ML20147E225
| ML20147E225 | |
| Person / Time | |
|---|---|
| Site: | 05000000 |
| Issue date: | 11/30/1981 |
| From: | Stromberg M GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML17342B416 | List: |
| References | |
| FOIA-87-696 7-18-01, 7-18-1, NUDOCS 8801210046 | |
| Download: ML20147E225 (43) | |
Text
-
J "A - W k
NAS/O Procecure Number p-,-)J Muclear 11-01 Date issued l
f 7
Revision No.
Authorized By '#1.j Mgm Important To Safety Yes @
No gp cs
( $
l
/ >O. >
"G
(
f
% *>/f 3 b Act 4
4' QUALITY ASSURMICE AUDITS Approval:
wtw Director, Q lity Assurance Concurrence:
Fszn - V7-69'6 B/)7 8801210046 880106
.- [
--
- E, A-# L' WEISSB.7-696 PDR annoOA74 Form -Q A 7 2 4 4 1 Res
Procedure Number I'
f=.
UC Gar 7-t8-ot geoe t or 1
f Date issued 11-81 7
Revision No.
Quality Assurance Audits Index and Revision Sheet Page No, Revision No. 7 1
2 3
4 I
l l
5 6
- l l
7
- I 8
l *i 9
- 1 1
1 10
- l i
11 l
l I,
12 l
13 1
- 1 14 l
- l l
15 i
- I l
i l
l 1
I l
i I
l l
l l
l l
l l
l 1
l i
l l
l I
(
l l
I l
l i
I I
l l
1 I
l i
I I
l l
l l
l l
1 l
l I
I l
l l
1 I
\\
l l
l 1
l l
l I
I l
l l
l l
l 1
I I
I l
l i
i i
I 1
I l
l 1
l I
l i
l l
A0000626 Fo<m CA 7 24 4 Ae -
l
SubjIct:
Procedure Numb:r p,,
og 7-18-01 2
15 Revision No.
Oate Quality Assurance Audits 7
11-81
'x 1.0 PURPOSE 1.1 The purpose of this procedure la to establish a Quality Assurance
{
s auditing program. Quality Assurance auditing will be conducted to verfly compliance with the General Public Utilities Nucice,r Corpora-i tion (GPUNC) Quality Assurance Programs / Plans, applicable codes, standards, Technical Specifications, and contract commitments.
2.0 SCOPE 2.1 This procedure assigns responsibilities of individuals associated with the auditing program end describes tasks to be accomplished during the auditing process.
i L
3.0 APPLICABILITY 3.1 This procedure is applicable to personnel performing QA auditing i
functions. Site auditors will follow the requirements of this I
procedure and supplemental site procedures, where applicable.
3.2 The audit program described herein applies to:
- 1) GPUNC internal QA audits of project functions, 2)
Design organizations and the quality assurance programs of design crganizations,
- 3) GPUNC QA participation in technical audits of specified design activities, 4)
Vendors and subvendors or equipment apd services, 1
5)
Shop and site construction activities of contractors and subcontractors, 6)
GPUNC Start-up, testing and operating activity, 7)
Technical Specification, Operating QA Plans and operating licenae provisions,
- 8) Nuclear Fuels Program.
Audits can be categorized as QA Systems Audits or Technical Audits.
l Form OA 724 2 Pev.1 A0000271
Subjnt:
Proczdure N b
7-
-01 Page 3
of 15 Revision No.
Date Quality Assurance Audits 7
QA Systems Audits are conducted to verify that the QA Program elements of the applicable organization are being implemented in accordance with their approved Quality Assurance Plan or Prograu and that the program is effective.
Internal audits are performed to verify the effectiveness of the QA Program, including implementation at sites and corporate of fices. External audits of Contractor / Vendor QA Programs are conducted at their facilities.
Technical Audits are comprised into three types:
Design Audits, Product Audits, and Process or Activity Audits.
- 1) Design audits will be conducted to verify that the designer has established an adequate design basis for the particulhr activity being audited and these design bases are being correctly translated into specifications, drawings, procedures and instructions.
Design audits will normally be conducted by personnel technically qualified to identify inadequate or incorrect assumptions, calculations, material selection or other design deficiencies. GPUNC Technical Functions will provide personnel of pertinent disciplines to participate in design audits.
- 2) Product Audits will be conducted to verify that the QA/QC require-ments of the applicable product specifications have been met.
Thesc audits may be applied to a specific operation or to all documentation 1eading to final acceptance of the product.
3)
Process or Activity Audits are conducted to verify that a selected process or activity is performed in accordance with the applicable QA Program, Regulatory and Cocpany requirements.
4.0 k'.FERENCES 4.1 10 CFR 2,10/80, Proposed General Statement of Policy and Procedure for Enforcement action.
4.2 10 CFR 50, Appendix B, "Quality Assurance Requirements for Nuclear Power Plants and Fuel Reprocessing Plants."
4.3 10 CFR 71, Appendix E, "Quality Assurance Criteria and Shipping Packages for Radioactive Material. "
i 4.4 USNRC Regulatory Guide 1.144, Rev.
I Quality Assurance Programs for Nuclear Power Plants.1, Requirements for Audit 4.5 ANSI N45.2.10 - 1973 "Quality Assurance Terms and Definitions."
4.6 CPUNC Procedure, 7-18-02, "Quality Assurance Auditor Qualifications."
i l
Form QA 724 2 Rev f
A000027'
f.
Subject:
Procedure N p,g, 4
og 33 y_
Revision No.
Date
[
A Quality Assurance Audits 7
11-81 4.7 GPUNC Technical functions Procedure LP-007, "Review of Potentially Reportable Incidents."
5.0 DEFINITIONS 5.1 The Quality Assurance terms and definitions listed in ANSI N45.2.10
- 1973Property "ANSI code" (as page type) with input value "ANSI N45.2.10</br></br>- 1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. are applicable to this procedure.
6.0 RESPONSIBILITIES 6.1 The Vice President - Nuclear Assurance, through the Director, Quality As su ra nce, is responsible for ensuring that an audit program is implemented for all signif f. cant c.ctivities affecting safety related design, procurement, construction, installation, testing and operations.
I a
The Director, Quality Assurance is responsible for:
- 1) Establishing and approving an auditing program which will verify GPUNC compliance with the GPUNC Quality Assurance Program requir ement s.
- 2) Ensuring that a formal auditing schedule is maintained and updated at least every six months.
& Audit is audit team leader.
- 4) Initiating unscheduled audits at his discretion when significant changes are made in functional areas of the Quality Assurance program, when it is suspected that saf ety, performance or reliability of an item is questionable or when an assessment of certain areas of the Quality Assurance Program is considered l
necessa ry.
- 5) Assessing the eff ectiveness of the. Quality Assurance Audit Program.
- 6) Resolving and closing those findings submitted to him by the Manager, QA Program Development & Audit.
6.2 The Manager, QA Program Development & Audit is responsible for:
l Establishing a program' of home office, site and nuclear fuels 1) audits to verify compliance with the GPUNC QA Program and I
technical specification requirements, l
l
- 2) Reviewirg and approving, at least every six months, a f ormal l
schedul.. f or perf or=ance of cudits,
l
- 3) Ensurirg that audit team leaders are qualified as Lead Auditors in accordance with applicable GPUNC QA procedures, i
i Form Q A 724 2 Re.
ACCCO??'
Subject:
Procedure Number p
g 7-18-01 5
15 Revision No.
Date Quality Assurance Audits 7
11-81
- 4) Ensuring that required qualification records are maintained for Lead Auditors, and, providing a list of certified lead auditors to the individuals responsible for QA Audit subsection supervision.
- 5) Reviewing and approving the audit reports. This responsibility may be delegated in writing to others at the discretion of the Manager, QA Program Development & Audit.
- 6) Ensuring issuance of a periodic Audit Status Summary Report (See example, Attachment 4 f or typical report form),
- 7) Taking action to evaluate the situation to ensure that quality has not been compromised when advised that the target date for submittal of corrective action or implementation of corrective action has been exceeded by the audited organization, f
- 8) Submitting to the Director, Quality Assurance those findings to which he has been unable to obtain an acceptable response and attempts have been made to resolve the findings with the responsible levels of management.
6.3 The Nuclear Fuels QA Engineer is responsible for:
I
- 1) Coordinating QA Fuels Audits with the affected organizations and GPUNC Nuclear Analysis Section,
- 2) Ensuring that audit plans and checklists are prepared prior to fuels audits and are approved by the Corporate QA Audit Supe rvisor,
- 3) Ensuring fuels audit notifications add audit reports are issued and that proper distribution is carried out,
- 4) Ensuring that follow-up action is taken and proper close-out is made of open findings,
- 5) Ensuring that a f uels audit status summary report is generated as required and that proper distribution is carried out.
6.4 The individual responsible for QA Audit subsection supervision is responsible for:
- 1) Establishing and updating a subsection audit schedule as required; the schedule is to be subwitted to the Manager, QA Pro-gram Development & Audit for review and approval.
