ML20149H335
| ML20149H335 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/16/1994 |
| From: | Modes M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | J. J. Barton GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 9411220129 | |
| Download: ML20149H335 (2) | |
Text
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November 16, 1994
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Docket No. 50-219 Mr. John J. Barton Vice President and Director GPU Nuclear Corporation Oyster Creek Nuclear Generating Station P.O. Box 388 Forked River, New Jersey 08731
SUBJECT:
0YSTER CREEK NUCLEAR GENERATING STATION TECHNICAL SPECIFICATION CHANGE REQUEST NO. 215 ADDITIONAL INFORMATION As required by 10 CFR 50.54, a technical specification change was submitted to the NRC on May 20, 1994, involving:
(1) a new audit schedule performance review, and (2) a change in audit frequencies, along with pages inadvertently missing from an April 15, 1994, submittal. Although our review revealed a i
number of issues that constituted a reduction in commitments from the plan previously accepted by the NRC, as tabulated in Attachment 1, the operational plan quality plan, which applies equally to Three Mile Island Nuclear Station, continues to satisfy the requirements of 10 CFR 50,. Appendix B.
In the future, submittals should be more thoroughly evaluated to determins if a change constitutes a reduction in commitment previously approved by the NRC.
Please refer t-No. QA-94-16 in future correspondence.
Sincerely, Michael C. Modes, Chief Materials Section Division of Reactor Safety cc:
G. Busch, Manager, Site Licensing, Oyster Creek M. Laggart, Manager, Corporate Licensing Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PA0 (2)
NRC Resident Inspector State of New Jersey l
l 9411220129 941116 PDR ADOCK 0500 9
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November 16, 1994 Mr. John J. Barton 2
bcc:
Region I Docket Room (with concurrences)
W. Dean, OED0 A. Dromerick, NRR/PD 1-4 P. McKee, NRR/PD 1-4 M. Shannon, NRR/ILPB J. Rogge, DRP H. Kaplan, DRS V. Curley, DRS t
DOCUMENT NAME: A:0C520.TSC To receive a copy of this document, indicate in the box: "(T = Copy without attachment / enclosure "E" = Copy with attachment / enclosure
- N" = No
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copy OFFICE Rl/DRS l
RI/DRS,,
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l NAME Kaplan/dmg Modes _ \\\\AL/
DATE 11/04/94 11/')/94 11/
/94 11/
/94 11/
/94 0FFICIAL RECORD COPY
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4 GPU Nuclear Corporation Nuclear
- en:
88 Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:
C321-94-2074 May 20, 1994 U.S. Nuclear Regulatory Commission f
gh Attn:
Document Control Desk JUN - I PED
<r.
Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station L'
Docket No. 50-219 t' U FT
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d/
I Technical Specification Change Request (TSCR) No. 215 Additional Information
/5 / f/4 1
i The purpose of this correspondence is to provide you with the 10 CFR 50.54 analysis and revised OQA plan pages as detailed in the cover letter for TSCR 215.
These enclosures were inadvertently omitted from our original submittal dated 4
April 15, 1994.
If you should have any questions or require further information, please contact Brenda DeMerchant, Oyster Creek Licensing Engineer at (609) 971-4642.
VerytEfJ1vavoord ~
/
JanJ.Bafjon
' ice President & Director Oyster Creek JJB/BDEM:jc cc:
Admini'stratr', Region 1 Senior NRC Resident Inspector Oyster Creek NRC Project Manager TMI-1 3r. Project Manager Y
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GPU Nuclear Corporabon is a subsidiary of General Pubbc Utaties Corporation
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] Nuclear memorandum
- sody, 10CFR50.54 Review of Audit om:
March 4,1994 Related Changes S. N. Tiwari - Engineer Sr. I Morris Corp. Center rmm:
tmoom 6161-94-034 To:
M. W. Laggart - Mgr., Corporate Licensing A Technical Specification Change Request (TSCR) is being initiated to transfer the frequencies of audits from Plants' Technical Specifications to the GPU Nuclear's Operational Quality Assurance Plan (OQA Plan). The following verbiage changes in the OA Plan have been proposed to facilitate this transfer:
1.
