ML20138E532

Rev 10 to 1000-PLN-7200.01, Gpu Nuclear Operational QA Plan

ML20138E532
Person / Time
Site:	Oyster Creek, Three Mile Island
Issue date:	04/24/1997
From:	GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20138E529	List: ML20138E525 ML20138E532
References
1000-PLN-7200.0, NUDOCS 9705050004
Download: ML20138E532 (10)

Text

__. _ _

GPU 50 CLEAR CORPORATE Number GPU NUCLEAR POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

10 Applicability / Scope This Plan Has GPU Nuclear-Wide Applicability Except TMI-2 Responsible Office 6L50 This Document is within QA Scope N YES NO Effective Date Safety Reviews Required X YES NO List of Effective Pages Page Rev, Page Rev. Page Rev. Page Rev. Page Rev.

No. No. No. No No No. No. No. No

_No 1.0 10 21.0 10 41.0 9 61.0 9 81.0 9 l 2.0 4 22.0 9 42 0 4 62.0 4 82.0 9 3.0 9 23.0 10 43.0 4 63.0 9 83.0 9 40 9 24.0 10 44.0 9 64.0 9 84.0 9 5.0 9 25.0 9 45 0 4 65.0 9 85 0 9 6.0 9 9 {

26.0 46 0 9 66.0 9 7 () 10 27.0 4 47.0 9 67.0 9 ta 9 '

3 28.0 9 8.0 9 68.0 10 9.0 29.0 9 49.0 9 69.0 9

10 0 V 30.0 9 50.0 9 70.0 9 11.0 9 31.0 9 51 0 9 71.0 9 12.0 4 32.0 9 52 0 9 72.0 9 13.0 10 33.0 9 53.0 9 73.0 9 14.0 10 34.0 9 54.0 9 74.0 9 15.0 10 35.0 4 55.0 9 75.0 9 16.0 10 36.0 9 56.0 9 76.0 9 17.0 4 37.0 9 57,0 4 77.0 9 18.0 4 38.0 9 58 0 9 78.0 4 19.0 v 39 0 9 59.0 4 79.0 9 20.0 9 40.0 9 60 0 9 80.0 4 Signature Concurring Organizational Element Date Originator k f h (4,f/ Director. Nuclear Safety Assessment -/dy/y'7 Concurred By N/A Dir-TMI N/A N/A Dir-OCNGS N/A N/A Dir-Engineering N/A N/A l Dir-Financial & Plannmg Services lN/A v v-

[ l Dir-Nuclear Safety & Tech. Services l'//2y[f/ 7 N/A l Dir-Human & Administrative Services JP[ O b l Corporate Procedure Administrator hl/u/D

/s/ l Responsible Technical Reviewer 4/13/97 i

j Approsed By h$b-46 President )' h_ k.k SY7 J J 9705050004 970425  ;

PDR ADOCK 05000219 i P

PDR au mwoio IU

1 GPU NUCLEAR CORPORATE Number  !

GPtfNUCLEAR

_ POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 )

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

10 DOCUMENT l{ISTORY PREPARED BY:

EFFECTIVE REVIEWED BY:

REVISION DATE DESCRIPTIGW OF CIIANGE APPROVED BY:

its administrative functions were transferred to GPU Service l Corporation. However. its QA Plan related duties of records 1 management have been transferred to Human r-4 Admini-strative Services Division. Plant Engineering Departments were deleted as organizational units. Most of their functions were assigned to the newly named Engineering Division.

Titeir receipt inspection function was assigned to the Financial and Planning Services Division.  !

l

• Format of the document was changed. In the previous l revision. the responsibihties were included in specific  !

sections. In this revision. the responsibilities have been relocated to Section 1. consolidated to avoid redundant ,

verbiage and streamlined to represent the current I organization. Responsibilities were deleted from the remainder of the document.

• Section 9 - Con;d of Training has been deleted and is i addressed in Section 6.13 to improve the description of work l processes at GPU Nuclear.

• Sewc. ' has been renumbered to be Section 9 and has  !

broader use of the tenn assessment that includes audits, monitoring. survey. document review. and special assessments. )

• Descriptr . how "self assessment" activities may be included m me QA Program was added. (Section 2).

• Provides for use of additional approved corrective action

hanisms for audits (Section 9).

• Some rewording of text throughout the document have been  ;

done to remove redundancy and to improve the description of work processes at GPU Nuclear.