- 2) Denoting the audit scepe of Q.A. audits,
- 3) Approving audit plans and audit checklists.
- 4) Assigning qualified audit team leader and audit team members, Form QA 724 2 Res A00CO2'
Subject:
Procedure Number 7-18-01 Page 6 of 15 Date
[
Quality Assurance Audits 7
11-81
- 5) Coordinating QA audit activities with any affected organi-zations.
- 6) Reviewing and concurring with audit reports and submitting them to the Manager, QA Program Developent & Audit for approval,
- 7) Ensuring the distribut'.on of audit notifications and audit reports.
- 8) Submitting to the Manager, QA Program Developent & Audit those findings to which he himself has been unable to obtain acceptable response frcm apprcpriate levels of management,
- 9) Issuing nonthly audit status summary reports to cognizant management with copies to the Manager, QA Prcgram Develcpment & Audit, Site audit subsection supervisor personnel are responsible to 10) insure that audit schedules address the auditing requiremants of the stations technical specifications, applicable ANSI standards and other atx3iting requirerents as may apply to the station. This responsibility includes coortlination of audit schedules with the Corporate Of fice audit subsection to assure ecmplete coverage.
6.5 Audit Team Leaders are responsible for:
l Orientation of the audit team, including review of applicable 1) documents and preparation of audit checklists as required, j
- 2) Arranging atx3it functions with the appropriate organization er contractor being audited,
- 3) Cocrtlinating the audit team, i
- 4) Establishing the place of audit, l
Ensure that any technical or manage: rent persons used to support 5) i an audit activity have been prcperly indoctrinated and are performing in accordance with requirements established by the team leade::,
- 6) Assuring comunication within the team and with the organization being audited, Assure that each audit finding is based on objective evidence 7) and is a clear statement of the facts,
- 8) Revies, analyze and concur with each audit finding, I
- 9) Participating in the audit process, I
- 10) Condense all similar finiings for presentation,
\\
l Fo,m QA.724 2 Rh 1 AOCCO27'
Subject:
Procedur4ggr page 7 of 15 r
Revision No. 7 Date Quality Assurance Audits 11-81
- 11) Coordinating the preparation and issuance of the audit report in approximately twenty working days from the time of the post-audit conference,
- 12) Conducting timely follow-up actions to ensure that effective corrective actions have been implemented as directed by the individual responsible for audit subsection supervision.
i 7.0 PREREQUISITES - Not Applicable 8.0 REQUIREMINTS 8.1 Audit Schedules I
- 1) Audit schedules will be established for each site location and the corporate office.
- 2) Audit schedules will be for a period of two years and will be formally updated at least every six months.
i
- 3) Audit schedules will include an audit matrix that identifies applicability of each required activity to the organization (s) that implement the activity. The matrix will be sufficiently detailed to insure that audit requirements of technical specifica-tions, ANSI standards and other corporate plans / procedures are identified.
- 4) Audit scoping documents will be developed to show exactly what activities / organizations are to be audited for each scheduled audit. These documents will be updated as appropriate.
8.2 Audit Notification
- 1) Audit notifications will be made using Form A0000411, Attachment 1.
Notification of GPUNC internal QA audit shall be addressed to the Vice President of the audited department; action copies shall be sent to the appropriate management personnel gf the audited organization.
- 2) Audit notification of equipment and/or material subcontractors
~
shall be sent to the contractor actually procuring the items.
- 3) Notification of QA audits shall be as follows:
i a) Notification of internal audits shall be by the individual res-pensible for QA audit subsection supervision.
b) Notification of project related Contractor audits shall be by the appropriate Project Manager.
Form Ok724 2 Pev.1 ACoCO271
Subject:
Procedure Number Page g
3$
of 7-18-01
[
Revision No.
Date
\\
Quality Assurance Audits 7
11-81 c) Notification of other Contractor / Vendor audits shall be by the appropriate Contract Administrator (or buyer).
d) Notification of nuclear fuel audits shall be by the Nuclear Analysis Manager.
- 4) At the time the Audit Notification is issued, the audit shall be assigned a unique report number. GPUNC QA Audits and Audit Reports shall be numbered as indicated below:
Exacple:
,S_-0 C-81 -02
-No. of Audit (Chronological Order)
Year Project (1)
Type (2) i (1) Project OC = Oyster Creek TMI = Three Mile Island l
g SAX = Saxton Station i
COM = Coc=on to more than one Project (2) Type S = Site Audit 0 = Hoce Office Audit l
{
F = Fuel Audit 8.3 Audit Preparation
- 1) The Audit Team Leader shall develop an audit plan describing the audit scope, audit requirements, activities to be audited, applicable documents and the procedures and checklists to be used.
Audits will include an evaluation of the results of past audits.
l
- 2) Technical specialists assigned will assist in development of check-lists on technical audits.
- 3) Generic checklists for specific QA Program elements or technical product audits can be used when applicable.
If checklists are not available, one cust be prepared by the audit team and j
approved by the individual responsible for QA audit subsection supervision prior to conducting the audit. Examples of generic
{
checklists and the format to be used are attached as Attacheent "A" (Generic Audit Checklist) and Attacheent "B" (Technical Audit Checklist). Generic checklists must be checked against specific applicable require =ents.
Form CA 724 2 Rev i A000c27'
~,
Procedure N
Subject:
be{
p,g, 9 og g
'I " " '
Date 7
11-81,
Quality. Assurance Audits J
- 4) The GPUNC Quality Assurance Department shall use qualified auditors and/or technical specialists or others on loan as the audit subject requires. Audit team members may be obtained f rom other departments as the need for technital specialists is identified. Audit team merbers shall be qualified in addordance l
l with 7-18-02.
}
8.4 Pre-Audit Conference A brief pre-audit conf erence shall be conducted b / the audit teamThe leader' at the audit / contractor site with cognizant management.
purpose of the conf erence sha17 be to tonfirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and establish channels of communication.
8.5 Audit Process The Audit Team shall systematically audit the implementation of the specifically assigned audit areas.
All audit findings shall be documented on Form A0000410 (Attachment 2).
The following guidelines shall be used in the performance of an audit.
- 1) Team members shall audit in accordance with written che6klists and/or procedures to ensure the required depth and continuity of audits. This shall not, however, constrain the audit scope or depth as the audit develops.
- 2) The selected ele 2ents shall be audited to the extent necessary to determine whether or not a partitular function is being implanented eff ectively.
- 3) All activities and documents reviewed during the audit shall be identified in suf ficient detail to furnish the basis for the verification of the degree of effectiveness of the audited activity.
- 4) Nonconformances, such as inadequate procedures, failure to follow approved procedures, violations of one or more QA Program elements, incomplete, inadequate or incorrect supportive documentation shall be reported as an audit finding using Form A0000410 (Attachment 2) and processed in a cordance with this procedure.
If appropriate torrective attion is taken and verified before completion of the audit, the corrective action and verification will be documented on the finding form by the l
lead auditor and issued as a closed finding.
When a condition cannot be shown conclusively that a noncon-5) formance exists due to lack of information or unavailability of
{
I i
Fom OA 724 2 Rev l
mOCoo.
subject:
Procedure Nu ber 9l P89e 10 of 15 Date Quality Assutance Audits 7
11-81 6)
If conditions are found on internal aMits which are evaluated as not significant indicators of inadequate procedures, failure to follcw procedures, violation of one or nere QA program elements or incmplete records which do not place the quality of an item or activity in question, then an audit finding need not be written.
Instead, a deficiency report or other nonconforrance reprting mechanism may be utilized to document and correct the nonconformance. Such cases will be dccumented in the atr$it report.
- 7) During the course of conducting the audit, conditions nay be identified that could be inproved, clarified, deleted or added that are not nonconferm nces. These conditions may be reported in the audit report indicating the nethod or action that nay be taken to inprove or nodify the conditions reported.
'Ihese conditions shall be reported as reccmendations and are not required to be tracked or closed by the atdit subsection.
- 8) If nonconfor ances are found during the atdit, the audited organization shall corduct further investigatien to identify their basic cause, magnitude and extent.
9)
If, during the aMit, a ccedition is obserwd which:
a) represents a significant breakdown of the quality assurance prcgram, or b) may warrant stop wrk, or c) may be reportable urder applicable laws and regulations.
A finding shall be written aid the potential reportability checked off on the finding forn. A ccpy of the finding shall be sent to Licensing for evaluation of reportability. Appropriate action defined by applicable procedures such as a stcp wrk, corrective action, etc. shall be taken. Attachment 5 (Forrs A0000560A-E) ray
{
be used to judge potential reportability. Attachment 5 is not required to be empleted or retained as a OA recod, but the results of the evaluation is to te documented on the finding ferm.
I.
