ML20151P993

Forwards Rev 2 to 1000-PLN-7200.01, Gpu Nuclear Corp Operational QA Plan for TMI-1 & Oyster Creek. Plan Will Be Revised to Reflect Planned Reorganization.Evaluation of Changes Associated W/Rev Also Encl

ML20151P993
Person / Time
Site:	Oyster Creek, 05000000, Crane
Issue date:	04/15/1988
From:	Roche M GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151P997	List: ML20151P993 ML20151Q005
References
9000-88-236, C311-88-2048, GL-83-28, NUDOCS 8804260299
Download: ML20151P993 (14)

Text

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+ 201-316 7000 TELEX 136-482 Writer's Direct Dial Number: (201) 316-7003 April 15, 1988 9000-88-236 C311-88-2048 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

Three Mile Island Nuclear Station Unit 1 (TMI-1) License No. DPR-50 (Docket No. 50-289) Oyster Creek Nuclear Generating Station License No. DPR-16 (Docket No. 50-219) GPUNC 00A Plan, Revision 2 In accordance with 10 CFR 50.54(a)(3), enclosed please find a complcte copy of the "GPUNC 0QA Plan for THI-l and Op ter Creek" (1000-PLN-7200.01), Revision 2. This revision contains changes in commitments in the QA Plan as previously accepted by the NRC. As delineated in Section 2.3.2.2 of the currently approved Plan, this revision shall be regarded by GPUNC as approved by the NRC upon receipt of a letter to that effect from the appropriate reviewing office or sixty days af ter this submittal to the NRC whichever comes first. This revision to this 0QA Plan will not be implemented until that time. The purpose of tnis revision is to improve the clarity of this 0QA Plan which should improve the corisistency of its implementation. This purpose is prin-cipally achieved by increasing the directness and the extent of the statement of the requirements; improving the consistency between the text of this 00A Plan and the Technical Specifications; and, by clarifying the GPUN response to Generic Letter 83-28. 4 The specific changes are described in the Document History Section and directly identified with margin bars in the text. The descriptions of the changes generally correlates to the margin bars. provides the characterization of the l nature of the change as either a reduction in prior commitment or not and the basis for that disposition or the justification of the acceptability of the reduction. 8804260299 880415 PDR ADOCK 05000219 ) P DCD g g GPU Nuclear Corporat.on is a subsd:ary of General Pubhc Utat>es Corporat.on

+ 4-NRC-9000-88-236 /C311-88-2048 page two It should be noted that a reorganization of GPUN is currently being planned. This reorganization will principally involve the combination of the Quality Assurance and the Training Departments into a new division. This organizational change will not have a material effect on this revision of the 0QA Plan. This Plan will be revised to be consistent with the change when implemented. This revised 0QA Plan continues to satisfy the criteria of 10 CFR 50, Appendix B, although there has been some reduction in the commitment previously accepted in some specific 00A Plan provisions. The principal basis for this determination is that the level of control provided for activities within che scope of this Plan has not been reduced. Sincerely, hh M. B. ROCHE Director, Quality & Radiological Controls MBR/RSM/ lab Attachments: 1. Evaluation of the Changes Associated with Revision 2 of the 0QA Plan 2. GPUNC Operational Quality Assurance Plan for Three Mile Island Unit 1 and Oyster Creek 4281L cc: W. Russell R. Hernan A. Dromerick R. Conte L. Thonus J. Wechselberger j

ATTACHMENT 1 9000-88-236 Page 1 of 12 EVALUATION OF THE CHANGES ASSOCIATED WITH REVISION 2 0F THE 00A PLAN I I I I CHANGE l DISPOSITION i l l I

11. General. The phrase "within the scope of this ll. Not a reduction in prior commitment. Permits the l

l Plan" has replaced the phrase "important to I integration of the NRC reviewed and accepted GPUN l l safety." I hardware classification and terminology without l I l changing the previously accepted scope of this Planl l I i

12. General. The designator "ITS" has been replaced

12. Not a reduction in prior commitment. Hardware I

i with the designator "QA Plan Scope" for activities I classification process and terminology previously l l and "NUCLEAR SAFETY RELATED" and "REGULATORY l reviewed and accepted by NRC. Refer to the NRC l l REQUIRED" for items. These designators are used i Safety Evaluation relating to Generic Letter 83-28,1 l to identify items, parts, materials and activities l Item 2.2 (Part 1) from Gordon E. Edison to l l and their associated documents which are "within i Henry Hukill, dated November 18, 1987. l l the scope of this Plan." l l 1 l 1 I I I l l l