10 The purpose of this rc.ision is to reflect changes in the R. E. Tilton Nuclear Safety Assurance Process uhich impact the plan C. Faust organizationally. The changes combine Licensmg and Regulatory Affairs with Nuclear Safety Assessment. T. G. Broughton Signatures for concurrence and approsal obtamed from those directly affected only.

w ro m euso 70

! GPU NUCLEAR CORPORATE Number GPU NUCLEAR i

eOucy AND PROCEDURE uaNUAt iooo-etN-7200.oi l

Titie: GPb Nuclear Operanonal Quality Assurance Plan Revision No.

10 The Director-Nuclear Safety Assessment repons directly to the Director- Nuclear Safety & Techmcal Seruces and has direct unencumbered access to the Directors of each of the nuclear stations with regard to actiunes affectmg quahty. This reponing relationship has been established to provide sufficient independence from the mtluence of costs and schedules to be able to effectively assure conformance to Quality Assurance Program requirements.

The Director-Nuclear Safety Assessment has no duties or responsibilities unrelated to the responsibihties contamed in this document that would prevent the required attention to quality assurance maners. The Director-Nuclear Safety Assessment has the authonty and responsibility to:

a. Develop and admmister the maintenance of the Operanonal Quality Assurance Plan and Nuclear Safety Assessment procedures required to assure that all GPU Nuc! car activities provide the required high degree of safety and reliability. I

b. Assess. audit. and momtor the conduct of GPU Nuclear acunnes to assure that they proude the required high degree of safety and reliability and are carried out consistent with all apphcable laws. regulations. regulatory commitments. licenses. corporate policies and other requirements. Assessment schedules are developed and implemented to ensure all required are:.s are assessed.

c. Establish and conduct of nuclear safety renew and assessment acunnes uhich include those [

of the nuclear stations' Independent On-site Safety Review Group and the General Office Renew Board.

d. Idenufv and repon noncor.formances as they may exist. Imtiate. recommend or proude soluuons through designated channels. Venf implementauon of resoluuons as required.

e Iniuate stop work or umt shutdown recommendations when warran:cd by a safety concern and obtam una shutdown unh appropnate unper-management concurrence.

f. Proude for a review of selected documents which presenbe methods for acunnes and quality l requirements for items within the scope of this Plan. Refer to Appendix B of this Plan.

g Proude for a reuen for concurrence of Contractor and Vendor Quahty Assurance Programs as speci6ed m Section i

h. Direct and manage Nuclear Safety Assessment.

! Proude a workmg mterface and one of commumcanon with other diusions and other apprepnate industry and regulators groups for all program matters.

j Proude mdoctnnanon. eeniticanon. and or trammy programs for Nuclear Safet)

\ssessment.

k. .\ssure QA program indoctnnanon of appropnate personnel outside of Nuclear Safets Assessment is pros ided.

oi ,, y e nio 13 0

- -- .- - - . _ . ~_ . __- -. - - _ _ . . - - . _ _ - -

GPU NUCLEAR CORPORATE Number Gpp POLICY AND PROCEDURE MANL AL l000-PLN-7200.01 NLICLEAR 4

Title:

GPU Nuclear Operational Quality Assurance Plan Redsion No.

10 1.

Immediately notify the President and appropriate Unit Director of any sipificant quality related problem or deficiency.

, m. Perform assessments on a planned and periodic basis to comprehensively determbe the effectiveness of the program and its implementation; and. detect adverse trends that may be i present.

I 1

n. Issue periodic reports to the President and Division Directors on the effectiveness of l implementation of activitics within the scope of this Plan.

o. Establish and maintain a Supplier Quality Classification List (SQCL) which documents the results of the examinations of prospective suppliers.

1

p. Assist in the development of a GPU Nuclear comprehensive self assessment Program.

Provide oversight of scif assessment activities to determine effectiveness of the program.

1 j q. Review and concur with all procedures for reporting and controlling of non-confermances for l compliance with the requirements of this plan.

r. Resiew. serify and concur with closcout of non-conformances, when required.

s. Provide for maintenance of the operating license for the Nuclear Plants.

t. Provide interpretations as necessary of this plan and the operating license to ensure proper implementation.

u. Coordinate the Safety Review Process to ensure consistent application of company and regulatory requirements.

v. Serve as owner for the " Issues Management" process by establishing and maintaining standards that provide for a graded approach to resolving issues based on complexity and risk.

w. Prouw principle interface and control with all non-financial, non-environmental regulatory agencies for GPUN including NRC, appropriate state agencies. and supporting legal services.

In addition, ensure preparation and coordination of GPUN responses to regulatory agencies, including NRC inspections and enforcement bulletins, circulars. notices and generic letters.

and activities associated with INPO and NEl.