Findings will also be reviewed and assigned a severity level to be determined in accordance with the guidelines prescribed by i
8.6 Post-Atdit Conference
- 1) For internal atdits, preliminary findings shall be presented to the canagenent of the audited organization at the conclusion of the active audit process. The post-atdit conference should te scheduled five days later. The five day pericd will be used to clarify infotration and/or presentation of additional evidence.
At this tire severity levels (similar to those of 10CFP2) shall te indicated on the preliminary firdings. The audited organization will te encouraged to review the preliminary findings and provide 1
written response at the post-audit conference.
I Form QA 724 2 pov, 1 A0000271 1
Subject:
Procedure Number Page i g ot 15 7-18-01 Revision No.
Date
(
Quality Assurance Audits 7
11-81
- 2) A post-audit conf erence shall be conducted by the audit team with representatives f rom the audited organization. The. findings of the audit shall be presented along with any recommendations to correct deficient areas of the quality assurance program described in the findings. Af ter the audit team has explained the findings, a responsible management representative of the audited organization shall sign the audit finding forms to acknowledge understanding of the findings. At that time the management representative shall provide a date (subject to the concurrence of the audit team leader) by which the corrective action responses to the findings vill be submitted (normally not to exceed thirty calendar days f rom the date of the post-audit conf erence).
If written responses are provided, the audit team leader will be prepared to perform a preliminary review of the responses for acceptability. The audited organization will be informed of the result.
8.7 Audit Reports
- 1) Audit Reports (Form A0000412, Attachment 3) shall be completed and signed by the audit tea = leader.
- 2) Audit reports, finding for=s and audit checklists shall be submitted to individual responsible for QA audit subsection supervision for concurrence. Audit reports shall be issued after l
approval by the Manager, QA Program Development & Audit, exc ept as noted in para 6.2 (5) or 8.7 (3).
- 3) Audit reports shall be submitted to the Director, Quality Assur-ance for approval when the Manager, QA Program Development & Audit is audit team leader.
l
- 4) Audit reports shall be issued as follows:
I a) Report of internal audit shall be by the individual responsible for QA Audit subsection supervision.
b) Report of project related Contractor audit shall be by the appropriate Project Manager.
c) Report of other Contractor / Vendor audits shall be by the appro-i priate Contract Administrator (or buyer).
I d) Report of Nuclear fuel audit shall be by the Nuclear Analysis Ma nager.
- 5) Each audit report and any significant findings shall be evaluated by the individual responsible for QA audit subsection supervision to determine if changes are required in the auditing schedule.
Changes to the auditing schedule shall be approved by the Manager, QA Program Development & Audit.
The audit reports issued shall not include the audit checklists.
6)
Fom1 CA 724 2 Rev 1 ACCCO2 P
Subject:
Procedure Number p
og g
Revishx1 No.
Date
[
(
Quality Assurance Audits 7
11-81
- 7) Reports of CPUNC internal QA audits shall be directed to the Vice President of the audited GPUNC division.
Copies of internal audit reports shall be sent, as a minimum, to the appropriate f
management personnel of the audited organization.
l
- 8) Audit reports shall be issued within approximately twenty working days f rom the date of the post-audit conf erence.
8.8 Audit Responses
- 1) Written responses from the audited organization shall be directed to the individual responsible for QA audit subsection supervision.
l
- 2) Corrective action responses shall be evaluated by a Lead Auditor. If the response is acceptable, follow-up action shall be scheduled and conducted by the Lead Auditor.
- 3) If the response is unacceptable, the individual responsible for QA audit subsection supervision will notify the audited organiza-tion delineating the reason for unacceptability and requert the submittal of an acceptable response.
i
.I
- 4) If no response is received by the individual responsible for QA audit subsection supervision, he will notify the audited organiza-tion and request the submittal of an acceptable response.
- 5) If af ter notification by the individual responsibic for QA audit subsection supervision, an acceptable response is not received, he shall submit the finding (s) to the Manager, QA Program Development
& Audit for action.
f 6)
If af ter notification by the Manager, QA Program Development & Audit an acceptable response is not received, he shall submit the finding (s) to the Director, Quality Assurance for resolution.
- 7) All findings submitted to the Director, Quality Assurance for resolution shall be closed by him. He will inform the Manager, QA Program Development & Audit of any follow-up action that may be i
requir ed.
responses should provide the corrective action including the i
- 8) Audit cause, action taken to prevent recurrance and the ef f ective date of l
impl ement a tion.
If the ef fective date of implementation exceeds l
thirty calendar days, the interim corrective action taken to assure l
that the QA program is not compromised should also be identified.
l1 8.9 Audit Follow-up Activity and Documentation
- 1) Upon issue of the audit report, the individual responsible for QA i
audit subsection supervision shall assure that an Audit Closecut Form CA.724 2 pn ACOCO271
Subject:
Procedure Number l
7-18-01 Page 13 of 15 f
Revision No.
Date l
4 Quality Assurance Audits 7
~
11-81 1
i Status Sheet (Attachment 6, Form A000ll37) shall be established.
For each finding, the response required date will be identified and the first entry under remarks will be a paraphrased summary of the finding.
If a response has been received, the response date and implementation date will also be identified.
- 2) When responses are received, the response date and implementation due date will be identified and a dated remark entered as to the accept-ablility of the response.
If the response is not acceptable, reference the memo number that documents the rejection.
- 3) If responses are not received by the response due date, a memo will be prepared within five working days to the responders' supervisor with a copy to the appropriate vice president stating that response has been received and asking for response within ten working days.
not A dated re= ark will be entered in the remarks section stating that an overdue response memo was sent and the new response required date will be entered under the original date.
NOTE:
Initial telephone contact shall be made when responses are due.
If a response can be and is provided within five working days,
}
the memo is not needed.
- 4) Unacceptable responses will be identified to the responder within five working days of receipt by memo with a copy to his supervisor and the Panager, Program Development and Audit.
The memo will ask for a re-submittal date within ten working days. Enter the new response due date in the response required column under the last entry.
- 5) Implementations will noreally be verified within 20 working days af ter due date.
If implementation cannot be verified due to insufficient data accumulation, magnitude of problem, etc. at A
least the interie or immediate corrective action will be verified.
dated remark will be used to identify what was verified and what remains to be verified and by when.
(i.e. - we assign a new date based on audit schedule, suf ficient time :o generate documentation, etc. )
NOTE: For responses which have implementation due dates exceeding 30 calendar days, the interim corrective action should be verified immediately and so noted in the remarks column.
If implenentation has not been acceeplished as stated, a cero will be 6) generated within five working days addressed to the responder's supervisor, copy to the responder, applicable vice president and the Manager, QA Program Development and Audit, stating the action that was delinquent and requesting a new response within ten working days.
A dated remark in the remark column is to identify the inadequate i=plementation memo and a new response required date is to be added to the response required column.
Form GA.724 2 Rev AC000P
Subject:
Procedure Nurnber 7-18-01 Page g4 of 15 f
i Revision No.
Date l
Quality Assurance Audits 7
11-81 I
- 7) Lack of response to any memo's identifying inadequate response or inadequate implementation will be elevated to the vics president level by special note in the monthly report addressed to the Director, Quality Assurance. The input should be made via the monthly report to the Manager, QA Program Development anc Audit as a problem area.
I
- 8) Requests for extensions will be reviewed by the assigned lead auditor and will be accepted / rejected by the individual responsible for QA audit subsection supervision with the advice of the assigned Lead auditor.
A memo may be sent to the requestor confirming or rejecting the ext ens ion. A dated entry in the remarks section will identify the memo and the response or implementation dates will be updated accordingly.
- 9) Responses which indicate that the cognizant party needs to be changed should be followed up in writing to the new cognizant party indicating thc reason for the changes and documenting the acknowledgement of the new cognizant individual. At that time the Audit Closecut. Status Sheet will be spdated to the new party.
- 10) The individual responsible for QA audit subsection supervision shall assure that the information from the Audit Closecut Status f
Sheet will be inputed into the audit tracking system. The system will be utilized to provide audit status reporting and overdue response and implementation information. A monthly status report will be issued to cognizant personnel reporting the status of their findings.
- 11) The time periods identified in this section are approximate and should be complied with to the extent practicable.
8.10 Audit Records Audit files shall be maintained for all audits in the GPUNC QA department home of fice files or at the site in accordance with the applicable record storage procedures.
The files will be indexed first to the project, then to the audit number. Each audit number folder shall be i
established as follows:
- 1) Attached to the right-hand cover in the following order:
Audit Plan Audit Notification Blank, approved audit Checklist Audit Reports
- 2) Attached to the lef t-hand cover in chronological order will be all correspondence concerning follow-up activity.
\\
- 3) Audit files becoce QA records when the audit is closed. These are non-per=anent records and will be maintained for seven years.