13. General. The subsection title "Policy" has

13. Not a reduction in prior commitment.

I l been replaced by the subsection title "General". I Editorial change. I I I l l l l 1 1 1

14. General. The term "review" has generally but not

14. Reduction in prior commitment. However, the l

l completely replaced the term "review for approval" l level of control provided to assure that a docu-1 i and "review for concurrence" with respect to the I ment is appropriate for use has been maintained. l l QA Department review of various documents. This l The selected review of operational procedures by l l change will result in the reduction of QA in-line l Technical Functions, the conduct of technical i i review of documents. Refer also to Appendix B. I reviews as delineated in Section 6.5 of the unit I i l Technical Specifications, the directly stated l l l requirement to change an iglementing document i 1 l if it cannot be implemented as written, the i i l conduct of independent design verification, etc. l l l permits the reduction of in-line QA reviews with-I out cogromising assurance that documents are I appropriate for use. l 1 1 4279L L-

l o ATTACliMENT 1 9000-88-236 Page 2 of 12 EVALUATION OF Tile CilANGES ASSOCIATED WITil REVISION 2 OF THE OQA PLAN CHANGE DISPOSITION 5. Ceneral. The "General" subsection of each section 5. Not a reduction in prior coas-itment. Clarity of has been defined as characterizing the intent of plan improved by directly stating the objectives the section. This, along with changes to Subsec-to be met. Psovides principle or desired etfeet tions 2.2.2, 2.3.1, 2.6 and 3.1, should improve a to be used by the Director QA in rendering deter-the consistency of identifying activities and minations as provided for in Section 1.1. documents which are within the scope of this Plan. 6. The phrase "regulatory requirements and consnit-6. Not a reduction in prior consuitucut. Directly ments" has been utilized where appropriate identifies the principal source of determining throughout the text. what is within the scope of this Plan. 7. Section 1.0 The level of organization detail has 7. Not a reduction in prior consni t uen t. The current been reduced. The cctivities previously assigned text consnits to provide and describes the current have been retained. The organization plan has been organization which provides for the performance explicitly added to Subsection 3.2.2.1. The of the activities directly delineated in Subsec-current organization is described. The organiz-tion 2.2.1. The ation chart has been simplified. independence and the principal functions performed by the Quality Assurance Department have not been reduced. 8. Subsection 1.5.1. The terms "review for approval" 8. Reduction in prior commitment. However, the and "review for concurrence" have generally been control pro /ided to assure that documents are replaced by the team "review". The term "selected" appropriate for use has been maintained. Heter has been insented to directly indicate the graded to Item 4. approach will be utilized in reducing the volume QA in-line review of documents. Refer also to Appendix B.

f. Subsection 1.5.2.

The qualification requirements 9. Change in prior consnitment. Five years of for the Director - Quality Assurance and QA "quality assurance" experience is not sufficient .a Managers positions have been upgraded to for the position. The required managerial r! quire amiugerial and supervisory experience respectively. experience has been increased and the requirement to be knowledgeable in pertinent req u i ren= n t s has been retained. The minirman requirements for the the positions have been enhanced. +- w e.9P= -mum ensu e%mw,.

ATTACliMENT 1 9000-88-236 Page 3 of 12 EVALUATION OF Tile CilANGES ASSOCIATED WITli REVISION 2 0F Tile OQA PLAN CllANCE DISPOS! TION 10. Text related to tiie qualification of inspection 10. Not a reduction in prior commitment. Editorial and examination personnel that was in time only. l previous Subsection 2.5 has been moved to this paragraph. l 11. Section 2.0. - This section has been reorganized 11. Not a reduction in prior commitment. Provides to reduce excessive subparagraphing and to provide enhanced clarity for the user. a nore direct display and discussion of principal concepts.

12. Subsection 2.1.

The text has been rewritten to 12. Not a reduction in prior cousuitment. The more directly state: (1) the objective of the Plan; specific objectives are directly identified to (2) the importance of adherence to documented enhance the implementability of the plan. direction; (3) the need to grade the applicati9n This subsection directly provides the "intent" of plan requirements; and, (4) the responsibility of this Plan. of the Director - QA in determining the extent of applicabi1ity of this Plan.

13. Subsection 2.2.1.

The "nuclear saf ety-related" and 13. Not a reduct ion in prior couuni tment. Reter "regulatory required" terminology is incorporated. to items 1 of 2 of tinis safety evaluation. It should be noted that these terms are corre-lated to the regulatory requirements and commit-ments associated with the plant whicle is more specific than the previous listing provided.

