANSI N45.2.23. Each audit team shall be led by a qualified Audit Team Leader. Audit team members shall be utilized as required and will be classified as either auditors or technical specialists, de-pending on their function on the audit team. 9.3 Responsibilities 9.3.1 Director--Nuclear Assurance The Director--Nuclear Assurance is responsible through the Director--Quality Assurance to: a. Establish and implement the audit program and assure all required areas are audited. b. Provide the auditing organization which meets the re-quirements 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. 9.3.2 Director (s) -- Audited Oraanization(s) l The Director (s) of the audited organization (s) are responsible through Directors / Managers to ensure: 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 non-con-formances are defined and implemented. 0 c. Responses to audit findings are reviewed and approved by their organizations prior to submittal to the auditing g organization. 3 ? E AGOO 10t ' 11 82 107.0 m

e Number gggy 0PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. 9.0 AUDITS 1-00 d Responses to audit findings are submitted to the auditing organization in a timely manner as defined in implementing policies, plans, procedures and/or in-structions. Corrective actions to resolve audit findings are taken e. in a timely manner. n 8 5 3< s A000105011 82 108.0 1

7 Number NucIear OPERATIONAt QUALITY ASSURANCE etAN iooo.PtN-7200.0i Title Revision No. 9.0 AUDITS 1-00 APPENDICES APPENDIX A Comparison Chart of Operational Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards APPENDIX B QAD Management Control Requirements for "Important to Safety" Documents APPENDIX C NRC Regulatory Guide Commitments and Exceptions APPENDIX D Terms and Definitions I 8 l = .5 5 N 2 1 O d_ A000105011 82 109.0

I ORM 1000 ADM 12 8 3 01 2 t i l 821 %2 A' 8 R APPENDIX A C COMPARISON CHART OF OPERATIONAL OUALITY ASSURANCE PLAN REQUIREMENTS 1W TH THOSE OF VARIOUS PARTS OF THE g eme CODE OF FEDERAL REGULATIONS AND NUCLEAR INDUSTRY STANDARDS 10 CFR 50, App. B ANSI N45.2 10 CFR 71, Subpart H ANSI N18.7 - 1976 Cri terion QA Plan Paragraph QA Plan Criterion QA Plan Paragraph QA Plan Paragraph QA Plan I 1.0 2.0 2.0 71.103 1.0 3.1 1.0 5.2.12 3.3 II 2.0 3.0 1.0 71.105 2.0 3.2 1.0 5.2.13. 5.0 9 III 4.0 4.0 4.0 71.107 4.0 3.3 1.0;2.5 5.2.14 8.0 IV 5.1 5.0 5.1 71.109 5.1 3.4 1.0; 5.2.15 3.0 V 3.1 6.0 3.1 71.111 3.1 Supplements 5.2.16 6.6 3 VI 3.2 7.0 3.2 71.113 3.2 4.0 1.0;2.4;2.8; 5.2.17 6.2 uE O VII 5.1 8.0 5.1 71.115 5.1 9.0 5.2.18 6.4 Q VIli 5.2 9.0 5.2 71.117 5.2 5.1 2.0 5.2.19 6.5 zc IX 6.4,6.11 10.0 6.4;6.11 71.119 6.4;6.11 5.2.1 1.4 5.3.1 3.1 X 6.2 11.0 6.2 7.0 Supplements 5.3.2 3.1 g XI 6.5 12.0 6.5 71.121 6.2 5.2.2 3.1 5.3.3 3.1 -c XII 6.6 13.0 6.6 7.0 5.2.3 3.1 5.3.4 3.1 XIII 6.7 14.0 6.7 71.123 6.5 5.2.4 3.1 5.3.5 6.11 M XIV 6.8;6.10 15.0 6.8;6.10 7.0 5.2.5 3.1 5.3.6 6.13 c XV 8.0 16.0 8.0 71.125 6.6 5.2.6 6.8;6.10 5.3.7 6.6 XVI 8.0 17.0 8.0 7.0 5.2.7 6.11 5.3.8 6.13 M XVII 3.3 18.0 3.3 71.127 6.7 5.2.8 6.12 5.3.9 3.1 m XVIII 9.0 19.0 9.0 7.0 5.2.9 5.3.10 6.5;6.8 71.129 6.8;6.10 5.2.10 6.9 7.0 5.2.11 8.0 71.131 8.0 71.133 8.0 -o 2 71.135 3.3 o2 8c 71.137 9.0 OE d S y !!! 8 ? n \\ o o s e 0 l i

Numb 2r Nuclear OeeRATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX B l-00 APPENDIX B QAD Management Control Requirements for Important to Safety Documents Document Type QA Department Management Control Requirements QA Plan Director Quality Assurance preparer writer evaluation of revisions; submit significant changes to the NRC. QA Corporate Procedures Approved by the Office of President or designee; Concurrence of Division Directors affected. NA Division Procedures Concurrence of Director-Quality Assurance. QA Department Approved by Director - Quality Assurance; Procedures Concurrence of QA Section Manager affected. QA Section Procedures Approved by the QA Section Manager affected; Concurrence of QA Subsection Manager / Supervisor. Unit Administrative Concurrence of Manager QA Mod /0ps. Procedures Unit Operating Procedures Concurrence of Manager QA Mod / Ops., unless otherwise designated. Unit Maintenance Concurrence of Manager QA Mod /0ps. Procedures NDE Procedures and Approved by Director - Quality Assurance or Calibration Standards applicable QA Section Manager; concurred by Level III in applicable discipline. Installation / Modification Concurrence of Manager QA Mod./0ps. Procedures Site Work Authorizing Documents Concurrence of Manager QA Mod /0ps. 2 Design Specifications Concurrence of Manager QA Design / Procurement ~ or, for site initiated specifications, g Manager QA Mod /0ps. E s k 6_ s A000105011 82 111.0

ENuclear WERAMNAL QUALITY ASSURANCE Number PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX B l-00 APPENDIX 8 QAD Management Control Requirements for Important to Safety Documents Document Type QA Department Management Control Requirements Procurement Requi-itions Concurrence of cognizant QA representative. Vendor / Contractor QA Program Concurrence of Manager QA Design / Procurement and Procedures or Manager QA Mod / Ops (for Placement on SQCL and/or for vendor / contractor program / procedures to be used on site) h = 5 b 3< h 2 AOOO105011 - 82 112.0