10.2.4 The areas to be audited are listed in the Nuclear Units' Technical Specification. The frequency of internal audits is based on performance. These frequencies are listed in Appendix E to this Plan.
2.
APPENDIX 'C' The frequency of performance and minimal Reg. Guide 1.33, Section 1 topical coverage of internal audits wi" be consistent with Appendix E of this plan.
3.
APPENDIX 'C' The frequency of performance and minimal Reg. Guide 1.144, Section topical cov(rage of internal audits will be C.3.a(1)and C.3.a(2) consistent with Appendix E of this plan.
As apparent, the changes revolve around the proposed Appendix E. This appendix is attached as Attachment I to this letter. Attachment 2 provides the comparison between proposed and existing audit frequencies.
Anabsis of Chances and 50.54 Determination The key elements of this proposed change in OOA Plan constitute of the 2 distinct aspects of proposed Appendix E: one, the Audit Schedule Performance Review, and two, the changed audit frequencies.
l A numerical comparison of the existing frequencies prescribed in the Units' Technical l
Specifications with the proposed frequencies indicates that the frequencies for audits associated with Fire Protection program are not changed. Also not changed are the frequencies mandated by regulations, such as, those for Security Plan and Emergency Plan.
Frequencies of other audits have been proposed to be reduced.
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4
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10CFR50.54 Review of Audit Related Changes Page 2 If the premise of commitment is the numerical frequency of the audit (s), the proposed numerical reduction in audit frequencies constitute an apparent reduction in GPU Nuclear commitment. It should, however, be noted that this quantitative reduction does not compromise the quality of GPU Nuclear's oversight of its operations. In fact the proposed controls. such as the Audit Schedule Performance Review and the inclusion of Corrective Actions as an item in all audits. enhance the quality of the oversight.
The proposed Audit Schedule Performance Review is the annual review of the performance of the topical area (s) by a group of managers including appropriate plant or corporate management to decide if more frequent audits will be needed. To make this decision. this yearly review will consider such salient performance data as deficiencv trends.
indusfrv events. nonce of violations and licensee event reports. This important database and the conduct and frequency of this review focuses critically on the performance of the area audited and not merely on the prescriptive duration between two audits. This position a consistent with NRC's Regulatory Review Group's (RRG) Recommendations, which among other things. recommends a performance based and graded quality assurance, t Refer to the topical area titled 'Ouality Assurance ~ of the implementation Plan of SECY-u:.003 of Januars 7.1904 and associated RRG's recommendation 4.1.1 ). This yearly performance review combined with the inclusion of Corrective Action as an item for all aed:ts is a significant step towards enhancing the efficiency and quality of. oversight.
Ibed on the ahme analysis. it has been determined that the proposed change constitutes a recuction in commitment, although it improves the quality of oversight.
(
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NM S. N. Tiwa Extension 7433
References:
1.
10CFR50.54 2.
NRC SECY 4 -003. Januars 7.1944. Quality Assurance and associated RRG recommendation 4.1.1
1 Operational QA Plan Appendix E Maximum Freauency TMI Ref.
OC Ref.
Descriotion (See Note 1) 6.5.3.1 ( A) 6 5.3.1 ( A)
The conformance of unit operations to 24 Months provisions contained within the Technical Specifications and applicable license conditions.
6.5.3.1 (B) 6.5.3.1 (B)
The performance, training and qualifications 24 Months of the entire unit staff.
6.5.3.1 (C) 6.5.3.1 (C)
The verification of the nonconformances and 24 Months corrective actions program to be properly (See Note 2) implemented and documented as related to action taken to correct deficiencies occurring in unit equipment, structures, systems or methods of operation that affect nuclear safe ty.
6.5.3.1 (D) 6.5.3.1 (G) The performance of activities required by the 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.