14. Subsection 2.2.2.

The specific activities within 14. Not a reduction in prior consuitment. This the scope of the plan are directly identified. text was changed to directly identify activities Some of this text was previously in Section 6.1. within the scope of this Plan. Some of this text was previously in Section 1.0. Further criteria has been added to be used to identity those tasks associated with the activi-ties which would be within the scope of the plan. Refer also to Subsections 2.3.1 and 2.6. 4279L

ATTACHMENT 1 ..-{ 9000-88-236 i Page 4 of.12 i EVALUATION OF THE CHANCES ASSOCIATED WITH REVISION 2 0F THE OQA PLAN 4 CHANGE DISPOSITION

15. Subsection 2.3.

This subsection was previously 15. Not a reduction in prior convui tment. Provides numbered 2.3.1. A basis for grading the applica-direction to the user of the plan to determine l tion of the plan to activities has been added. the extent j This method relies on those regulatory requirements to which the plan applies. Provides } and commitments in addition to this Plan which a minimum decisional basis for the Director QA speenfy requirements associated with activities to render determinations related to the appli-cability of the plan. t and/or tasks wittiin the scope of tinis Plan. i 4 4

16. Subsection 2.4.1.

This subsection was previously 16. Not a reduction in prior consuitment. numbered 2.3.1.1. Technical Functions has been Provides more formality and structure to i added as an organization which periodically performs Level I activities. selected data gathering activities normally 1 conducted by engineers. 1

17. Subsection 2.5.2.

This subsection was previously 17. Not a reduction in prior consuitment. I numbered 2.3.2.2. Review and approval requirements Provides for direct consistency between this for the plan have been revised to be consistent j with the CPUN Review and Approval Matrix. text of the plan and the GPUN Review and Approval Matrix. i i i

18. Subsection 2.7.

This subsection was previously 18. Not a reduction in prior consuitment. Editorial a numbered 2.5. The text has been editorialized to j be consistent wi th time new Section 9.0. change resulting from the addition of Section 9. Some text transferred to subsection 1.5.2.

19. Subsection 2.8.

This subsection was previously 17. Not a reduction in expressed connaitment. numbered 2.6. The text has been revised to Provides additional information to the user (1) directly address activities; (2) inco rpora t e of the plan. the new classification designators; and (3) incor-porate a general hasis to determine if parts and materials are within the scope of this Plan. 4279L _ _ ~. - ~ __ _ ~ _. _

o ATTACilMENT 1 9000-88-236 Page 5 of 12 EVALUATION OF THE CllANCES ASSOCIATED WITH REVISION 2 0F Tile OQA PLAN CllANGE DISPOSITION

20. Subsection 2.10.

This subsection was previously 20. Reduction in prior conunitment. This previous numbered 2.8. 'Ibe text has been revised to section required tisat "all" activities within (1) refer to the CPUN Review and Approval Matrix scope of this Plan that were addressed by the to determine if safety reviews are required; Regulatory Guide commitments in Appendix C (2) be consistent with current practice; and required safety review. This editorial change (3) add some specific tasks conducted during an establishes direct consistency with Section 6.8 "independent safety review." of Technical Specifications as the basis for what docwnents are listed on the Matrix.

21. Subsection 2.11.3.

This subsection was previously 21. Not a reduction in prior convui tment. Provides numbered 2.9.3. The text has been revised to a more direct indication of the leadership role more directly state the principle responsibilities expected from this position. of the position of Director - QA and reduce redundancy.

22. Subsection 3.1.

The term "doewnent" is used 22. Not a reduction in prior consuitment. Provides generically to directly recognize the use of documents other than "procedures" to prescribe clarity for the user of the plan. Recognizes that documented direction can be provided by methods for implementing the requirements of the formats other Lisan "procedures." plan (e.g., drawings, work authorizing documents, specifications, etc.)

23. Subsection 3.1.1.

More direct implementing 23. Not a reduction in prior consuitment. Provides document compliance statement has been added. clarity for user of the plan. Directly provides the general principle that documents which prescribe direction for the conduct of activities i within the scope of this Plan shall be complied with as written or changed prior to proceeding. I 42791. i )

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^c ATTACHMENT 1 ^ 9000-O-236 Page 7 of 12 EVALUATION OF Tile CilANCES ASSOCIATED WITH REVISION 2 0F THE OQA Pl.AN CilANCE DISPOSITION

30. Section 5.0 Editorial changes liave been made to 30.

No reduction las prios rou ui tii.eist. Direct make this subsection clear and direct. consistency between Subsection 2.8, 5.1.1.3 and 5.1.2.4 of this plan provided.