I gggy OPERAT10NAL ALITY ASSURANCE Title Revision No. APPENDIX C 1-00 APPENDIX C QUALITY ASSURANCE PROGRAM NRC REGULATORY GUIDE COMMITMENTS AND EXCf7TIONS 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 backfitting and/or retroactive compliance. It is also to be recognized that existing plant conditions, may prevent or preclude the satisfaction of all requirements of a specific Regulatory Guide. These conditions will be documented and, along with the justification, will be approved by the Director - Quality Assurance. + n = 5 3< 8 AOOO 105011 -82 113.0 J

toau 1000 ADM 1218 OI 2 O I B23 %2 ?5 5R APPENDIX C, PART I COMMITMENT TO QUALITY ASSURANCE REGULATORY GUIDES FOR GPUN cg amma REG. GUIDE DEGREE OF ANSI STD. 00ffLIANCE REMARKS DBF 1.8 5/77, Rev.1-R Personnel Selection and Training N18.1 1971 Modified See attached conenents. 9 1.26 2/76 Rev. 3 QA Classifications and Standards Modified See attached comments, for Water Stream and Radioactive Waste Containing Components of Nuclear Power Plants O m" 1.28 2/79, Rev. 2 Quality Assurance Program N45.2 19 77 Full Requirements (Design and Comply with Regulatory Position, Construction) d o 1.29 1/78, Rev. 3 Seismic Design Classification 5 m c-Modified Same comment as for Reg. Guide 1.26 5 c> 1.30 8/11/72 QA Requirements for the Install-N4 5.2.4 1972 Hodified See attached comments.

• 5 ation, Inspection and Testing r-of Instrumentation and Electrical Z

Equipment 1.31 4/78, Rev. 3 Control of Ferrite Content in D Full Stainless Steel Weld Metal Comply with Regulatory Position. 1.33 2/78, Rev. 2 Quality Assurance Program N18.7 19 76 Modified See attached comments. 3 Requirements (Operation) + 1.37 3/16/73 QA Requirements for Cleaning of N4 5.2.1 1973 Modified See attached comments. g Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants 1,38 5/77, Rev. 2 QA Requirements for Packaging, N4 5.2.2 19 72 Modified See attached comments. ii ? h f b Shipping, Receiving, Storage and Handling of Items for Water S ? 9! Cooled Nuclear Power Plants 2 2 5 9 h g o 8 ~ o U

FORM 1000 ADM 1218 012 til 82) ?? 5 8R o APPENDIX C, PART I DEGREE OF REG. GUIDE ANSI STD. COMPLIANCE REMARKS w umm 1.39 9/77, Rev. 2 Housekeeping Requirements for N45.2.3 1973 Modified See attached connents. Water Cooled Nuclear Power Plants "I 1.54 6/73 QA Requirements for Protective 101.4 1972 Modified See attached comments. Coatings Applied to Water Cooled Nuclear Power Plants o 1.58 9/80, Rev. 1 Qualifications of Nuclear Power N45.2.6 1978 Modified See attached comments, h Plant Inspection, Examination and Testing Personnel o P 1.64 6/76, Rev. 2 Quality Assurance Requirements N45.2.ll 1974 Modified See attached comments. h o for the Design of Nuclear y Power Plants r- ((> 1.74 2/74 Quality Assurance Terms and N45.2.10 1973 Full Comply with Regulatory Positiot C Definitions [ 1.88 10/76, Rev. 2 Collection Storage and Main-N45.2.9 1974 Modified See attached comments. h tenance of Nuclear Power Plant Quality Assurance Records ( 1.94 4/76, Rev. 1 QA Requirements for Instal-N45.2.5 1974 Modified See attached connents. S 1ation, Inspection and Testing of Structural Concrete a Steel during Nuclear Power Plant Construction 1.116 5/77, Rev. 0-R QA Requirements for Installa-N45.2.8 1975 Modified See attached comments. (( hE tion, Inspection and Testing of o i7, o 3 Mechanical Equipment and Systems Q h( h ? 8 ~ e M S 3 o a e

IOftM 1000 ADM 1218 012 413 823 5$ A5 5 R E APPENDIX C, PART I E O DEGREE OF ~ REG. GUIDE ANSI STD. COMPLIANCE REMARKS 1.123 7/77, Rev.1 QA Requirements for Control of N45.2.13 1976 Modified See attached coments. M Procurement of Items and Serv-ices for Nuclear Power Plants 1.142 10/81, Rev.1 Safety-Related Concrete Struc-H45.2.5 1974 Modified See attached coments. tures for Nuclear Power Plants ANS6.4 1977 O,a (Other than Reactor Vessels ACI318 1977 9 and Containments) D m -{ 1.143 10/79, Rev. 1 Design Guidance for Radioactive Full Comply with R'egulatory Waste Management Systems, Position yr Structures, and Components do Installed in Light-Water- "E Cooled Nuclear Power Plants F 1.144 1/79 Requirements for Auditing of N45.2.12 1977 Modified See attached comments. Quality Assurance Programs for Nuclear Power Plants g c$ 1.146 8/80 Qualification of Quality N45.7.23 1978 Full Comply with Regulatory Position M Assurance Program Auditors m for Nuclear Power Plants T' = 5z O! Yb s ya 8 8 g 5 = m

OPERATIONAt QUAtITY ASSURANCE Number Nuclear l PtAN looo.PtN.7200.oi Title Revision No. l APPENDIX C 1-00 APPENDIX C - PART 2 NRC Regulatory Guide 1.8, Rev. 1-R, May 1977 Personnel Selection and Training Guidelines have long been established in the company with respect to awarding jobs to plant maintenance, operations, and other bargaining unit personnel who may be involved in testing, examination and inspec-tion activities. Personnel are 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 even though he 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 as otherwise noted in the Technical l Specifications. NRC Regulatory Guide 1.26, Rev. 3, February 1976 Ouality Group Classification and Standard for Water, Steam and Radioactive I Waste Containing Components of Nuclear Power Plants Since the original design and construction of TMI-1 and Oyster Creek was I to different classification criteria than contained in this guide; GPUN will comply with the regulatory position of this guide with the following clarifications: 1. For modifications tc existing plant systems and for new construc-tion, items will be classified by Technical Functions according I to the original design basis or this guide. This classification l will not degrade the safety of the system being modified. 2. Tie-in's to existing plant systems will be made to the same or l more recent applicable code, standard and technical requirements which were originally applied to the system to which the tie-in is to be made. 5 NRC Regulatory Guide 1.30, August 1972 Quality Assurance Reauirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment 3 h 3 A0001050ti 82 117.0