I 6.5.3.1 (Ei f.5.3.1 (D) The Emergency Plan and implementing 12 Months (Reg.
procedures.
Reg'd. Frequency) 6.5.3.1 (F) 6.5.3.1 (E)
The Security Plan and implementing 12 Months (Reg.
procedures.
Reg'd. Frequency) 6.5.3.1 (G) 6.5.3.1 (F)
The Fire Protection Program and 24 Months implementing procedures 6.5.3.1 (H) 6.5.3.1(1)
The Offsite Dose Calculation Manual and 36 Months implementing procedures.
6.5.3.1 (1) 6.5.3.1 (J)
The Process Control Program and 24 Months i
implementing procedures for solidification of radioactive wastes.
L
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,c----
Operational QA Plan Appendix E Maximum Frecuency TMI Ref.
OC Ref.
Descriotion (See Note 1) 6.5.3.1 (J) 6.5.3.1 (H) The performance of activities required by the 24 Months I
Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977.
6.5.3.1 (K) 6.5.3.1 (K)
Any other area of unit operation considered As Requested appropriate by the IOSRG or the Office of the President-GPUN.
6.5.3.2 ( A) 6.5.3.2 (A)
An independent fire protection and loss 12 Months prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.
6.5.3.2 (B) 6.5.3.2(B)
An inspection and audit of the fire protection 36 Months and loss prevention program, by an outside qualified fire consultant.
Note 1:
All frequencies except for those at 36 months can be extended for an additional 25%
to allow for schedule flexibility. The 25% will not be used on two consecutive audits of the same area.
Note 2:
Corrective action will be a standard audit scope item for individual audits throughout the annual audit schedule.
Comparision of Existine and Proposed Audit Freauencies TMI OC Existine Proposed Frequency TechJnee, Tech. Snec Frequency (See Note 1)
- Ref, iter.
Descrintion 6.5.3.1 ( A) 6.5.3.1 ( A) The conformance of unit operations to 12 months 24 Months provisions contained within the Technical Specifications and applicable license conditions.
6.5.3.1 (B) 6.5.3.1 (B)
The performance, training and qualifications of 12 Months 24 Months the entire unit staff.
6.5.3.1 (C) 6.5.3.1 (C)
The verification of the nonconformances and 6 Months 24 Months corrective actions program to be properly (See Note 2) implemented and documented as related to action taken to correct deficiencies occurring in unit equipment, structures, systems or methods of operation that affect nuclear safety.
6.5.3.1 (D) 6.5.3.1 (G) The performance of activities required by the 24 Months 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.
6.5.3.1 (E) 6.5.3.1 (D) The Emergency Plan and implememing 12 months 12 Months (Reg. Rey'd.)
procedures.
6.5.3.1 (F) 6.5.3.1 (E)
The Security Plan and implementing 12 Months 12 Months (Reg. Req'd.)
procedures.
l 6.5.3.1 (G) 6.5.3.1 (F)
The Fire Protection Program and implementing 24 Months 24 Months l
procedures 6.5.3.1 (II) 6.5.3.1(I)
The Offsite Dose Calculation Manual and 24 Months 36 Months implementing procedures.
ff tQ tbl I
Comnarision of Existine and Proposed Audit Freouencies TMI OC Existing Pronosed Freauency Tech. Spec.
Tech. Snec Freauency (See Note 1)
Iter.
Iter.
1)escription 6.5.3.1(1) n.5.3.1 (J)
The Process Control Program and 24 Months 24 Months implementing procedures for solidification of radioactive wastes.
6.5.3.1 (J) 6.5.3.1 (II) The performance of activities required by the 12 Months 24 Months Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977.
6.5.3.1 (K) 6.5.3.1 (K)
Any other area of unit operation considered As As Requested appropriate by the IOSRG or the Office of the requested President-G PUN.
6.5.3.2 ( A) 6.5.3.2 (A)
An independent fire protection and loss 12 Months 12 Months prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.