The individual responsible for audit subsection supervision Form CA,724 2 Rev AOCOC27'
subi:ct:
Procedurs Numb 2 7_1g_01 Page 15 Of 15 Date
(
Quality Assurance Audits 7
11-81 shall assure that these are forwarded to the appropriate station document center or the Corporte information Center for micro-i graphic retention, annually.
l 8.11 Audit Correspondence l
Audit report transnittal letters and other correspondence such as accept or j reject letters shall be transmitted to cognizant management in the area 1
atx3ited and the Panager, QA Program Develognent & Audit.
9.0 ATIAOBENTS 9.1 Attachment 1, Audit Notification Form A0000411 I
9.2 Attachment 2, Audit Finding Nonconforming Form A0000410 9.3 Attachment 3, Audit Report Form A0000412 I
i 9.4 Attachment 4, Exanple of Audit Status Sumary Report 9.5 Attachment 5, Guidance for Determination of Potential Reportability
+
Ftres A0000560A-E I
9.6 Attachment.6, Audit C1cseout Status Sheet Ebt n A0001137 t
i
\\
\\
Form cA 724 2 Rev ACCCO2-
ATTACHMENT 1'
[r cs1 Nuclear auoir aseoar Audit dates (s)
Audit No.
Facility Reference P.O.
Rev.
Documents:
Rev.
Activity item (s)
Attendees Name Title Representing i
e I
i I
i PURPOSE SUMMATION COMPLETION l
l Close out required for l
l Non Conformances Target Date Signed:
Aud.t Team u6cer Concurres cy:
Audit Approved by:
er Cate D. rector. QA Manager. QA Program l
l Reviewed response. Will check implementation by:
Z R e. A udit C#
D'"
I
- Follow up
[
l Audit Satisf actorily completed, closed QA Date A0000412 a
ATTACHMENT 2 Audit No.:
Date:
Audit Finding U
Sar Nonconformance I
Criteria No.:
Finding
. of Facility / Functions:
REQUIREMENT:
FINDING:
Potentially Reportable C Yes O No Severity Level Cognizant Group / Activity:
r
(
You are recuested to furnish CORRECTIVE ACTION for the finding by the target date below stating the CAUSE for the deficiency,inciucing the exter.t ut the problem, ACTION TAKEN by you to prevent recurrence and ef-fective date of implementation of CORRLCTIVE ACTION. If time recuired to implement corrective action ex-ceeds 30 days you are requested to identify what interim CORRECTIVE ACTION is to be taken to assure that the quality assurance program is not compromised.
Acknowledging finding:
Signature Date Target Oate CORRECTIVE ACTION:
- 1. Response to be sent to:
- 2. For GPUN Internal Audits. copy of response to VP of audited organi:stion Provided By:
S,gnature Date Accepted /Rejectec:
g,,,
l CLOSE OUT:
Avoit Team Leacer oste Computer Tracair 7 Coce AOOOo410 10.*'
ATTACHMENT 3
[c LJ1 Nuclear Auoir norisicarion i
l-Date:
To:
Subject:
Notification of GPUNC-QA Audit Project:
Contract No.:
Gentlemen:
The following information pertains to the audit we plan to conduct on (catei Audit Team Leader:
Audit Team Members:
Date of Pre Audit Conference:
Scope of Audit:
Anticipated Completion Date:
Any cuestions concerning this audit shall be transmitted to the Audit Team Leader.
Very truly yours, CC FORM CA 735 ACooo411 4 -
k 0
Attachmont 4
.e oos s
- 8 A e I
I wu o om um w
=
v,
,e o
o z
w e
l 4
- U d
e Ze OM de 1
DM W W2 o
e oZe o
e %
I Zeo kw d
9 osmo 30 o
e ewww he e
se=
u
=
ww a
=3e
wo om e
3~
o*
==
e 8 >WM e
so 3
owmos O
e
=t u<
we s
%=Nw=
o e
NW4 ek e
ozo u wo e
ammw mu e
< Low ww e
ow<
ou et ow e
=
we womDo cz aa w-o w
==
=s wwor z
ne tv z-w we ocog<
Qe as www w so e
won =r w=
t Wow 3M de eewmk za we>>E a a m e e
wd de ce zwzme zw e
=4 osum4 MJ 4
M e he m Ow a
wa d<wso ww e
a wwusw w
e e
assuw oC e
t e = s oocoo ao oc o ooo econoce s w ememe me em e mee camouco i
EW4 e wa s dedde de ce e eee moooooo e
woe ammma mm NN N
NNN MMMMMMM I
L 8
t C
3
- We#W NN N
N rd N dededed e
a e
ooooo ao ao o ooo ooooooo I
ei won oceen e o ooo ooooooo e ewe mamme e
mee emecome e
e => e NNs%%%%
>v i
o=e accom e m
mee mmmmmme
==
ce two Nummm
=N m
ooo omonoon op We MUe f
3e wl wwe mmNNm um
- +
9+4
+++449m 4m
< s mas comme ao ooo economo
~
tn 44 wa
(-
w, o=s deedd de mm ~
~~~
mmmmmmm o~
ue woe ooooo ao ooo ooooooo e
e own momem em mee
======e e
ZMe ae LDs NNNNN NN o
ao MMMmMMM oe dos
%s
%s L8 wwg mmmmm mm 44 4
e mmmmmmm we aus ooooo ao ao o -
ooooooo e,
M ww e vos DDDDD Du ze <
2222222 e
wo s av t
8 e
a sa
=
2r =
s ud 6 mmmmm um MM M
QI
=31 wwwsd wd WW d
=TT WWWWWWW wa
<o-
=
wwssssm o
N-e cocco co oo o ocococo we
>s o====
=x
=x
=
www occocoo oe
==1 meddee ed ed e www 9 0 0o0 w
W W
M I oNS SCEEEE EC 4 w M99999%9 W 4 4, e
o
= e w-e e
m i e
3CC000 00
>QO Q
>dec TwwkWWWW ce w
w w
m l Me wmdfdd de EMd d
EdMM mMeded*M g e Us c o se o o op oo o coo ocoooue os 4 8 Mooooo ao Goo O
Coco wooooooo 9
3 3
m E
was eccMd de de M
Ned ema==me i
Lot ooome MM wm m
omm MMooooM Qe
>M i pococo ao ooo o oooo oooooooo m
we Mb N
e e
e W
wn)
L wy e Ce of McA A
MefA Me6@eeee
.g r; t ke Nooooo ao ooo o meno mooooooo ow I os
%ooooo ao
%oo o %ooo Noooonee g i N
M M
M Z
W I m
o e
o o
L m e
@ deen NN 46 h
d46 enomfed u
M8 ocoom um me d
omo OUmmoon e t U
m M
N m
1 o00 m
a m
=
4' kos A
C C
C C
m ha e w I
====22 22
- E 2 m222 m2222222 U
g o
O i
M
- a
=* 4 h a) e o== P k F4 N o e famMJ
- 1 en eg M J.% d A 5
cQE mot cocoom um een a
Good monocono e
4m te,,1 JhMMOo ou Goo M
ts-s@ +
M 8toVuo@
e4 o
e o
o e
M weM S e
o e
o
\\
w H N 4 03 N
\\J 6
e w se e9&
e e
e e
e p.
e e
e
ATTACHMENT 5 Page 1 of 6
{
FINDING TRANSMITTAL FORM From:
Manager. QA Program Development & Audit Date:
To:
Supervisor. Licensing
Subject:
Finding, No.:
Audit No.:
C The attached addit finding has been evaluated by QA and found potentially reportable. Please reviev the finding and take action you consider necessary to inform Regulatory Agencies. Uccer Managemer and appropriate Safety Review Committee Chairman. You are requested to furnish writte-acknowledgement of the receipt of this notification. Please provide copy of completed evaluatie-report to Manager, QA Program Development & Audit for placement.n the audit file.
i O For your information.
O The attached audit finding is forwarded for resolution of the identified nonconformances O Other/ Additional:
CC:
( ) Director, QA
( ) Operations CA Manager
( ) Manager, CA Design and Procurement
( ) Site Audit Manager f
( ) QA Manufactunng Assurance Manager
( ) Others
( ) Man 6ger, QA Modifications / Operations t
J l
t Receipt Acknowledgment Recuired Yes C No C If receipt acknowledgment is required, sign the following statement and return this form to the Methods /Pr:grar Audit Manager.
From:
t The receiot of Audit Finding No, is hereoy acknowledged.
i Signed:
Date:
[
(
i i
ACCCCf 6010
_,, - ~ _ _ _ _ _....__. _.. - _ _ _ _. _ _ _.. - -.
Page 2 -
f Guidance for the Determination of Potential Reportability.
1.
Introduction The QA Program Development & Audit Section has the responsibility to perform the preliminary evaluation to determine the potential reportability, under the terms of Parts 20. 21, 50 and 71 and Regulatory Guice 1.16. of nonconformances and deficiencies identified in audit findings. This preliminary evaluation is not a technical engineering evaluation the intent is to assure that potentially reportable occurrences are crougr.t to the attention of responsible organizations and management in a timely manner.