Note: For responsibilities regarding the establishment and conduct of the General Office Review Board (see item C above) the Director-Nuclear Safety Assessment has a direct reporting relationship to the President.

1.6 Director-Human & Administratisc Services The Director-Human & Administrative Sersices reports directly to the President. The Director's Quality Assurance Plan responsibilities consist of establishing. implementing and maintaining m:rou.w ou ILO

GPU NUCLEAR CORPORATE Number

.GPU NUCLEAR POLICY AND PROCEDURE MANUAL 1000-PLN-7190.01 l

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

! 10 ,

for-duty testing plans and procedures; coordinating administration of the GPU Nuclear policy and procedure system; establishment, maintenance, and implementation of plans and procedures for nuclear plant security, access authorization. safeguard contingencies and plant security guard force  ;

training and quali6 cation consistent with Corporate Policies and all applicable laws.

j l.7 All GPU Nuclear- Management

Management personnel in each disision are responsible for the implementation of the Quality i

Assurance Program by their division. department or group. including the development and i i

implementation of approved documents; performing activities in accordance with expectations and i

requirements; use of qualified personnel and equipment; and the training and indoctrination of their j personnel associated with those of their activities within the scope of this Plan. l

. I i

( Management personnel in each division are responsible for the conduct of the technical and

} independent safety reviews within their division, department or group. This includes the identification and qualification of personnel as Responsibie Technical Reviewers and Independent Safety Reviewers; the review and approval of documents within their functional area of responsibility as l assigned by the GPU Nuclear Review and Approval Matrix (1000-ADM-1291.01); and other activity

] as may be required to implement Technical Specifications Appendix A, Section 6.5. requirements.

4

I Management personnel in each division are responsible to provide sufficient support to the assessment process and to take positive action to evaluate and correct nonconformances identified in the conduct of their activities within the scope of the Plan. This responsibility includes correcting adverse trends l

as may be identified.  ;

4

The Director or Manager of each department performing activities within the scope of this Plan is responsible for the preparation. approval and implementation of documents which prescribe activities j and/or tasks necessary to effectively implement this Plan. This responsibility includes ensuring that i provisions are made for interface controls for internal and external lines of communications among

] participating organizations and technical disciplines.

t Each Department Manager is responsible for ensuring that procurement documents contain  ;

i appropriate requirements for the identi6 cation and control of materials, parts. or components and that

, only materials. parts or components uhich have been properly accepted are used. Each Department i Manager is responsible for maintaining records as required by this Plan until tumover to an approved l record storage facility.

1.8 ,Extemal Organizations Suppliers who provide items and/or senices uhich are within the scope of this Plan snail have a QA Plan and implementing procedures appropriate for the items, consumables. md/or seruces. The suppliers QA Program may be supplemented or replaced by this Plan. The supplier's QA program shall be subject to review for concurrence by the Director-Nuclear Safety Assessment or his designee.

The extent to which the supplier's QA program will be applied will be specified by procurement documents.

i<icamr.u m 15.0 l

1 GPU NUCLEAR CORPORATE Number i ,@PU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01

. NUCLEAD

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

1 10 4

1.9 Minimum Oualifications of Assessment and insocction Personnel The Director-Nuclear Safety Assessment shall have. as a minimum a baccalaureate degree in engineering or science, with at least fificen (15) years of technical experience including ten years of managerial / supervisory experience in operational, technical support and/or quality assurance activities associated with nuclear power plants. At least onc 3 car of this experience shall be in a nuclear assessment oversight organization or a special training program approved by the Director-Nuclear Safety and Technical Services and will be completed within six months of assuming the position.

Additionally, the Director-Nuclear Safety Assessment must be knowledgeable in operating license conditions. other regulatory requirements and commitments, plans. procedures and quality and technical standards.

Managers within Nuclear Safety Assessment who report to the Director-Nuclear Safety Assessment shall have an academic degree in engineering or a physical science and 10 years of professional level i experience in nuclear power or related technical fields. Managers must have at least 3 years {

experience in a position responsible for supersision of operational, technical and/or oversight activities. The degree requirements may be waived for personnel with demonstrated exceptional capability and a minimum of 15 years of appropriate experience.

Each Independent On-Site Review Group Engineer shall have an academic degree in engineering or a physical science field and 3 years of professional level experience in the nuclear power field including technical supporting functions or 8 years of appropri.ite experience. Credit toward experience will be given for advanced degrees on a one-to-one basis up to a maximum of two yrvs.

For personnel performing inspection. examination ar.d special processes, the qualification criteria shall be delineated to the techniques ofinspection or items being inspected and the technical abilities of the person being certified will be consistent with the assigned tasks (e.g., electrical inspection, mechanical inspection.)