6.5.3.2(B) 6.5.3.2 (B)
An inspection and audit of the fire protection 36 Months 36 Months and loss prevention program, by an outside qualified. fire consultant.
Note 1:
All frequencies except for those at 36 months can be extended for an additional 25% to allow for schedule l
flexibility. The 25% will not be used on two consecutive audits of the same area.
i Note 2:
Corrective action will be a standard audit scope item for individual audits throughout the annual audit schedule.
freq tb4
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GPUNC OPERATIONAL QUALITY Number Nucioar-ASSURANCE PtAN rOR THREE xItE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.Ol
Title:
GPUNC Operational Quality Assurance Plan for Three Revision No.
-Mile Island Unit 1 and Oyster Creek See Note Below.
Applicability / Scope This Plan Has GPUNC-Wide Applicability Responsible Office Except THI-2 6160 1
This Document is within QA Scope I YES NO Effective Date 6
Safety Reviews Required I YES NO See Note Below.
List of Effective Pages on Page 2.0 i
i l
l e
t i
NOTE:
The changes of this revision involve relocation of audit frequencies from Technical Specification to new Appendix E of this Plan.
A revision number and i
effectave date are not being provided for this revision pending NRC's approval of the said changes.
I Signature Concurring Organizational Element Date t
Originator Director, Quality Assurance
{
Concurred By Dir-Services i
Dir-Independent Safety Review Dir-Nuclear Assurance Dir-OCNGS I
Dir-THI Unit 1 Dir-Technical runctions l
n Approved By Office of the President 4/I
/
36eSL wPo 1.0
GPUNC OPERATIONAL QUA*.!!Y ASSURANCE Number
'J MUCIOCr PLAN FOR Tsarr xI:.E IS:.AND UNIT 1 AND OYSTER CREEK 10CO-P*N-7:0 0. ".
t e
Title:
Organization Revision No.
See Note o.. Po..
1,!ST OF EFFECTIVE PAGES Page Rev.
Page Rev.
Page Rev.
Page Rev.
No.
No.
No.
No.
No.
No.
No.
No.
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See Jean we 2.0
i CPUNC OPERATIONAL' QUALITY ASSURANCE Number hhLICh3SI PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK lOOO-PLN-72OO.01 I
Titles 10.0 Audits Revision No.
See Note on Pg.
1 1
c.
Procedure (s) for the scheduling, preparation, performance, reporting
)
of the results of audits, and distribution to appropriate levels of i
management.
d.
Periodic analysis wf audit results and the reporting of such results to appropriate levels of management.
Follow-up action to be taken based upon individual and collective e.
audit results.
10.2.4 The areas to be audited are listed in the Nuclear Units' Technical l
Specifications. The frequencies of internal audits are based on performance and are listed in Appendix E of this plan. Annual review of these frequencies shall be conducted.
This review shall examine the appropriateness of the prescribed audit frequency by considering performance factors such as deficiency trends, assessment results, etc.
and shall determine if more frequent audit is needed of the topical areats).
t I
1C.I.5 The frequency of conducting external audits of selected suppliers of techn: cal support, environmental monitoring, radwaste shipping, computer, radicanalyt: cal, and engineering services shall be scheduled once within the life of the activity or every three years depending on the duration of the contra::ual relationship.
1C.2.6 Each audit shall be led by a GPUN certified lead auditor.
Audit team members shall be utilized as required and will be classified as either aud:: ors or technical specialists, depending on their function on the aud:: team, t
IC.:.-
Those CPUN and external organizations providing items and/or conducting activ ::es within the scope of this Plan are subject to audit consistent with the requirements of this Plan.
1C.2.5 Aud::s shall be performed in accordance with pre-established written pro:edures er checklists.
The personnel utilized to perform on an audit sna;. no: have any responsibility for,the activity audited.