Th1information given below is intended to provide guidance in the performance of this preliminary CA evaluat:c' References are provided to assist the evaluator in making determinations it' difficult cases.
2.
Part 20. Notification of Incidents
Reference:
Part 20.403 Net Yes No Acc:
a.
Did the incident involve by-product, source or special nuclear materiai and O
O C
b.
Did the incident cause or threaten to cause either:
O O
C (i) exposure to an individualin excess of:
whole body 5 Rem.
O O
C skin of the whole body 30 Rem.
O O
C feet ankles, hands or forearms 75 Rem O
O C
(ii) release of raoloactive material greater than 500 x the limits given in 10CFR20. Appen-dix B. Taole 11.
O O
C (iii) los.s of operation of a facility for more than 1 day O
O C
(iv) damage in excess of $ 2,000.
O O
C If the answer to a and any part of b is YES, the finding is to be evaluated POTENTIALLY REPORTABLE.
NOTE: These incidents are reportable to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in accordance with 10CFR50.72.
3.
Part 21. Reporting of Defects and Noncompliances
References:
Part 21 Defect as defined in 10CFR21.3 i
AC000!f04 1 C-t' t
Page 3 cf i Guidance for the Determination of Potential Reportability Quality Classification List (QCL)
Regulatory Guide 1.29, Seismic Design Classification -
A material nonconformance or quality deficiency, to be potentially reportable under the terr"s of Part 21. must :
either:
a defect in a "Basic Component" which could create a substantial safety hazard (radiological safety).
a noncompliance in design, inspection, testing or consulting services associated with a Basic Component and relating to substantial safety hazards.
A Basic Component may be a componertt, structure, system or a part thereof. See 10CFR21.3 (a) for cefinitic-The following checklist is provided to assist in the QA evaluation of Potential Recortability.
Net Yes No Ac; a.
Determination of "Basic Com* :,ent" ti)
Does the Purchase Order specify 10CFR21 applicacility ?
O O
C (ii) is the item a part of a system in the QCL?
O O
C j_
(iii) is the item part of a structure, system or component classified Seismic Category I (Reguatory Guide 1.29)?
O O
C
[
b.
Determination of Resconsibility to Report.
O O
[
(1)
Has the Basic Component been delivered and accepted?
O O
C (iil is the Basic Component installed or in use?
O O
C (iii) is the Basic Component part of a facility of-fered for acceptance?
O O
C (iv)
If commercial grade, has a dedicated safety-related end use been specified?
O O
C j
(v)
If a security defect or noncompliance, is it contnbutary to a significant safety hazard?
l (e.g. could a saboteur have gained access to any Basic Component?)
O O
C (vi)
If a noncompliance in design, insoection, testing or consulting services, could the non-compliance affect the function or reliaoility of the associated basic component?
O O
C if the mswer to any one cuestion listed under a, and any one cuestion under b,is yES, the finding is to te
[
evalus i POTENTIALLY REPORTABLE.
A00Co6608 Ic41
L Pageaofi Guidance for the Determination of Potential Reportability 4.
Part 50. Domestic Ucensing of Production and Utilization Facilities.
Note: These events are reportable to the NRC within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />
Reference:
Part 50.72 (Attachment to IE inferraation Notice No. 80-06),
a.
Is the significant event listed below?
Yes No (i)
Any event recuiring initiation of the licensee's emergency plan or any sec-tion of that plan.
C C
(ii)
The exceeding of any Technical Specification Safety Umit.
O C
(iii)
Any event that results in the nuclear pcwer plant not being in a controlled or expected conditior, while operating or shut down.
O C
(iv)
Any act that threatets the safety of the nuclear power plan: or site per.
sonnel, or the security of special nuclear material, including instances of sabotage or attempted sabotage, O
C (v)
Any event recuiring initiation of shutdown of the nue'est power plant in accordance with Technical Specifiestion Umiting Concitions for Opera-tion.
C C
(vi)
Personnel error or procedural inadecuacy which, during normal opera.
e tions, anticipated operational occurrences, or accident conditions, preven's or could prevent, by itself, the fulfillment of the safety function of those structures, systems, and components important to safety that are needed to (1) shut down the reactor safely and maintain it in a safe shutdown condition, or (ii) remove resicual heat following reactor shut-down, or (iii) limit the release of radioactive material to acceptable levels or reduce the potential for such release.
O C
(vii) Any event resulting in manual or automatic actuation of Engineered Safe-ty Features, including the Reactor Protection System.
O C
(viii) Any accidental, unplanned, or uncontrolled radioactive release. (Normal or expected releases from maintenance or other operational act:vities are not included.)
C C
(ix)
Any fatality or serioue injury occurring on site and requiring transport to an offsite medical facility for treatment.
C C
(x)
Any serious personnel radioactive contamination recuiring extensive on-site decontamination or outside assistance.
O C
(xi)
Any event meeting the criteria of 10CFR 20.403 for notification.
O C
(xii) Strikes of operating employees or security guards, or honoring of picket lines by these employees.
C
[
7 if the answer to any one cuestion listed under a. above is YES, the finding is to be evaluated POTENTIALL I
REPORTABLE.
i AoCooS60 C i
1,> t l j
l
- cL r
s.,
Page5c' 1
Guidance for the Determination of Potential Reportability c
5.
Part 71. Packaging of Radioactive Material for Transport.
Reference:
Part 71.61.
Yes No a.
Does the nonconformance or deficiency involve a substantial reduction in the effectiveness of an in use authorized osckage? -
C O
i If the answer to question a. above is YES, the ocu.r-rence is POTENTIALLY REPORTA8LE.
6.
Uconsing Event Reportu.
a.
Does the finding identi+y a condition in violation of section 6.9 of the Technical Soecification?
Yus No Acc Twenty four hour recorting:
(i)
Failure of the reactor protection system or other systems sub.
ject to limiting safety system settings to initiate the recuired protective function by the time a monitored parameter l
roacies the setcoint specified as the limiting sefety system setting in the tecnnical specif; cations or failure to complete the recuired protective function.
Z C
Z f
tii)
Operation of the unit er a ected - systems wnen any parameter or operation subject.o a limiting condition is less conservative than the ; east conservative ascect of the limiting cencition for oceration estactishec in the technical specifica-e tions.
(iiil Abnormal degradation discovered in fuel cladcing, reactor coolant, cressure bouncary. or primary containment.
Z
~
(iv)
Reactivity anomalies involving disagreement with the
[
l predicted value of reactivity balance under steady state con.
I ditions during cower coeration greater than or ecual to 1% k/k; a calculated reactivity balance indicating a chut-down margin less conservative than specified in the technical scocifications; short term reactivity increases that corres-pond to a reactor period of less than 5 seconds or, if sub-critical, an unplantied reactivity insertion of more than 0.5%
~
k/k; or occurrence of any unplanned criticality.
Z (v)
Failure or malfunction of or e or more components which prevents or could prevent. cy itself, the fulfillment of the functional requirements of system (s) used to cooe with ac-l cidentt. analyzed in the FSAR.
Z Z
Z i
(vil
- ersonnel error or procedural inadecuacy which prevents or j
could crevent. by itself. the fulfillment of the functional re-I quirements of systemt, recuired to cope witn ace: cents analyzed in the FSAR.
l l
(viil CorMitions arising from natural c man mace events that, as a direct result of tne event recuire plant shutcown. operation of safety systems or other protective measures required by tee.nnical specifications.
Acc0c s(c p s o.g
- 4
u Page 6 of 6 Guidance for the Determination of Potential Reportability Not (viii) Errors discovered in the transient or accident analyses or in Yes No Appl.
the methods used for sucn analyses as described in the FSAR or in the bases for the Tecnnical Soecifications that have or could have perrcted reactor oceration in a manner less con-servative than assumed in the safety analyses.
C C
C (ix)
Performance of structures, systems, or components that re-quires remedial action or corrective measures to prevent operation in a manner less censervative than assumed in the accident analyses in the FSAR or Technical Specifications bases; or discovery during plant life of conditions not specifically considered in the FSAR or Technical Soecifica-tions that require remedial action or corrective measures to prevent the existence or development of an unsafe condition.
C C
C b.
Thirty Day Written Reports:
(i)
Reactor protection system or engineered safety ' feature in-strument settings wnich are found to be less conservative than those established by the technical specifications but whien do not prevent the fulfillment of the functional re-quirements of affected systems.
C C
C tii)
Concitions leading to operation in a degraced mode permitted by a limiting condition for operation or plant shutoown re-y quired by a limiting condition for operation.
C C
C fili)
Observed inadecuacies in the implementation of ad-ministrative or procedural controls which threaten to cause reduction of degree of recandancy provided in reactor protec-tion systems or engineereo safety feature systems.
C C
C tiv)
Abnormal degradation of systems other tnan thoce specified in item 6.9.2.At3) above designed to contain radioactive matenal resulting from the fission process.