31. Subsection 5.1.2.4 A new subsection specific 31.

Not a reduction in prior consnita.ent. Intention to the use of conenercial grade items in nuclear safety-related applications has been added to is to use the recently developed EPRI Cuidetines enhance and clarity the control of such usage. on controlling the use of conmeercial grade items in nuclear sately related applications.

32. Subsection 6.1.

Portions of the text from the 32. Not a reduction in prior conunitment. Revision I have been moved to Sections 1.0, 2.0 Editorial change nunde to enhance the useability and 3.0. of the docwnent. 33. Subsection 6.'*.2.3.c. This subsection has been 33. Reduction in prior connaitment. The current revised to delete QA review for concurrence of process for the review and approval of such all maintenance and installation procedures. documents is sufficient to assure the appropri-Review for concurrence of administrat ive proce-ateness for use of the doewuent without in-line dures for maintenance and installation is overview by QA. Note, however, that review of retained. all such documents for inclusion of inspection points is maintained.

34. Subsection 6.4 This subsectioa has been revised 34.

Not a reduction in prior conuni tment. to directly identity chemistry and the preparation Editorial change made to directly state that of radioactive wastes f or shipment as special chemistry and preparation of radioactive wastes processes. for shipment are "special processes" within the context of the OQA Plan and that the indicated controls apply.

35. Subsection 6.10.1.2.c.

This subsection has been 35. Not a reduction in prior consuitment. Editorial revised to clarify MCF responsibilities associatel change which establishes direct consistency with with testing activities. current organizational policy. 4279L

ATTACHMENT 1 9000-88-236 Page 8 of 12 EVALUATION OF THE CHANCES ASSOCIATED WITH REVISION 2 OF THE OQA PLAN CHANCE DISPOSITION 36. Subsection 6.6.1.1. This subsection has been 36. Not a reduction in prior consni tauent. Editorial revised to clarify that the calibration require-ments of this Plan apply to both installed and change which directly indicates the scope of coverage of the plan. portable test and measurement equipment. 37. Subsection 6.6.1.2.f. This subsection has been 37. Not a reduction in prior couunitment. Provides revised to clarify that some measurement equipment clarity by recognizing that certain exceptions will not be (alibrated because of the construction as indicated are authorized. or lack of adjustability. 38. Subsection 6.9.2.2. This subsection has been 38. Not a reduction in prior convui tment. Editorial added to directly state MCF Division's responsi-change which diaectly indicates responsibility bility in the housekeeping activities. under this plan. 39. Subsection 6.lO.l.2.c. This subsection has been 39. Not a reduction in prior conunitment. Provides revised to incorporate supplemental controls for an additional and equivalent method of indepen-temporary modifications provided by ANS 3.2-1982. dent verification for ensuring equipment has been properly returned to service. 40 Subsection 6.11. This subsection has been revised 40. Not a reduction in prior conmuitment. Provides to (1 ) di rect ly indicate the equivalence of the requisite consistency within the plan and current terms "procedure" and "inst ructions"; (2) clarify organizational policy. corrent MCF Division responsibilities; and (3) establish consistency with current CPUN policy (s) 41. Subsection 6.11.1.1. This subsection has been 41. Not a reduction in prior conuni tment. Provides revised to directly state that time Plant Division direct consistency between this plan and current Director is responsible for approving major work organizational policy. during plant operations in advance. The authority to delegate this is also provided.