Nwnw gggy OPERATIONAL QUALITY ASSURANCE ( PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX C 1-00 GPUN shall coInply 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 associated with maintenance and modifications shall be the original technical requirements or better (e.g., code requirements, 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 con-ducted during the construction phase. In lieu of this, GPUN utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test procedures during the operational phase. NRC Regulatory Guide 1.33, Rev. 2, February 1978 Quality Assurance Program Requirements (Operation) The GPUN QA Program complies with the regulatory position of this guide with the following clarifications: 1. Paragraph C.4.a is interpreted to mean audits will be made once each 6 months to verify the nonconformances and corrective action program is properly implemented and documented, particularly as related to actions taken to correct deficiencies that affect item <; important to safety. 2. 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 TMI-1 Technical Specifications, temporary changes shall be l 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. 3. Paragraph 5.2.8 of ANSI N18.7 - 1976 titled " Surveillance Testing l 5 and Inspection" ~. In lieu of a " master surveillance" schedule, a technical specifi-5 cation surveillance testing schedule shall be established reflecting the status of all inplant surveillance tests and

• j inspections required by technical specifications, a

I 4 Paragraph 5.2.15 of ANSI N18.7 - 1976 titled " Review, Approval 5 and Control of Procedures" 2 AOOOI050if 52 118.0 J

@ Nuclear oetaatto"Ag^tIrvASSuRANcE Number g Revision No. APPENDIX C 1-00 The third sentence of the third paragraph is interpreted to mean applicable procedures shall be reviewed following a reportable incident such as an accident, an unexpected transient, significant operator error, or equipment malfunction. 5. 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 pro-cedures or other documents with the procedures or documents serving as the record; however, records of inspections will be identified and retrievable. NRC Regulatory Guide 1.37, March 16, 1973 Quality Assurance Requirements for Cleaning Fluids Systems and Associated Components of Water Cooled Nuclear Power Plants The GPUN 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 flushes of fluid systems and associated components shall be at least equivalent to the quality required for normal operation. This requirement does not apply to disolved oxygen or nitrogen limits nor does it infer that chromates or other additives normally 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 indicatin wrapping materials (other than polyethylene)g crayons, labels, , water soluble I materials, lubricants, NDT penetrant materials and couplants, which contact stainless steel or nickle alloy material surfaces shall contain no more than trace elements of lead, zinc, copper, mercury or other low melting alloys or compounds. Maximum allowable levels of water leachable chloride ions, total halogens and sulfur compounds shall be defined and imposed on the afore-mentioned materials. ~ 3. Section 2.1 of ANSI N45.2.1-1973 states that required planning is l 5 frequently performed on a generic basis for application to many E installations on one or more projects. This results in standard procedures or plans for installation and inspection'and testing 3 which meet the requirements of the Standard. Individual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans 1 A0001050t1 82 110 n

ENuclear OPERATIONA ALITY ASSURANCE Title Revision No. I APPENDIX C 1-00 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 Paragraphs 2 and 3 of ANSI N45.2-1977 which provides for examination, measurement or testing to assure quality or indirect control by monitoring of l processing methods. However, final cleaning or flushing activi-l ties will be performed in accordance with procedures specific to the system. 4. GPUN intends to conform to the Cleanness requirements of Section 3.1 of ANSI N45.2.1-1973 with the exception of permissable particle sizes for cleanness Classes B and D. In these cases, GPUN will conform to the requirements of ANSI N45.2.1-1980, Section 3.2.2.l(b) which states, "These shall be no particles larger then 1/32 in, by 1/16 in. long (0.8 m by 1.6 m)" for cleanness Class B and Section 3.2.4.4 which states, " Particles no larger than 1/16 in. by 1/8 in. long (1.6 nm by 3.2 m) on a 14-mesh (1.4 m, ASTM E-ll, Specification for Wire Cloth Sieves for Testing Purposes) or finer filter, or the equivalent." for cleanness Class D. i 5. Section 3.1.2.1 of ANSI N45.2.1-1973 states that surfaces shall be examined without magnification under a lighting level (background plus supplementary lighting) of at least 100 foot l candles. GPUN intends to permit the use of neutral 18% gray card with a 1/32" black line for determining acceptability of illumination in lieu of the 100 foot candles. j 6. Section 4.0 of ANSI N45.2.1-1973 states that items are not to be delivered to the point of installation sooner than necessary unless the installation location is considered a better storage l area. The strategy for the storage of items is based on many i factors, one of which is to not adversely affect the item's { acceptability while in storage. If other factors make it j desirable to store an item at the installation site, and the location is acceptable from a quality standpoint, it is not our l intention to eliminate that site as a potential storage area. As I an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations. Example I 5 - reduced handling or easier access, thereby reducing suscepti-bility to handling damage. In all such cases, equipment stored T. in place will be protected in accordance with Section 5 of ANSI j N45.2.1-1973. l [l 2 7. Section 6.0 of ANSI N45.2.1-1973 states that where environmental l 3 contamination causes degradation of quality, seals are installed and the item is tagged with identification: and instructions for seal removal. GPUN utilizes procedural controls which specify a the authorization requirements for seal removal. " Tags" are not normally utilized. A0001050II 82 120.0

Number gggy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX C 1-00 NRC Regulatory Guide 1.38, Rev. 2, May 1977 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with the regulatory position of this guide with the following modifications or clarifications to ANSI N45.2.2-1972: 1. Section 2.7, Classification of Items. The four-level classifica-tion 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 trace-able through the procurement documents. Classification differing from Section 2.7 will be considered acceptable provided no degra-dation is assured; for example, electric motors designed for outside service may be stored in a level C area rather than a level B. 2.. Section 3.2, Levels of Packaging. The four level classification system for packaging of items may not be used explicitly. For commercial grade items standard commercial grade packaging requirements may be specified. 3. Section 3.6 concerns prevention of halogenated materials from contacting 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. 4. Section 3.7.1 Cleated, sheathed boxes will be used up to 1000 I lbs, rather than 500 lbs. as specif 1 ? This type of box is safe for, and has been tested for, leas 5 a to 1000 lbs. Other material standards (i.e., FED s e. t '-8-601) allow this. Special qualification testing c,at' required for loads in n excess of 1000 lbs. 5. Section 5.5, Correction of Nonconformances. This section pro-vides for " rework" and "use as is" dispositions for nonconforming items. As an alternate, the " repair" disposition (as defined in ANSI N45.2.10-1973) will also be used. 2 6. Section 6.2.1 For storage of level D items access will be con-K trolled and limited by posting. Other positive controls such as 5 fencing or posting of guards will be provided for higher storage y levels. O AOOO105011 82 121.0