C C
C If the answer to any one cuestion listed under a and any one question under b, is YES. the fincing is to ce evaluatec POTENTIALLY REPORTABLE.
i l
AcoCc56o E ic-61
PAOCEDURE NO Pmuml Nucloer t
e l ORIG. ISSJE DATE: 3/1/g1 f
TECHNICAL FUNCTIONS DIVISION PAGE1 OF ic TITLE REGULATORY CORRESPONDESCE MANAGEMENT AND CO.P.ITMENT CONTROL l
PREPARED BY-REVISION DATE OESCRIPTION PREP AR ATION.
, AUTHORIZ ATION APSAOVAL il7',
1 3/1/82 Revised to replace " I n t e rir."
g//
procedure.
i i
i i
l I
I l
l i
l l
f l
l I
i i
l l
Fol n - S7 -V16 kY l
PREC AR ATION AUTHC Rt2 ATION
( IPROVAL
].
0
&& 1l?$fu
- h.bi ls--
2h.%
a'i R E5 5 0 '. S i E.1 OA~i
\\':i
- FES.Di's' Oa'i SSCCE* LSI 5 e
STAN0 AROS MGF DE S AFTVE',T Dic Ti;- FUNCTIONS e.;;;t't t
$ t' N 0
(
zh
-?
/
j ggm 7 TECHNICAL FUNCTIONS REV. NO TROLDURE NO.
DIVISION 1
Lp.002 TITLE Regulatory Correspondence DATE OF REV.
Managegent and Commitment Control 3/01/82 PAGE 2
OF 18 l
1.0 PURPOSE & SCOPE Tnis procedure defines and establithes the GPUN system for the management of inco.ning and cutgoing regulatory correspondence and the assignment of tasks associated with that correspondence.
Control and docamentation of commitments made to regulatory agencies in out-going correspondence is provided via a task manage-ment reporting system.
The procedure pertains to intradivisional contributions to responses made to regulatory agencies.
Tnis procedare shall become effective April 1, 1982.
NOTE:
Generic correspondence, including those items tnat GPUN intends ta comment on, will oe handled by LP-006.
2.0 REFIRENCES EMP-012 "Task Requests" LP-008 "Gener ic Regulatory Cor r espondence Kanagement" 3.0 DEFINITIONS 3.1 GENERIC REGULATORY CORRESPONDENCE Includes NLRIG 's (cr otner documents which provide guidance on rules and/or j
regulations), new regulatory guides, new ra'es, and any documents from a regulatory agency which regaire l
comments.
3.2 Refer to "Glossary of Terms" used in Technical Func-tions Procedures.
l 4.0 REQUIREMENTS I
4.1 Licensing is the corporate recipient of GPUN regala-tory _coIJespondence, an_d tne resteetive Licensin_g S J pe ry.1.s or _f 0.r _Aach.un: t.shallJt_34.e_dgji 11rd L ;i recipient of suen correspondence _for that unit.
Tne date tna; correspondence is received by Licensing is tne official start time for any time constraints
(
imposed on a response to tnat correspondence.
4.1.1 Oatgoing regalatory correspondence, ooth routine
,r e, _o r t,s,, montn,1y re grts, eYc.),and reports ( a n n u.a.'
p nor. r o a : I ne_r epo t t s,,( r epo r ta ole oc c J r r e n c e.s_,, _re,sponses to oJlletins, nor, compliance r epor ts, cirCJlars, etc.)
so:c:t s
TECHNICAL FUNCTIONS REV.NO CROCEDURE NC j g g'--;
DIVIStON 1
Lp.002 Regulatory Correspondence and Commitment Contro! }lDATE OF REv.
TiTtt 3/01/82 PAGE 3 OF 18 Management i
will be directed __to the a,Epropri W h i_,0..L1Cer1 Sing J
Supervis g for f i n a l appr.ov a l _ a n d_f o r ma l_, s_u bm i t t a l.
4.1.2 Anyone who receives an original copy of regulatory correspondence directly from a regulatory agency which does not indicate that the Licensing Department was included on distribution must immediately send a copy directly to the appropriate Unit Licensing Supervisor.
Generic regulatory correspondence should be sent directly to the Manager, Generic and Regulatory Affairs for processing.
This correspondence is not to be sent via the Engi-neering Data & Configuration Control (ED&CC) section or the Document Distribution Control Center ( DDO C ).
4.1.3 For each piece of correspondence, Licensing is respon-sicle to determine the consecuences of noncompf fahce' or late compliance.
Wnen it becomes apparent that tne required action will not be completed by tne due date, the Unit Vice president must be notified.
Licensinc is responsible to see that the work is_ completed cv tne_re:;ested due dAls.
If timely submittal is not possiole, Licensing will inform the requesting agency of the date when tne requested information will be available.
4.1.4 For eacn piece of incomino recul,ately correspond,Lnce, the[ Unit Licensing Supervisor]will assign action as a p e r'o pr i a t e, r e p r o d u c eW:uit.e nTs _ a s r e,q u i r e d,' aftM.
dis tr ibution_ slip and dir ectly_ dis tr ibute one copy,,to.
tne appropriate Section Manager (s) using the Action Item (Al) form 3eserIbec in Apoenclx'C' tin e section
~
l Kanager4 is responsible for distriouting the document witnin nis section and obtaining the necessary t e _e n -
l nical inputs from interfacino sections prlor.t.o I
respondingito_ Licensing.
Responsibility f or budget allocations, contracts, etc., rests with tne Section Manager assigned.
The informational distribution shall be made as indicated by the Unit Licen71ng Section on tne Distribution Slip (see Appendix 6;.
I 4.1.5 Action Item responses tnat impose follow-up commitment on otner sections shall ce concurred witn tne affected iTe~c t iokir lor to tne action item being returned,to Licensing.
' or nas designee a0::: m 1
1 i
TITLE Regulatory CorrospondGnce DATE OF REV.
Management and Commitment Control 3/1/82 PAGE 4
OF 18
~
g 4.1.6 If tne Section Manager e.ssioned to the Action Item is unacle to complete the task ey tne assigned date, he shall notify Licensing immediately.
4.1.7 If the recipient Section Manager of an Action It<.n (AI) believes that an inappropriate assignment ras been made, he shall contact the Unit Licensing Supervisor immediately.
4.1.8 A completed AI includes all of the following:
Tne assigned section has developed a full response or taken all of tne action required to fulfill the commitment or requirement.
Tne AI response has received all necessary technical comments from interfacing sections in accordance with 4.1.4 above.
1 Any comrents resulting from reviews nave ceen havell in-corporated into tne response to Licensing or been resolved.
4.1.9 Licensing i s r e_s po n s ib l e f o r,, oo t a,1,n i n e final _ approvals on c.:tgoirtg reculatory co rns po n es;Lc.e_. __T;a s_ w ill c e ace:mplisned oy octaining r e:;u i r e d,s ic,_na t u r e s or t n e_
corresponcence checksheet snown in Appenclx E.
Intercivisional~ disagreements arising cuTinf final approvals will be resolv_e_d oy_ Licensing.
4.1.1 For environmental licensing correspondence wnlen pertains to botn units, Licensing is responsicle to sucmit copies Si reports and correspondence te cotn units' Operat ans Department with the approprtate Licensing Correspondence Cheexsheet for final letter approval signatura.
Upon review and approval cy Unit-2 Opera tions, the package will be forwarded to tne Unit-2 Vice President or Acting Director for review and concurrence.
The Unit-2 Vice President or Acting Director will sign and date tne enecksneet indicating nas concurrence.
Tnis package will tnen be r eturned tc Licensing.
Licensing will then transmit tne eneessneet bea:Ing tne approval and concurrence signatures of Unit-2 to the Vice Presicent of Unit-1 fer inclusion witn tne review package previously su:citted to Unit-1 Operations.
The two Licensing Correspondence Cnecksneets will then bear tne I
ixer e.
-;.~..
~
- - - - ~.
lLc.IdNucimr EMMNCMS QV NO MOCED NO 1
TIT 5 Regulatory Correspondence DATE OF REV Management and Commitment Control 3/01/82 PAGE 5
OF 1B signatures for final letter approvals of Licensing, Technical functions (if appropriate), both Units Operations Departments, other Departments as ap-propriate and the Unit-2 Vice President or Acting Director.
Upon receipt of the correspondence package with both Checksheets the Unit-1 Vice President may sign the correspondence and return the package to Licensing for suomittal.
For environmental licensing correspondence clearly relevant to a single unit the review and approval need only be obtained from :nat Unit's Operations department prior to obta gng tnat Unit's Vice President's or Acting Director's signatare.
4.1.11 It commitments are made in response to a regulatcry agency, follow-up Als will be initiated for eacn of i
i these commitments by Licensing.
Applicable sections of tne basic documentation wnlen inittsted the commit-ment and/or original document which articulates tne regulatory agency's request shall be attached or
. referenced in the AI.
Implementation and revies of i
i these follow-up Als will follow the same procedares as' l normal AIs.