The qualification requirements n.d ;xperience levels for other Nuclear Safety Assessment personnel are such as to assure competcace commensurate with the responsibilitics of and the Regulatory Guides associated with the activities performed by the position.

1 i

I l

1 Kll(M)AP.010 l6 0

GPU NUCLEAR CORPORATE Number spgs POUCY AND PROCEDURE MANUAL 1000-PLN-7200.01 NU. CLEAR

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

10 obtain the necessary access to management to conduct the review and audit. resolve any issues which may arise from the review and audit and secure additional technical support for the perfonnance of audits ar, may be required.

2.5 Operational Ouality Assurance Plan Control This Plan is authorized by the President and requires that the appropnate !cvels of management. as designated herein, implement the Program. This Plan is controlled ta ensure that only the latest approved revision is implemented. This Plan is implemented through approved documents (refer to Section 3.0).

Appendix A provides a correlation of the sections of this Plan with the requirements of 10CFR50 Appendix B; 10CFR71. Subpart H: 10CFR72 Subpart G; ANSI N45.2; and ANSI N18.7.

2.5.1 Approval This Plan shall be originated by the Director-Nuclear Safety Assessment and be approved by the President with concurrence by the following:

Director-TMI Director-OCNGS

, Director-Engineering Director-Financial & Planning Services Director-Nuclear Safety & Technical Senices Director-Human & Administrative Services Corporate Procedure Administrator Responsible Technical Reviewer 2.5.2 Revisions The Director-Nuclear Safety Assessment is responsible for ensuring this Plan is modified and updated as needed. Proposed revisions to this Plan may be suggested by GPU Nuclear personnel by submitting a written request to the Director-Nuclear Safety Assessment.

The Director-Nuclear Safety Assessment. shall for each revision to this Plan, determine if the changes reduce or do not reduce the commitments in this Plan previously accepted by the NRC.

Revisions to this Plan that do not reduce commitments to the NRC shall be originated by the Director-Nuclear Safety Assessment and approved by President with the concurrence of any Division Director affected The Cover Page containing the approval and concurrence signatures of the President and the Division Directors shall be retained. Resisions of this type do not require approval by the NRC prior to implementation. but must be submitted to the NRC at least annually. The Document History page will be utilized to identify such changes.

1 RI.TWJAP olo 21.0 i

GPU NUCLEAR CORPORATE Number GPU NUCLEAM POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No. l i 10 t

'7 Indoctrination and Trainina -

1 4

Formal indoctrination and training programs for personnel performing or verifying activitics within the scope of this Plan are required to be established and maintained. A Training Department is ,

! estabhshed and staffed and is responsible for planning, scheduling developing and providing training 4

to GPU Nuclear personnel. The indoctrination and training programs are established by on-site and '

by off-site organizational units responsible for the perfonnance or verification of activities within the 3

i scope of this Plan. I l

The proficiency of personnel shall be evaluated; and. measures to maintain proficiency shall be  !

) implemented through either retraining. reexamining and/or recertifying.

l When certification is required. a certificate (s) shall delineate the specific function (s) the individual is ;

certified to be able to perform and the criteria used to certify the individual for that function (s). i 2.8 Classification Process i

Activities that are within the scope of this Plan and general criteria for further classification of tasks associated with these activities are identified in Subsection 2.2.2 of this Plan. Subsection 2.3 provides further basis for grading the extent of application of the requirements of this Plan to activitics. Documents that prescribe methods for implementing the requirements of this Plan shall be marked as specified by 3.2.2.2.b of this Plan.

1 Items within the scope of this Plan shall be classified and identified as " Nuclear Safety Related" or l

" Regulatory Required." A procedure (s) shall be prepared to establish, implement and maintain a classification process for items. This procedure (s) and changes thereto shall be reviewed for concurrence by the Director-Nuclear Safety Assessment or designee prior to issuance.

Structures, systems and components shall be identified on a Quahty Classification List (QCL). A QCL shall be established and maintained. by Engineering. for each plant. The classification of j structures. systems and components will be subject to mdependent design review as part of the classification process.

Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts and materials that perform or contribute to the performance of a Nuclear Safety-Related or Regulatory Required fimetion are within the scope of this Plan and classi6ed similarly as the component of which it is a part. For procurement of spare or replacement l parts uhich are of a difTerent classification. the classi6 cation will be determined by Engineering. The l

determinations will be documented. retained and cubject to review and assessment by Nuclear Safety Assessment. Refer to Section 5.0 for additional requirements.