r Numb:r %KUClear OPERATIONA UALITY ASSURANCE 1000-PLN-7200.01 Title Revision No. APPENDIX C 1-00 7. 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 lif ting equipment, and supplement periodic inspections with special visual and non-destructive examinations and dynamic load tests. In lieu of this, GPUN does perform dynamic load tests on new equipment, preventive maintenance on cranes, nondestructive examination of lifting hooks annually, and a visual inspection of lifting equip-ment prior to use. 8. Appendix A.3.4.1 The last sentence of A.3.4.l(4) and (5) should be corrected as follows: (4) "However, 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 shall be indicated to facilitate touch up." 9. 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. 10. Appendix A.3.5.2 Tapes will meet a sulphur limit of 0.30% by weight instead of 0.10% as specified in A.3.5.2(1)(a). This limit is reasonable based upon the chemical content of commercially available tapes. Tapes will be of a contrasting color rather than " Brightly Colored" as required by A.3.5.l(3). 11. Appendix A.3.7.1 In lieu of A.3.7.l(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. NRC Regulatory Guide 1.39, Rev. 2, September 1977 2 Housekeeping Requirements for Water Cooled Nuclear Power Plants Endorses 3 ANSI N45.2.3 - 1973 Gi The GPUN Quality Assurance Program complies with this guide with the il following clarification to ANSI N45.2.3-1973. A000105011 82 j 122.0

r Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revisior' No. APPENDIX C 1-00 1. Sectio'ns 2.1 and 3.2 The Nuclear Stations will not utilize the five level zone designation system referenced in ANSI N45.2.3, but will utilize standard janitorial and work practices to main-tain 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 considered important to safety. 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. I Additional housekeeping requirements will be implemented as required for control of radioactive contamination. l 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, GPUN has established positions or commitments relating to fire safety or protection. NRC Regulatory Guide 1.54, June 1973 Quality Assurance Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification: 1. GPUN will comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative require-ments included therein shall apply to maintenance and modifica-tion activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection require-5 ments) shall be the original requirements or better. E \\ 2. The quality assurance program for protective coatings includes ~ 5 the planned and systematic actions necessary to provide adequate [ confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service. ~ AOOO 105011 82 123.0 ]

Number NucIear OPERATIONAL QUAL 1TY ASSURANCE gLAs iooo.gtn.7200.03 Title Revision No. APPENDIX C l-00 All protective coatings, 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 exceed those described in the FSAR. 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 procedures for generic coating materials / systems. (b) Review and evaluation of coating manufacturers' demonstra-tion test data and quality assurance measures for control of manufacture, identification, and performance verification of applied coating systems. (c) Review and evaluation of supplier quality assurance measures to control storage and handling, surface preparation, application, touch-up, repair, curing and inspection of the coating systems. (d) Training and qualification of inspection personnel in coatings inspection requirements. (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 for: (a) Surfaces to be insulated. 5 (b) Surfaces " contained" within a cabinet or enclosure (for example, the interior surfaces of ducts). 5 2 S AOOO105011 -82 124.0 J

Nuclear OPERATIONAL QUALITY ASSURANCE l PLAN 1000-PLN-7200.01 Title Revision No. I APPENDIX C 1-00 (c) Field repair on any Q-class coated item less than 30 square inches of surface area such as: Cut ends or otherwise damaged galvanizing. Bolt heads, nuts, and miscellaneous fasteners. Damage resulting from spot, tack, or stud welding. Field touch-up and repair of larger areas shall be in accordance with item (1). (d) Small " production line" items such as small motors, hand-wheels, electrical cabinets, control panels, lounspeakers, etc. where special painting requirements would be inpracti-cable. (e) Stainless steel or galvanized surfaces. (f) Coating used for the banding of piping. (g) Strippable coatings used for cleanup. 4. Quality Assurance documentation 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 Regulatory Guide 1.58, Rev.1, Septembhr 1980 Qualifications of Nuclear Power Plant Inspection, Examination, and Testing Personnel The GPUN Quality Assurance Program complies with this guide with the following 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 5 with GPUN established requirements. The qualifications of plant operation personnel concerned with day-to-day operation, s maintenance, and certain technical services shall conform to 3 Regulatory Guide 1.8. NDE Level III personnel shall be j recertified at an interval of every 5 years as noted by ASME Code Cases N-341 and N-356, rather than the 3 year interval l recommended by ASNT-SNT-TC-1A 1980. A0001050tt 82 ] 125.0

Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX C 1-00 2. Not afl personnel who: A. Review and approve inspection and testing procedures, 8. Evaluate the adequacy of activities to accomplish the inspection and test objectives, C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, D. Certify Level III individuals in specific categories or

classes, Will be certified as meeting the Level III capability require-ments of ANSI N45.2.6 - 1978.

Rather these personnel will be determined by management through evaluation of their education experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented. NRC Regulatory Guide 1.64, Rev. 2, June 1976 Quality Assurance Requirements for the Design 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 clarification to paragraph C.2(1): If the designer's immediate Supervisor is the only technically qualified individual available, this review can be conducted by the Supervisor, providing that: (a) the other provisions of the Regulatory Guide are satisfied, and (b) the justification is individually documented and approved in 5 advance by the Supervisor's management, and (c) quality assurance audits cover frequency and effectiveness of use of Supervisors as design j verifiers to guard against abuse. i_ 2 k A0001050t1 82 126.0 J

N d er Nuc1 ear OPERATIONAL QUALITY ASSURANCE glAN looo.ptn.7200.0i Title Revision No. APPENDIX C 1-00 NRC Regulatory Gufde 1.88, Rev. 2, October, 1976 Collection, Storage, and Maintenance of Nuclear Power Plant Availability Assurance Records GPUN will comply with the intent of this regulatory guide by compliance with the requirements of ANSI /ASME NQA-1-1979, Supplement 175-1 and Appendix 17A-1 including Appendix 17-1, NQA-la-1981. NRC Regulatory Guide 1.94, Rev. 1, April 1976 Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification: 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). NRC Regulatory Guide 1.116, Rev. 0-R, May 1977 Ouality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems The GPUN Quality Assurance Program complies with this guide with the following clarification: 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). i3 Much of N45.2.8 applies to construction and pre-operational testing. As T. a result, many of the listed tests are not appropriate in an operational 5 plant. In lieu of this, GPUN utilizes its Engineering and/or Maint-enance organizations to establish the need for specific tests or test { procedures during the operational phase. R 2 8 A000105011 82 127.0 J