If the activity covered by the follow-up AI is controlled by the Pro]ects Department, tne folles-up AI will only cover the licensing items l
involved.
Control of the item, inclading schedaling i
and expediting will be tne responsibility of tne Pro]ects Gerart. tent.
l 4.1.12 A trac <ing s/ stem status report will be sent monthly to all applicaele Department Managers (DM) as informa-tion.
Tnt status report (Appendi x D) will list Als assigned in chronological order of due date by depart-ments.
Each recipient should review the statas report-to ensure adequate actions are being taken witnin enel: departments to complete overdue or near-term ji stems.
A summary statur report will also be dis-I tricated to upper management monthly.
i 4.1.13 An Action Item is closed oat by the Uiit~~
~
Licensing Sapervisor wnen in his ]adgement tne avalloble documentaticn indicates tnat the action is complete.
4 I
(
4.2 Imolementation (Refer to Procedure Flow Cnart, i
Appenclx At 4.2.1 LICENSING Logs incoming regJlatory Correspondence I
SUPERVISOR Reviews correspondence for applicability to the (LS; nuclear facility k h l
l l
l
tm.vINualcar
[35"s@M NNCMS W NO AOCED EN0 1
,_9 2
itTLE Rega10 tory Corrosponconco DATE OF rE V Management and Commitment Control 3/01/82 PAGE 6
OF 16
~
Determines if an AI is necessary: if so, assigns AI Annotates letters giving reasons for not assign-ing Als Forwards document and annotated Distribution List to DDC0 for filing ano distribetion Enters AI information (i.e., tas< assignment, commitment date, response date) into the tracking system Issues tracxing system status report of oatstand-ing AIs Follows up on outstanding AIs 4.2.2 SECTION Conducts work required by AI KANAGER Octains the necessary internal technical reviews, (SM) interfacing section reviews of assigned Als Resolves comments from reviews and incorporates into the response to Licensing Forwards the completed Als and sJpporting docu-ments to Licensing Assares tnat the cover letter for the response to the regulatory agency is drafted, if specified 4,2.3 LICESSISS Reviews completed Als to see tnat response is SUPERVISOR acceptacle (LS; Assure pr oper filing of comp}eted Als, support-ing docament, draft correspondance, anc annotated districation slips Updates trac <ing systec Finalizes draft suosittals as appropr iate Obtains final approvals as required by Appendices j
F&G, using the Correspondence Chec<sneet shown in Appendix E l
Resolves Management's comments I
rrereres a fermal response for the Unit VI:e-Presiden*.'s signature I
i AC ;t:5 I
l l
TECHNICAL FUNCTIONS GEV.NO PROCEDUKE NC.
h@~nr DIVISION J
1 Lp.co2 itTLE Regulatory Corresponcence OATEO8REv.
Management and Commitment Control 3/01/82 PAGE 7
Op 16 Prepares a distribution slip (refer to Appendix B) for the signed document Issues as new Als for commitments generated from approved responses Assures proper distribution and filing of copies 5.0 APPENDICES A.
Procedure Flow Chart B.
Distribution Slips C.
Licensing Action Item Form and Instructions D.
Tracking System Status Report and Instructions E.
Licensing Correspondence Checksheet and Instructions F.
Letters not Aequiring Technical Functions' Aeview G.
Technical Functions Level of Approval Autnority l
I l
i l
i A;r :t'i i
TECHNICAL FUNCTIONS REV.NO.
PROCEDU;E NO..
l NuaL~,u,r DivistoN 1
tv-oo2 i
10 ATE OF REV.
TITLE Regulatory Correspondence Manacement and Commit-ent Control 3/1/82 8
18 i
c 4
1 A
w#
t-t:
r a w =.
m m
I
't mgr4 Il" k
6 Ig;e, 2
<u we z
it H x u
.4
- fr-M r 'g 'e<-
ll e-e
..=t aue e
"uge
~6 a
E3 Iv i
g-l 2:!
c:
2-e$:e (I-
>w
- wwm J L
.- s a
n
- 6.,? z -
l a E4 -
M-5 w
3 y e,
- r. < a gwwc
- $?
E..z[f,
- - w.
- 6. - x r-.
e
- v. - r p.-
e ce
<'re
.>gm
- > 1 :,.
g2'v s
av<
w.
ezwe-5-;
3-
<===
ez--
I l
2.24 a i-m
- v. e - t -
FP' g
z-z m'
-. *= = s w
a v. - a,
v.
=
vw va
. i ii i m. v.
a-3 v:
- r c'
m 5w 5-r s*C r 3 ~"
U g.
- v. r e av.
J k x
2 E
- c C,
4 w e A
t t
r *h.C n.
au g
.a Oa L
W 6-e A
c e'*
l-
- v. w C 5 4
. ca5
->v-
- a c-as M
<=-a h
i t, "
rs
!m p *t ic&.
b'
- -v i
r s
[ c gcl A
y i
/
?
v
~
e 7
b c
r w
E-
=
ew w n
e c.
6; <
E5 2_:
a
.t v w a
v
- v.
- c..a 5
-c JL i
- l i
g>
/\\
-E i
si E
aa c
e
.s;wi.
vy yE>
4) st;*
-Ei a
I ft4
> l
>a e
1*
v:
a I;
l pw.s a
~E
.ll 'y c%)h.i
{
i t L E..
l a--.
=PC4 3
>a2-C y12 2
a s
c.-
AhO*J $'h 1
ENuclear EC"$" "S "'"f -
"TRssyo:
t DATE OF REV.
TITLE negulat'ory Correspondence f
Wanagement and Com.9itment Control 3/1/62 PAGE g op yg i
w aL
?
u s w o. E ::
FCs As I.
saw s
g c
mcgn ws ed
<6 na I.
u
-k c-.
-uz.F*
.
==
aea e E Ed tSA EEEE_
a l
JL A :.
U
.n. :A 2
'd 4
L' '-i it g a u
=*
e s v. e c.
p.6 1
4
- a. 5 :
-5:
. v. -
w e:a
- v l
m I
t i
e.
.a i
e e
e s
- w w w
- =
- =
s a v: u rwc?
e ge rt ra c v.
5 M w <z e =
c>
5
- E.
6 c
e-7 e-r 2
s a
e a r 2,.
e*E" c
-c av c
I.
a
<C
<aca O
c
=
=
N/iN/
i i,
y Ak Al I.
ik I.
CU:
7 r-
^
x c
tu v.
.5; W
-?*
4 I
e:Ec c;
c a > s. c 4
I I. ~
N i *,,
r-,
i i
P Ed AL t.
> ec
=mL*-
z
. e e <n e g
ee
- 5.. E
- m. ;
= = :.
- c. c awe e z -.-
z u=
-zca:
ea E. E'c. -
-E P
- s. a r
s.
we -:
tEi e
L' en ea l
l 4
4 I i i
rL' JW:
1
- v. -
_E r
ae I
<t-g =Z.i. -
g 7
r w
r '.: 5 k
x: a was
- 1
/
i H..!y 1
v e
i
,C.
E S d
)
& O. s 6 a $
=J u
g G&m-$*
3
. *$ F. ( U
(
w E
d g s z %.* W e
y a
- EFG a
-*.3-c n
c g
ey=
E =s a 4
4 A Z.
5'-
gp*q TECHNICAL FUNCTIONS GEV NO PROCE0ccENO j
DIVISION 1
Lp.002 T m.E Regulat,ory Correspondence DATE OF AEv.
Management and Commitment Control 3/1/82 PAGE 10 05 18 APPENDIX E Distribution Slips are subject to continual change; Site Li-censing Supervisor should be contacted for the most current Distribution Slip.
A0710h !*t-eisnian:a t C
O etsm Cun tx:-1 c#
$dject:
1 Aa.npes to:
t.e case-t:s n:::r.:s
}C A ! ::sn t r.i::s
!C I I
A
-FAA51PFArt-
- hilt P.;;.1 11'.A.'C -
P. E. C;sts AC
- t. C. Arnolt - Adnan.
- t. E. Croteberger - b;
- 3. tallar<
tr1. 255
- 1. V. newarc - M J
J. Colsts - Trl 164 b.
C. 12 : a r.a s - M J C. ke r h e ar - T r l. 118 E. V. Eester - C1 1
- 1. L aii; - Tr;. 16-J. ta. bel Ch L. A. Late! - trateteg
- 1. K. Lacey - Ch P. helser a 'rl. 145 T. F. Mar.garare - it; R tes: - Serv. Ilsg.
i V. T. $thaa.as - CF
- 1. Toole - Sen list.
C. C 5; ear - C1 J. Waiser - Aasta.
J. L. Therpe - C)
I f, DX:
- TMI l E. C. ballete Ch i
F. beir,ttm er
- CF a
E.