2.9 Reculatory Commitments Records of regulatory requirements and commitments are maintained by Nuclear Safety Assessment.

Appendix C herein lists those Regulatorv Guides uhich contain specific quality assurance requirements with the stated GPU Nuclear position. exceptions and/or clarifications prosided. These must be complied with in conjunction with this QA Plan. Appenda C will be revised. as necessary.

to reflect any change in the GPU Nuclear conunitment to the Regulatory Guides. Nuclear Safety su;iwwmo 23.0

GPU NUCLEAR CORPORATE Number

.GPU NUCLEAD POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

10 Assessment provides GPU Nuclear documented positions and interpretations on all other regulatory  !

guides not contained in Appendix C of this Plan as may be required.

2.10 Resolution of Disnutes and Escalation All personnel, including those performing assurance activities who are not part of Nuclear Safety Assessment. have access to the Director-Nuclear Safety Assessment to raise quality or safety concerns. Disputes involving quality or safety arising from a difference of opinion shall, if possible.

be resolved at the level at which such disputes occur. If this is not possible, the difference of opinion d shall be escalated through supervisory / management levels until resolution is achieved.

The Director-Nuclear Safety Assessment shall make the decision on matters related to if and to what degree this Plan applies to activitics, quality requirements, and verification and acceptance to established requirements.

1 The Director-Engineering shall make the decision on matters related to classification ofitems. and  !

technical requirements or design changes.  !

l The Director-Nuclear Safety Assessment shall be responsible for evaluating deficiencies generated by Nuclear Safety Assessment, as specified in 8.2.8 of this Plan. Escalation of significant deficiencies to higher management levels shall be evaluated in accordance with written procedures when inadequate or untimely responses occur.

2.11 Safety Review Prouram The safety review program consists of technical review and as necessary, an independent safety review.

The technical res iew is a thorough review conducted by someone other than the individual whe prepared the work. This review is performed by a qualified Responsible Technical Reviewer en  !

documents and substantive revisions of documents as specified by the GPU Nuclear Review and .

Approval Matrix. (1000-ADM-1291.01)

. The independent safety resicw is an independent review of documents and substantive revisions of documents as specified by the GPU Nuclear Review and Approval Matrix, it includes a review of a safety evaluation. This review is conducted by a qualified Independent Safety Reviewer (ISR) on safety evaluations associated with documents and substantive revisions to docummts as specified by the GPU Nuclear Review and Approval Matrix. The ISR shall not have diren responsibility for the activity reviewed.

kiflo)Alw tu 24 0

GPU NUCLEAR CORPORATE Number

'EPU NUCLEAR POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 l

Title:

GPU Nuclear Operational Quality Assurance Plan Revision No.

109

Appendix C - Part 2 NRC Regulatorv Guide 1.30. Aueust 1972 j Ouality Assurance Req 1irements for the Installation. Insocction and Testine ofInstrumentation and Electric Eauipment 1

GPU Nuclear shall comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic /a6ninistrative 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 stall 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 conducted during the construction phase. In lieu of this GPU Nuclear utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test procedures during the operational phase.

NRC Reculatorv Guide 1.33. Rev. 2. February 1478 Quality Assurance Program Reauirements (Oneration)

He GPU Nuclear QA Program complies with the regulatory position of this guide with the following clarifications:

1. Regulatory Position C 4 of the regulatory guide The frequency of performance and the minimum topical coverage ofintemal audits will be consistent with Appendix E of this Plan.

2. Paragraph 5.1 of ANSI N18.7-1976 titled " Program Description" This paragraph refers to the compilation of a "sununary document" to identify the sources, index the source documents to the requirements of this standard and to provide a consolidated base for the description of the program. For the purpose of clar;ty. this "GPU Nuclear Operational Quality Assurance Plan" is the " summary" document required. Appendix A correlates the sections of this Plan to ANSI 18.7 1976. Section 2.0 provides the " consolidated" base and description for the program. Implementing documents are identified in Section 3.0. are required to be consistent with this Plan and Appendix C of this Plan. and are marked as stated in Section 3.0.

3. Paragraph 5.2.2 of ANSI N18.7-1976 titled " Procedure Adherence" In accordance with Section 6.8.3 of both the Oyster Creek and TMI-l Technical Specifications. temporary changes shall be approved by two members of GPU Nuclear Management StafTqualified as Responsible l Technical Reviewers and knowiedgeable in the area affected by the procedure. For changes which may affect the operational status of facility systems or eqmpment. at least one of these individuals shall be a member of facility management or supervision holding a Semor Reactor Operator's License on the facility.

uwnuuno 68.0