I gggy OPERATIONAL QUALITY ASSURANCE Nurnber PLAN 1000-PLN-7200.01 Tide Revision No. APPENDIX C 1-00 NRC Regulatory G'uide 1.123, Rev. 1, July 1977 Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification: 1. Section C.3 A corrective action system may, depending upon 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 is 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. 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 10.2.d of ANSI N45.2.13-1976. 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. 6. 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 5 certificates and the effectiveness of the certification system are accomplished as an. integral part of the total supplier T. control and product acceptance program, and no separate GPUN 5 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 importance. The means of 3 verification may include source witness / hold points, source audits, and document reviews; independent inspections at the time AOOO10'a0 t t 82 128.0 J

ENuclear OPERATIONA ALITY ASSURANCE Title Revision No. APPENDIX C 1-00 of ma'terial 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 Regulatory Guide 1.142, October 1981 Safety-Related Concrete Structures for Nuclear Power Plants (Other Than Reactor Vessels and Containments) 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 ANSI /ACI 318-77 for the design and construction of new ITS structures and additions to existing ITS 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 Regulatory Guide 1.144, January 1979 Auditing of Quality Assurance Programs for Nuclear Power Plants GPUN is in basic agreement with the position set forth in the Regulatory Guide subject to the following comments: 1. Section C.3.a(2) The proposed scheduling requirement for internal audits appears to change the basis for having a rational, programmatic approach to auditing. In its place, the new Regulatory Guide requires mandatory auditing of all program elements on a yearly basis. The latter would require that all elements obtain the same attention regardless of importance, past performance, or to what extent other aspects of quality assurance measuring and evaluating techniques are used; as an example, the extent to which surveillance and process monitoring is used. Accordingly, minimum schedule frequency will be as defined in Regulatory Guide 1.33. 2. Section C.3.b(1) Source inspection provides a controlled basis for replacing the need for external audits. The use of quality 5 assurance program surveillance will also be used as another 3 alternative. 3. Section C.3.b(2) 2 2 While the licensee is responsible for procurement control, this j can be exercised through an annual evaluation of the contractor's t e A0001050tt 82 129.0

~. Number NucIear OPERATIONAL QUALITY ASSURANCE plan ,ooo.ptn.,200.03 Title Revision No. APPENDIX C 1-00 perf6rmance using pertinent results from manufacturing surveillance, source inspection, receiving inspection, and other applicable factors. The evaluation would include a recommenda-tion as to the need for a scheduled program or problem area audit. Hence, auditing, like surveillance and inspection, will be treated as a quality assurance tnol used for evaluation. Furthermore, the recommendation to audit will include provisions for reviewing the importance and impact of the particular contractor's scope and status.

~

5 3 0 3< e A0001050 t t-82 130.0

gdgy OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX 0 1-00 APPENDIX D Terms and Definitions This Appendix contains certain terms and their definitions that are important to a uniform understanding of the requirements of the GPUN Opera-tional Quality Assurance Program. ANSI N45.2.10-1973, as endorsed by 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 NQA-la-1981 are identified by footnote (1). Certain 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). ACCEPTANCE (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) ALARA: (Acronym for As low As Reasonably Achievable) - a method of analysis of the performance of activities in radiological areas to determine specific methods for reducing man-rem exposure. ARCHITECT / ENGINEERING (A/E): A firm under contract to provide engineering or design services. APPROVAL: An act of endorsing and adding positive authorization (signature) to a document by the person (s) responsible for the document. (2) AS-BUILT DATA: Documented data that describes the condition actually achieved in a product. (1) 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 2 standard. 5 COMMERCIAL GRADE ITEM: An item that meets all of the following conditions: 5 5 - Is used in applications other than nuclear power plant facilities or activities; e g - Is not subject to design or specification requirements unique to NRC requirements for nuclear power plants; A000105011 82 131.0

Nuh Nuder PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX D l-00 - May be ordered from the manufacturer / supplier on the basis of specifi-cations set forth in the manufacturer's published product description (e.g., a catalog). Note: The specification set forth in the published product description must match the requirements needed to satisfy the design function of the item. CONCURRENCE: Written agreement that the provisions in a document for which review has been requested are acceptable for implementation within, or from the standpoint of, the signer's area of responsibility. CONDITION ADVERSE TO QUALITY: 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. CONFIDENTIAL-SECURITY: Information, the disclosure of which could provide the intelligence required -to defeat plant security systems. CONTRACTOR: Any organization under contract for furnishing items or services. It includo the term Vendor, Supplier, Subcontractor, Fabricator and subcontractor lev 1s, where appropriate. (1) CONTROLLED DOCUMENT: A document which is assigned and distributed to an individual or organization and requires that individual or organization to be accountable for the document and to acknowledge receipt of the document in writing. The distributing agent is responsible for providing the recipients with current revisions to the document and for maintenance of the return acknowledgment receipts. CORRECTIVE ACTION: Measures taken to rectify conditions adverse to quality and, where necessary, to preclude repetition. (1) DESIGN CHANGE NOTICE (DCN): A formal document for authorizing (by appropriate engineering authority) changes to be incorporated into drawings, specifications, system design descriptions, or project design criteria documen ts. Demonstrates and applies change controls responsive to regula-tory, policy, and operating requirements. 2 S 8_ AGOGIO5011 82 132.0

Nuclear PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX D 1-00 DOCUMENT: Any Written or pictorial information describing, defining, specifying, reporting, or certifying activities, requirements, procedures or results. A document is not considered to be a QA Record until it is com-pleted and contains the required signatures. (2) ENGINEERING (Engineer): This term refers to the technical responsibilities of Technical Functions, Plant Engineering or A/E's. EXTERNAL ORGANIZATIONS: Any organization participating in the project which is not a part of GPUN. This term includes vendors, A/E's and contractors. FIELD CHANGE REQUEST: A document which is generated in the field requesting engineering approval of a drawing, specifications or procedure change. GENERAL 0FFICE REVIEW BOARD (G0RB): An advisory board which reports to and gets general direction from the Office of the President and is responsible to provide independent review of major safety issues, foresee potentially significant nuclear and radiation safety problems and advise the Office of the President on these matters. l' IMPORTANT TO SAFETY (ITS): A special classification or category of those structures, systems, components and activities that provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public. It encompasses the broad class of plant features covered (not necessarily explicitly) in the General Design Criteria, (10CFR50 Appendix A) that contributes in important ways to the safe opera-tion and protection of the public in all phases and aspects of facility operation (i.e., normal operation and transient control as well as accident mitigation). It includes " Safety-Related" as a subset. INDEPENDENT ONSITE SAFETY REVIEW GROUP (IOSRG): A full time group of engineers, independent of the unit staff and reporting to the NSAD Director who are responsible for performing independent evaluations and assessments of procedures and activities which have a direct effect on the safe opera-tion of their assigned plant. LICENSEE EVENT REPORT (LER): A report made to the NRC of events and occurrences defined in the technical specification which can be generally classified as failures of safety-related equipment or events that affect nuclear safety. 2 MONITORING / SURVEILLANCE: An act of assuring compliance of activities to 5 program requirements by direct observation or record review. Generally, g monitoring is performed on site and surveillance is performed at a vendors's facility. 3 PROCUREMENT DOCUMENT: Purchase requisitions, purchase orders, drawings, 4 cortracts, specifications or instructions used to define requirements for l purchase. (1) A000f050tt 82 133.0 J