T. h t l e e r. - CV
{
I:400 -D
-C Y!!!I CIlt t -
-C M 13-J t carrel; E.C.E. Facattaaet l
j P. Taes;er l
E. Crow-ei i
(
J F. Kaioney J
L. $4:avar.
C. Traces 20; - C* ster Creen
(
f
'l I
I w'
e I
TECHNICAL FUNCTIONS REV.NO.
PROCEDURE NO.;
g p*o p j
DIVISION 1
LP-002 v
TITLE Regulatory Correspondence DATE05PEv.
Manacement and Committnent Control 3/1/82 PAGE 11 OF 18 APPENDIX C LICENSING ACTION ITEM b
Reterr. to Lice. sang P:. ANT NAw.I OI 1:n ediately af unable t: cc: ple te as sign-ments.
A: N; w.E I F i Als:0NIO CIP!. 4 OATE OT M:
I 0;I ;ATI KITERINCE DESOK:TT :S OF A55:0Nw.IN* W apt eval L 0LN5;h!, CONTA07
- 7. E0
- N::
L:0EN! NT, $*.'TERV:$07 8
l L INS!b; 5 '.' 71 E. ; i ; ;
AtT:0N 7Iw RISPONS E L:7)
O PR;mR SE:0h;AFI l
l l'A07I27 cts!*:PT!ON of e0 writ?r: A C ! 0'.
l CO"d*EII Ati; IN;;.;;.A.
15 ':5? OT ATTAD.wrNT!
l
- . REY:EA 6
h
^#***
ALs1 E A.it;; hLA: -
O ej (KIEF YELLOW COTY CT A:n h
. PC/:rWI 6 i
,,gg3 l
An K: <t:
F6k
( 8 t ')
(
k6A
- 06) _
i pgA
(,t' w
AOhh k h l
l t
l
TECHNICAL FUNCTIONS REV. NO PROCEDURINO.
gp'^y j
DIVISION 1
LP-002 TITLE Regulatory Correspondence OATE OF REv.
Management and Commitment Control 3/01/82 PAGE 12 QF 16 f
APPENDIX C - contd.
LICENSING ACTION ITEM COMPLETION INSTRUCTIONS 1.
If assignment is not accepted or if due date cannot be met return AI immediately to Licensing 2.
Each AI is assigned a unique number by Licensing 3.
Enter department /section assigned the AI 4.
Enter date AI is written.
Example 012181 5.
Enter doe date wnen AI is to be completed by responsiole manager and returned to Licensing.
Example:
022451 6.
Enter plant name 7.
Use this space to reference pertinent documents 6.
Enter complete yet concise description of work to be done 9.
Licensing SJpervisor signs here, approving action re:alred as assignments 10.
Licensing Engineer assigned to manage AI completion 11.
" P F.I MA RY " means tne name of manager / supervisor assigned to tas<, "SECONDARY" means the name of tne sabordinate individaal completing ne assignment, if Rnown 12.
Signature of individual assigned work responsibility wnen action is complete 13.
Signature of s a' ' ion manager signifying review and approval l
14.
te Signatore of other applicable department managers sig-17.
nifying peer revies and approval.
l 16.
Enter a description of completed action, or a list of i
attachments wnlen describe completed actions.
(
Note:
This appendix snows a r epr es en ta t ive form, use of a tecnnically eqJ1 valent form is acceptable.
m :: m
TECHNICAL FUNCTIONS REV.NO P;iOCEDUAE No..
y gn,g g DIVISION 1
.:m o
TITLE nogulatory Corrosponcence DATE OF GEV.
Management and Commitment Cont,ol 3/1/82 PAGE 13 OF 18 I
APPENDIX D RICOM.VINDED TRACKING SYSTEM STATUS REPDRT
, FORMAT r w.-
x:
c'er D;t A: Rrs7
.rr/ts:
A:
s;
- rP:
ers:E:r:::s DAir cActs PR:x/st:
ur
- .:s t:.7 C C C
C C
b C
C TTe: KING SYSTEM STATUS REPORT EXF:,ANATION 1.
Tne AI numoet assigned to eacn piece of regulatory correspondence 2.
Responsicle manager's department l
3.
Tnis description of action is taken directly f ro
- ne AI l
form 4.
Date worm is to ce completed to De returned to Licensing 5.
For each AI, a compilation of past due dates incica:Ing I
tne extent to wnlen tne AI is overdue l
l 6.
PRIM (Primary) indicates the name of manager / supervisor assigned to task.
SEC (Secondary) inoicates tne nare of I
tne suoordinate individual completing :ne ass ignmen:,
7.
References to licensing and/or engineering doeurents wnicn w111 facilitate completion of the A:
6.
Date response is sent to agency. or internally closed and letter / memo reference l
SOTE:
Tne format of tne Status Repor t may e varied oy tne l
Unit Licensing Supervisor, nowever, tne informati:.-
l listed in columns 1 tnrougn 8 must ce pr ovided, t
I Ac:::t u
TECHNICAL FUNCTIONS REV.NO.
P.70C E DU":E NO g
jg g gv,pp DIVISION 1
LP-002 w
TITLE Rogulotory Corrospondenco DATE OF REV Management and Commitment Control 3/1/82 PAGE 14 OF is
(
APPENDIX E LICENSING CORRESPONDENCE CHECKLIST LICENSING CORRESPONDENCE CHECKSHEET AGL?.0Y f Dt;t OA?r T ::.I N~.'w.3 I A )
..:- N Aw.I '
O l
l I
CD Ots:A:;;;;s or 5;6w.:
A; i
(' )
I O Air s:::::: 4 CHIOF OT:
C COM.M: MINT! P'.ADE TO PE*.M*0PY AGE:;0'.
O C F01.1,0W-UF ACTION l R* NTE0E0 h.
e aAh h k 4[
fh b
I l
CD i
l I
t l
l I
g r::,c t-th u n:.u s
- c:i
- . !!!N! !';0 :
i rd.4ACEI.
T:::! w t r * !!:" P ft!.* t!!! :
l cpru :r: :
i I
OTH!*
!;!**TY):
1
- !Htt :r;t!:rY:
A000;('l
TECHNICAL FUNCTIONS MiV.NO PROCEDunENC md DIVISION 1
Lp.co; TITLE Regulatory Correspondence DATE OF REV Management and Commitment Control 3/01/82 PAGE 15 OF 18 i
APPENDIX E - cont'd LICENSING CORRESPONDENCE CHECKSHEET COMPLETION INSTRUCTIONS ONLY LICENSING COMPLETES ITEMS 1 - 7 1.
Enter Licensing correspondence los number 2.
Enter appropriate plant name 3.
Enter the date when this response is due to the applica:le agency 4.
Provide a complete description of the attached submittal 5.
Enter the date on which the outgoing correspondence is signed 6.
Cne:< this box if:
Tne resposse contains com.T.itments to the regulatory agency A follow-up AI needs to be generated as a result of the response 7.
Enter tne names of the individuals who offered signifi-cant inpat/ review in the development of this response, and the date on whien that input was received B.
Enter any supplemental comments relating to the response here 9.
Approving authorities sign or intial where indicated ar.d date l
l l
l I
Note:
Tnis appendix snows a representative form; ase of a tecnnically equivalent form is acceptacle, a co::e n
TECHNICAL FUNCTIONS REV.NO.
P;;OCEDURE NO.
j g op J,q DIVISION 1
to-Sm2 DATE OF REY.
)
TITLE Rsgulctory Corresponcence Managecent and Commitment Control 3/1/82 PAGE 16 OF le
(
l.
APPENDIX F LETTERS NOT REOUIRING TECHNICAL FUNCTIONS' REVIEW l.
Mater ial Status Report (Form 742).
2.
Operator license medical exams 3.
Fire brigade Durning permit request 4.
Annual balance sneet 5.
Routine exposure data report 6.
Personnel exposure at termination of employment 7.
Personnel exposure and monitoring report 8.
Rebo'ses to financial question 9.
Operator license applications 10.
Annual ervironmentalopera: Ing report 11.
Biological Monitoring Repor ts 12.
Annual mercury report 13.
Se: 1 annual effluent re' ease report 14.
NPDES distnarge monitoring report (DMR) 15.
Well water diversion report 16.
Drinking water report 17.
Sludge disposal report li.
A r. u a '. statenent of source materials inventory 19.
Effluent monitoring report 20.
Effluent release report aoo::t >
1
TECHNICAL FUNCTIONS REV.NO.
??OCEDU?E NC.
Nooloer DIVISION 1
LP-M2 TITLE Regulatory Correspondence DATE OF REV.
Managem'nt and Commitment Control 3/1/82 PAGE 17 OF 18 e
(
APPENDIX F cont'd 21.
Changes made to the emergency plan implementing procedares without prior approval 22.
Copy of annual financial report 23.
Notifications of disa: 111ty of operator 24.
Cnanges to secu 2ty plan (pursuant to 10CTR50.54(p);
25.
Snipworm Monitor ing kepor ts t
I l
l A;" :t's I
l
-