1C.2.9 Aud::s sha1; consist of reviews of approved documents and records and coservation(s) of selected activities in sufficient detail to determine i
the appropriateness of the documents for use. effectiveness of f
implementation' and the ef f ectiveness of actions taken to correct previous nonconformances:
10.0.10 Audited organizations shall provide sufficient support to assure the accuracy of :ne audt: results, review and response to audit _nonconform-ances, and effective resolutton/ prevention of deficiencies.
The corre:::ve a : ens requ; red to resolve adverse audit findings shall be oefened and implemented in a timely manner.
1C.0.1.
Aud:: find:ng nonconf:rmances shall be followed up in a timely manner.
Suen adverse aud : findings sha'.1 typically not be closed until the I
effect:ve :mplementation of correct ve action (s) is verified.
10.2.;;
Suff ::ent reecrds shall be generated and maintained to provide coeu.cntatien of aud:: system secpe of coverage, individual audit coverage i..e..
aud:: plans, enecklists, or equivalent), audit reports, lead aac.::: cer::f:ca :ons, followup and verification and results of periodic l'
ana;ys.s ci aud:: results.
3899L (;;/68 84.0
n GPUNC OPERATIONAL QUA* :TY ASSURANGE Number n
Nucbcr Pun rOR TnREE azi.E :SuNo UN:7 1 AND OYSTER CREEK 1000-P*N-7;;;."1 i
Title:
Appendices Revision No.
See Note On P.
APPENDIX C-PART ?
2.
Additions to existing plant systems w.'11 ee made to ne same code.
standard and technical requirements wnien were originally applied ::
the system to wnich the addition is to be made or more recent verstens of :nese codes, standards and technical requirements.
Tne add : ton wil. not degrade the safety of :ne system oeing added to.
2.
For new construction, the lates: applicable code wil. ce ut. :ed unless sucn uts1 1:ation would result in hardsnip or unusual caff:cu':y w::nou: provi g an equivalent level of safety.
NPC ceru'a :rv Gu:de 1.3C. Aucus: 1972 Oua;;t. Assurance pecurrements for the Installation, Inspection and Testine ef
- nstru erta::en an: I;ee rte Ecutoment GPUN snail :Omply with the Regulatory Position established in this Regulatory Guace in :nat QA programmatic / administrative requirements in:.uce: :nere:n sna11 apply to maintenance and modifica:Lon activ;;;es even tnougn such requirements were not in effect originally.
Tecnnical requirements associated with maintenance and modifications snall be the
- g nal ternntral requirements or better (e.g.,
code requirements, ateria; properties, aesign margins, manufacturing processes, and
.nspec:: n requirements).
Se::: ens i.: and 6.2 of ANSI N45.2.4 list tests wnich are : be conducted cur:ng ne construct on pnace.
In lieu of this. GPUN util;:es 1:s Engineer;ng and/or Maintenance organ;:ations to establisn :ne need for sper:f:0 tests or test procedures dur:ng the operattonal pnase.
NFC =acu.a:Orv C;;:e 2I tev.
2.
Februarv IC75 Ou a.
rsurarre Preira-Decu rements tocara Ori Tne GPUN QA Program complies with the regulatory post:lon of this guide
-: n :ne f llowing : arif::a : ens:
Reguia crv Pos ::en C.4 cf the regulatory guide Tne frequency f performance and minimal :cpical coverage of internal au s
w;..
ce consistent w :n Appendix E of this plan.
39C:*_
- ii 94.0
i CPUNC OPERATIONA*. QUAI. TY ASSURANCE ' Number ENuciaar PtAN POR TaREE artE 1stANo UNr..
AND OYSTER CREEK 1000-P"N-7:00. ;
o
Title:
Append:ces Revision No.
See Note en P=.
APPENDIX C - PART 2 4.
Hose may be used in lieu of rice where the connections are-temocrarv.
The ant:ripated applications of hose would -Ormally De (1) conner: ens te contractor owned skid mounted radioactive waste crocessino ecu;oment, (2) connections to a nonmounted, frecuentiv-nanced
- mOonert surn as a burial liner / HIC er (3) rennections :: nenmounted c:eces of radioactive waste processinc or : ;1ection ecutoment unten must ce read 1*.
removeable fe.c.
tems clared on ecuirment hatenesi.