e- '\\ OPERATIONAL QUALITY ASSURANCE Number NucIear gLAN ioo0. gen 7200.0i Title Revision No. APPENDIX D l-00 QA PLAN (Plan): ' The basic document which describes the method and extent of compliance of the QA Program to the applicable regulatory and GPUN require-men ts. QA PROGRAM (Program): The planned and systematic actions which constitute compliance with regulatory quality assurance requirements and the controlled documents which describe and prescribe those actions. QA RECORD: A completed document that furnishes evidence of the quality of items and/or activities affecting quality. (1) QUALIFICATION (Personnel): The characteristics or abilities gained through education, training or experience, as measured against established require-ments, such as standards, or tests, that qualify an individual to perform a required function.(1) QUALIFICATION (Procedures): An approved procedure that has been demon-strated to meet the specified requirements for its intended purpose. (1) QUALITY CLASSIFICATION LIST (QCL): The controlled document used to record the identification of systems and major components subject to the requirements of the Operational Quality Assurance Plan. SAFETY RELATED: As used in 10 CFR 100, Appendix A, this term refers to those structures, systems or components designed to remain functional for the Safe Shutdown Earthquake (SSE) necessary to assure required safety func-tions, i.e.: (1) the integrity of the reactor coolant pressure boundary (2) the capability to shut down the reactor and maintain it in a safe shutdown condition; or (3) the capability to prevent or mitigate the consequences of accidents which could result in potential off-site exposures comparable to the guideline exposures of 10CFR. Safety related is a sub-set of Important to Safety. SAFETY GRADE: Applies to those structures, systems and components which are required for the critical accident prevention, safe shutdown, and accident consequence mitigation safety functions defined in Appendix A to 10 CFR Part 5 100. 7. SAFETY REVIEW ?.ROUPS: Committees or organizations with responsibilities for evaluation of methods, procedures or conditions affecting plant safety during the operational phase. 3 SPECIAL PROCESS: 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 } A000tOSO1t 82 134.0 J

OPERATIONAL QUALITY ASSURANCE Number Nuc1 ear PLAN 1000-PLN-7200.01 Title Revision No. APPENDIX D l-00 which the spectfied quality cannot be readily determined by inspection or test of the product. (1) SUPPLIER QUALITY CLASSIFICATION LIST (SQCL): A list of Suppliers who have been evaluated by the GPUN Quality Assurance Department for their capabilities to produce or provide items, equipment or services important to safety for nuclear power plants. 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 analyzing non-conformance/ deviation events with the goal of systematically determining programmatic / procedural weaknesses. VENDOR: A firm which manufactures items at an off-site facility and operates under the requirements of their own quality assurance program. VERIFICATION: An act of confirming, substantiating and assuring that an activity or condition has been implemented in conformance with the specified requirements. (1) 5 A 34 3 AGOOto$0 t t g) 135.0

ENuclear PERATIONA ALITY ASSURANCE Title Revision No. SUPPLEMENT I 1-00 SUPPLEMENT I TO THE OPERATIONAL QUALITY ASSURANCE PLAN FOR GPU NUCLEAR CORPORATION AS APPLIED TO THREE MILE ISLAND NUCLEAR STATION - UNIT I ?. E 2 1_ AOOO10$01I 82 136.0

r Number Nuder PERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No SUPPLEMENT I l-00 INTRODUCTION This Supplement describes the organization and the Quality Assurance Program requirements applicable to the operation and maintenance of TMI Unit 1. These activities include design, procurement, fabrication, installation, inspection, operation, preventive and corrective maintenance, repair, replacement, modification and refueling. This Supplement contains only those requirements which are unique to TMI Unit 1. This Supplement must be used in conjunction with the GPUN Operational Quality Assurance Plan. 5 5 3 1 A00010$0tt 82 137.0 w -- 1

f Number OPERATIONAL QUALITY ASSURANCE NucIear plan iooo.ptn, zoo,0, Title Revision No. SUPPLEMENT I l-00 1.0 ORGANIZATION Director - TMI Unit 1 The responsibilities of the Director - TMI Unit I are described in Section 1.4 of the main body of the Operational Quality Assurance Plan. The Director - TMI Unit I utilizes the following management staff members in carrying out his responsibilities: Plant Engineering Director - TMI Unit 1 Operations and Maintenance Director - TMI Unit 1 Manager - Plant Administration Manager - Plans and Programs l The organization chart, Figure I-1, illustrates the management staff responsible to the Director - TMI Unit 1. In addition, for continuity l purposes, it illustrates the management staff of other divisions which are assigned on site. The responsibilities for these positions are described in the main body of the Operational Quality Assurance Plan. 1.1 Plant Engineering Director - TMI Unit 1 The Plant Engineering Director - TMI Unit 1 reports directly to the Director - TMI Unit I and is responsible to provide engineering and l technical services in support of day-to-day plant operations and maintenance, implement fire protection program and conduct chemistry activities to support the station in a safe, reliable and efficient manner in accordance with corporate policies and all applicable laws, regulations, licenses and technical requirements. The Plant Engineering Director is responsible for the following major functions: a. Provide day-to-day engineering and technical support to plant operations and maintenance. b. Prepare or assist in preparation and review of plant operation, emergency, maintenance, alarm ano surveillance procedures. c. Conduct operations experience assessment and problem investiga-tions. g d. Prepare spare parts specification and assist in procurement. f. e. Develop, implement and ensure compliance with the fire protec-tion program. 2 2 f. Develop, implement and ensure compliance with the plant 3 chemistry program. i: A00010$0I1 82 138.0