Tne cressure ratine of surn hoses and connections snal. ecua; er exceed those cf :ne systemfs) or componentist to which thev are Onnected.
Prior to use, the hoses shall be hydronested to the apercoriate cressure for tne system or comoonent to wnten thev are connected.
After installation, thev are to receive recular hvdretestine er
- rserv;ee insoections.
A safe:. evalua: en is recuired to,ustifv the use of surn nose Terreet; ens.
NPC De:u'.a erv Gu;te. 144 Januarv 2979 Aue::; : Of Ou a ; ; ; *. Assurance Procrams for Nuclear Power Plants GPUN is an casic agreement with the position set forth :n the Regulatory Guace sucye:: :: :ne following comments:
Sert: ns C. 3. a '
'.1 and C.3.af2)
Tne frecuency cf performance and minimal topical coverage of internal auc :s w.. be consistent w;th Appendix E of this plan.
Se:::Or C.3.bt: 1.
Source surve:11ance will ce utilized in lieu of or
.n acca :on :: rece:p: :nspe:::en.
As perm;;ted, external audits of suen pr=:urement a:: ens w;..
- ypically not te scheduled.
3.
Sert:er C.3.br:s
^
External auc::s cf sele :e: suppiters of services which are within the s::pe cf nts P'.an w.. De seneculed and conducted at least once wnn :ne life of :ne activity er every three years.
Refer also to
- 0.:.5
=f
- nts p.an.
An a n..a a ; evaluation of suppliers of :: ems, parts, materials and services w;;l ce conductec.
These evaluations will be conducted u :1;;;ng :ne results of source surve;;1ance, source inspec: ton, rece:pt inspe ::cn and/cr aud::s: and, c:ner factors.
These eva;uations wa..
cetermine ne neec :o concuc-audits of suppliers of
- ems. parts er ma:ertals: cr. :n=rease tne frequency of conducting aud::s of supp;;ers cf serv ces.
3900*..;;/S2p 105.0
CPUNC OPERATIONAL QUALITY ASSURANCE Number MUCIOCr PLAN FOR THREE MILE ISLAND UNIT 1
~
AND OYSTER CREEK 1000-PLN-720C.Cl
Title:
Appendices Revision No.
See Note on Pc. 1 Appendix E Haximum Frecuency THI Ref.
OC Ref.
Description (See Note 1) 6.5.3.1 (A) 6.5.3.; (A)
The conformance of unit operations to 24 Montns provisions contained within the Technical Specifications and applicable license conditions.
6.5.2..
{3) 6.5.3.1 (B)
The performance, training and 24 Months qualifications of the entire unit staff.
6.E.2..
(C) 6.5.3.1 (C)
The verification of the nonconform-24 Months ances and corrective actions program (See Note 2) to be properly implemented and documented as related to action taken to correct deficiencies occurring in unit e qu ipme nt, structures, systems or methods of operation that affect nuclear safety.
6.5.2..
6.5.3..
(C)
The performance of activities 36 Months required by the Operational Quality Assurance Plan to meet the criteria of Appendix "B",
6.5....
.I.
6.5.3..
(Di The Emergency Plan and implementing 12 Months (Reg.
procedures.
Reg'd. Frequency) 6.i....
5.5.2..
(E)
The Security Plan and implementing 12 Months (Reg.
procedures.
Req'd. Frequency) 6.5.2..
O.
6.i.3..
(Fi The Fire Protection Program and 24 Months implementing procedures 6.5.2..
4M 6.5.2..
Tne Offsite Dose Calculation Manual 36 Months and implementing procedergs.
6.5.2..
.~,
6.i.2..
if, The Process control Program and 24 Months implementing precedures for solid;ficat;on of radioactive wastes.
l r
1 3900;..:/E8) 115.0
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