Number ( ) Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. SUPPLEMENT I l-00 g. Proville day-to-day in-core fuel management. h. Coordinate with and request technical support, as needed, from Technical Functions Division. i. Initiate investigations, responses and corrective actions as required by regulatory correspondence. J. Core Engineering 1.2 Operations and Maintenance Director - TMI Unit 1 The Operations and Maintenance Director - TMI Unit 1 reports directly to the Director - TMI Unit 1 and is responsible to conduct plant l operations, radwaste, ar.d maintenance activities at Three Mile Island 1 in a safe, reliable and efficient manner consistent with corporate requirements and in ccmpliance with all applicable laws, licenses, regulatory and technical requirements. Included is the efficient implementation of the corrective and preventative maintenance pro-grams. The Operations and Maintenance Director is responsible for the following major functions:: a. Conduct plant operations and maintenance activities to provide maximum capability in a manner consistent with license, regula-tory and corporate requirements. b. Direct the implementation of preventive and corrective main-tenance program, including the priorization to assure the plant is maintained in a safe, efficient and reliable manner, c. Direct the operation of the Radioactive Waste facility, including the conduct of the Radioactive Material Handling and Shipment programs. d. Coordinate with plant maintenance, technical support, adminis-trative, radiological control to assure proper support and control of activities with respect to plant operations. 1.3 Manacer - Plant Administration TMI Unit. 1 5 The Manager - Plant Administration reports directly to the Director TMI Unit 1 and is responsible to provide administrative support to the Director through the following functions: 5 E l 4 1 5 2 i A 00010$011 82 l 139.0

Nuclear OPERATIONAL QUALITY ASSURANCE Number gtAN icoa.pt,.7200.0i Title Revision No. SUPPLEMENT I l-00 a. Cobrdinate administrative activities between the TMI-l Division and the Administration Division in the areas of Fiscal /Information Management; Materials / Management; Human Resources; and Security, b. Day-to-day coordination with human resources, budgets, safety, security and facilities activities. c. Assist Director, TMI-l in staff planning, correspondence, and l scheduling. 1.4 Manager - Plans and Programs The Manager - Plans and Programs reports directly to the Director TMI Unit 1 and is responsible for coordinating all activities between the plant oivision (TMI-1) and the Maintenance, Construction and Facilities Division of major outage and construction projects and monitoring the effectiveness of all plant programs. The Manager - Plans and Programs is responsible for the following major functions: a. Provide coordination between the plant and all supporting Divisions for major outages. b. Provide coordination between the plant and supporting Division for construction projects. c. Plan, schedule and monitor the status of all TMI-l Division commitments and propose actions to correct detected deficiencies. d. Monitor the status of all support Division commitments and propose actions to correct detected deficiencies. e. Direct the activities of the Plans and Programs staff. f. Coordinate establishment of work scopes and development of integrated plans and schedules for all outages. 5 ~ c. 5 3 2 3< A0001050tI 82 140.0

ha OPERATIONAL QUALITY ASSURANCE Numbsr RUOgMI u PLAN 1000-PLN-7200.01 Title Revision No. SUPPLEMENT I l-00 b 4 yrca er rg pegg.., FlouRE 0-1 nesaa' GPU NUCLEAR CORPORAT10N IW '"i '4 8'em TMI-1 O_RG_A_.NIZATION I I i i f-W'vaamt &"C'*J o 'a temst f ga.ce). f I l ~ b =DfbL di'l'_ Tr."" ~dk NE Ic$ ~ I*E"' .%'r"'"'. .$s".",C !$$*h wY. "[xE1 4

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OPERATIONA ALITY ASSURANCE Num e gggy Title Revision No. SUPPLEMENT II l-00 SUPPLEMENT II TO THE OPERATIONAL QUALITY ASSURANCE PLAN FOR GPU NUCLEAR CORPORATION AS APPLIED TO OYSTER CREEK NUCLEAR GENERATING STATION 5 [< 5 ? O 34 A000105011 82 142.0 2

Number Nuclear OPERATIONAL QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. SUPPLEMENT II 1-00 INTRODUCTION This Supplement describes the organization and the Quality Assurance Program requirements applicable to the operation of the Oyster Creek Nuclear Generating Station. These activities include design, procurement, fabrication, installation, inspection, operation, preventive and corrective maintenance, repair, replacement, modification and refueling. This Supplement contains only those requirements which are unique to Oyster Creek. This Supplement must be used in conjunction with the GPUN Operational Quality Assurance Plan. 5 2 S d A0001059tttl2 143.0

\\ OPERATIONA UALITY ASSURANCE gggy Revision No. Title SUPPLEMENT II l-00 1.0 ORGANIZATION Director - Oyster Creek The responsibilities of the Director - Oyster Creek are described in Section 1.4 of the main body of the Operational Quality Assurance Plan. The Director - Oyster Creek utilizes the following management staff members in carrying out his responsibilities: Deputy Director Manager - Plant Administration Plant Engineering Director Plant Operations Director Manager - Plant Materiel Manager - Plans and Programs The organization chart, Figure II-1, illustrates the management staff responsible to the Director - Oyster Creek. In addition, for continuity purposes, it illustrates the management staff of other divisions which are assigned on site. The responsibilities for these positions are described in the main body of the Operational Quality Assurance Plan. 1.1 Deputy Director The Deputy Director reports directly to the Director - Oyster Creek and shares in the duties and responsibilities of the office of the Direc*.o Oyster Creek. 5 .~. ~ = i AOOOlOSO 11 8 2 144.0 J

[ \\ Number OPERATIONAL QUALITY ASSURANCE g MNuclear PLAN 1000-PLN-7200.01 l Title Revision No. SUPPLEMENT II 1-00 1.2 Plant Eng'ineering Director The Plant Engineering Director reports directly to the Director - l Oyster Creek. He is responsible to provide engineering and tech-nical services in support of day-to-day operations, maintenance, fire protection, and chemistry to support the station in a safe, reliable and efficient manner in accordance with corporate policies and all applicable laws, regulations, licenses and technical requirements. The Plant Engineering Director is responsible for the following major functions: a. Provide day-to-day engineering and technical support to plant operations and maintenance. b. Prepare or assist in preparation and review of plant opera-tions, emergency, maintenance, alarm and surveillance pro-cedures. c. Conduct operations experience assessment and problem investiga-tions. d. Prepare spare parts specifications and assist in procurement. e. Maintain and insure compliance with the fire protectior program. g. Maintain and insure compliance with the plant chemist y program, f I h. Provide day-to-day incore fuel management. i 1. Coordinate with and request technical support as needed from Technical Functions Division. j i j. Initiate investigations, responses and corrective actions as I' required by regulatory correspondence. k. Core engineering, f 1. Conduct the fire protection surveillance system program. 1.3 Plant Operations Director 5 The Plant Operations Director eports directly to the Director - l ~. Oyster Creek. He is responsible to conduct plant operations, radwaste and chemistry activities at Oyster Creek in a safe, reliable and 2 efficient manner consistent with corporate requirements and in com-i 2 pliance with all applicable laws, licenses, regulatory and technical j requirements. The Plant Operations Director is responsible for the i following major functions: Q l A000t0 M 11 02 145.0 J

1 X l Nwbr OPERATIONA ALITY ASSURANCE htte Revision No., i SIIPPLEMENT II l-00 Cbnduct plant operations activities to provide maximum a. capability in a manner consistent with license, regulatory and corporate requirements. b. Direct the operation of the Radioactive Waste and A0G facili-ties, including the conduct of the Radioactive Material Handling and Shipment programs, c. Coordinate with plant materiel, plant engineering, plant l administration, plans & programs and all support Divisions to j assure proper support and control of activities with respect to plant operations. d. Conduct the plant chemistry program. 1.4 Manager - Plant Materiel The Manager - Plant Materiel reports directly to the Director - Oyster Creek. He is responsible for upgrading and maintaining the plant material condition to a level consistent with safe, reliable operation i in accordance with corporate policies and all applicable laws, j regulations, licenses and technical requirements. The Manager - Plant Materiel is responsible for the following major functions: f a. Administer'a dedicated organization which shall identify material deficiencies, establish priorities and assign J responsibilities for their timely resolution. b. Develop and administer the Preventive Maintenance and Surveillance programs to support the operation of the plant consistent with license, regulatory and corporate l requirements. I c. Provide a surveillance program consistent with applicable j regulations and sound engineering practice. d. Administer a Station Services support program to compliment and enhance the performance of operational objectives. e. Administer and conduct the Fire Protection Preventive 5 Maintenance and Surveillance Program. f. Administer a Respirator Maintenance / Decontamination Facility in support of Plant Operations. b 1 A000I050tt 82 146,0

Nuclear oetaatto"^L QUALITY ASSURANCE PLAN 1000-PLN-7200.01 Title Revision No. SUPPLEMENT II l-00 1.6 Manager - Plans and Programs The Manager - Plans and Programs reports directly to the Director Oyster treek and is responsible to coordinate all activities between Plant Operations (0CNGS) and the Maintenance, Construction and Facilities Division for major outage and construction projects and to monitor the effectiveness of all plant programs. The Manager - Plans and Programs is responsible for the following major functions: a. Provide coordination between the Plant and all supporting divisions for all outages. b. Provide coordination between the Plant and all supporting divisions for construction projects. c. Monitor the status of all plant commitments and propose actions to correct detected deficiencies, d. Direct the activities of the Plans and Programs staff. 5 ?. i 3 A000 l 0'3011 8 2 147.0 \\ /

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~ Numkr GPU NUCLEAR CORPORATE Nuclear e0ticy ANO eROCcoURe MANuAt iOOO-e0t-7200.0i II*'* Revisi n No. Statement of Policy and Authority Regarding the GPUNC Operational Quality. Assurance Plan 0-00 Applicabdity/ Scope Responsible Office GPUNC-Wide except TMI-2 6160-QA PD&A This document is important to safety a Yesa No Effective Date List of Effeedve Pages 1 Page Revision 1.0 0-00 2.0 0-00 3.0 0-00 Signature Concumng Organizational Element Date onginator bj M Mdol QA Prog. Dev. & Audit Mgr. S/d86 concurred by M-Sr. Analyst Adm. Proj./Org. Policy 7/2,/r.5" l l l l i I I I l l l a l l l i I I N 8A s 0 Tm by YM _,b, Office of the President f/ts/f[ A g ~ f g A0o0105111-82 1.0

gjgp GPU NUCLEAR CORPORATE ] POLICY AND PROCEDURE MANUAL 1000-POL-7200.01 htement of Policy and Authority Regarding the GPUNC ReWson No. Operational Quality Assurance Plan 0-00 1.0 PURPOSE To establish the GPU Nuclear Corporation Policy regarding the use of the GPUNC Operational Quality Assurance Plan. 2.0 APPLICABILITY / SCOPE 2.1 This policy has GPUNC-Wide applicability except for TMI-2. 2.2 The scope of this policy encompasses all Important to Safety (ITS) activities and activities not Important to Safety (NITS) as described in Reference 6.1 and 6.2. 3.0 DEFINITIONS None. 4.0 POLICY 4.1 It is the policy of GPU Nuclear (GPUN) to maintain and operate its nuclear generating stations (TMI Unit 1, and Oyster Creek) in a manner that will ensure the safety and health of the public and personnel on site. Is is also the policy of GPUN to comply with the requirements of the Code of Federal Regulations, the NRC Operating Licenses and the applicable codes, guides and standards with respect to operation, inservice inspection, maintenance, procurement, repair and modification of the stations. 4.2 The Office of the President has the overall authority and responsibility to implement the Quality Assurance Program. 4.3 The Vice President - Nuclear Assurance reports directly to the Office of the President and provides, by way of the Quality Assurance Department, the staff necessary to develop and maintain the Quality Assurance Program consistent with the applicable federal and state requirements and to verify the implementation of the Program. The Vice President - Nuclear Assurance has direct access to the GPU Nuclear Board of Directors for reporting on issues with substantial safety implications. i i i 1 i " aoaotoso 3.s 2.0 /

Nuclear GPU NUCLEAR CORPi) RATE POLICY AND PROCEDURE MANUAL 1000-POL-7200.01 Datement of Policy and Authority Regarding the GPUNC ReWmon 2. Operational' Quality Assurance Plan 0-00 4.4 The Director - Quality Assurance, who reports directly to the Vice President - Nuclear Assurance, has the overall authority and organizational freedom to identify quality assurance or management control problems and provide recommended solutions. This authority and responsibility includes stop work authority in activities r l associated with operation, maintenance, repair, modification, l refueling and manufacturing at or for the nuclear generating stations. With regard to the stoppage of work, including the recommendation that an operating nuclear unit be shut down, the Director - Quality Assurance has direct access to the Vice Presidents of the nuclear generating stations and the Office of the i President. The Director - Quality Assurance shall use this path when differences of opinion regarding quality arise within GPUN. l 4.5 The effectiveness of any Quality Assurance Program is dependent upon the individuals who implement the program. Accordingly, all personnel of GPUN and their contractors must comply with the requirements of this Quality Assurance Program. All members of the l management must give full support to maintaining an effective quality program as defined in this Plan. 4.6 The Quality Assurance Program, as described in the Plan, is approved for implementation at TMI Unit 1 and Oyster Creek. 5.0 RESPONSIBILITIES As stated above.

6.0 REFERENCES

6.1 1000-PLN-7200.01, GPUNC Operational Quality Assurance Plan for TMI-1 and Oyster Creek. 6.2 R. C. Arnold Memorandum dated October 18,1983, "QA Department Responsibilities." 7.0 ATTACHMENTS None. I I l " A0001050 3 82 3.0}}