42791,

ATTAC K NT 1 9000-88-236-Page 9 of 12 EVALUATION OF THE CHANGES ASSOCIATED WITH REVISION 2 0F THE 00A PLAN l l I 1 CHANGE l DISPOSITION l 1 I l l42. Subsection 8.1.3. This subsection has been added 142. Not a reduction in prior commitment. Text l l to define when nonconformance reports do not have l added to provide for and authorize a graded l l to be used to report deficiencies. Such deficien-l approach to deficiency reporting. Key concept l l cies are required to be documented in the verifica-I that remains is that all deficiencies identified l l tion report and periodically analyzed as specified I by verification activities shall be documented, I I by Subsection 8.2.8. I reported and trended. l 1 l I 143. Section 9.0. This section has been added to 143. Not a reduction in prior commitment. GPUN l l directly describe and, therefore, clarify the i experience has indicated that the previous I methods to be utilized to develop, implement and i Subsection 2.5 was not sufficient to delinecte I i maintain the training associated with activities I the extent to which QA Plan requirements apply I I within the scope of this Plan. I to developing, conducting and evaluating training.1 l l This section was added to provide that l 1 1 delineation. l I I i 144. Section 10.0. Section has been renumbered; l44. Not a reduction in prior commitment. The 1 l previously Section 9.0. Editorial changes I manner in which audits will be scheduled and l l have been made to more clearly define the I conducted is more directly stated. Indicates l l intended and current comprehensiveness of the I that GPUN intends to maintain a performance-based l l audit program. l audit program. l l l l 145. Appendix 8. This appendix has been revised 145. Reduction in prior commitment. The extent of I l to provide for varying the timing and number i QA in-line review of all documents previously l l of QAD review of documents. l listed is not required to assure the documents l I are appropriate for use. Refer to Item 4. l l 1 l 1 1 I i 146. Appendix C. The commitment to Regulatory Guide 146. Not a reduction in prior commitment. I i 1.33 was revised to further clarify that the l Editorial change made to assure direct l l requirements for the minimum frequency and topical I consistency between the units' Technical l l coverage of the GPUN internal audit p ran are l Specifications and the QA Plan. I go e g g by the unit's Technical pecifica-1 I I 4279L

ATTACHMENT 1 9000-88-236 Page 10 of 12 EVALUATION OF TiiE CllANCES ASSOCIATED WITH REVISION 2 0F THE OQA PLAN CHANGE DISPOSITION

47. Aylwndix C.

The consnitment to ANSI N18.7-1976 was 47. Not a reduction in prior couanitment. revised to clarify that this Plan is the "sunsnary Directly states within the plan how this document" referred to in Paragraph 5.1 of that ANSI N18.7 section is met. standard.

48. Appendix C.

The conunitment to ANSI 18.7-1976 was 48. Reduction in_prio r consui tment. The level of modifled to use a four year instead of two year control of the appropriateness of plans, periodic procedure review cycle. proce-dures or instructions for use has not been compromised. This modified approach places the requisite emphasis on revising procedures to permit compliance as the principal sneans to ensure that plans, procedures and instructions are appropriate for use.

49. Appendix C.

The conunitment to ANSI N45.2.1-1973 49. Not a reduction in prior consnitment. was revised to add portions of the 1980 edition of this standard for the use of fluids other than Provides for use of other f luids f or f lushing in a controlled manner espalvalent to that water for flushing. already consnitted f or water. $0. Appendix C. The consui t men t to Regulatory Guide 50. Not a reduction in prior commitment. 1.$8 was revised to f urther clarif y that plant Di,rectly states that ** ope ra t ional" pe rsonnel personnel utilized to perform visual examinations will meet f or leakage would be qualified to the edition of pertinent ASME qualification require-ments when conducting ASME Section IX examina-ASME Section IX and related codes currently Lions. Prevents the misapplication of connai t ted to. Regulatory Guide 1.8 in this situation. $1. Appendix C. The conunitment to Regulatory Guide 51. Not a reduction in prior conanitment. 1.64 was revised to clarify that a review of a Intended to clarify that some "Ifeld changes" "f ield change" to a previously verif ied design will not reouire "independent design veriti-for effect on the design constitutes a design cation" because a verification of those "field changes" which have review of each "Iicld change" request for the effect on the design may be no elfcct on the design. sufficient in certain cases. 42791.

ATTACliMENT I 9000-88-236 Page 11 of 12 EVALUATION OF Tile CllANCES ASSOCIATED WITH REVISION 2 OF Tile OQA PLAN CHANGE DISPOSITION $2. Appendix C. The consni tment to ANSI N45.2.5-1974 52. Reduction in prior cenunitment. Level of has been sevised to adopt a longer caliteratiosa const rol provided by the plan not affected. Interval for torque wrenches. The f requency of calibration remains directly related to the frequency of use. $3. Appendix C. The conuni t men t to ANSI N45.2.13-1976 $3. Not a reduction in prior consuitment. has been revised to clarify that personnel who Restatement for the sale of assuring the perform audits will be qualified to Regulatory consistency of the QA Plan text. Guide 1.146,8/80 and not ANSI N45.2.6, as may be implled.

54. Appendix C.

The consnitment to Regulatory Guide 54 P.cduction in prior consuitinent. This guide was 1.143 has been modif led to be consistent witti utilized in the original design basis to not the NRC modif ied conunitment to Regulatory Cuide 1.26. specif y either quality or technical requirements. Change required to establish direct consistency with Llie original design basis.

55. Appendix C.

The consnitment to Regulatory Guide $5. Not a reduction in prior consuitment. 1.144 has been revised to clarify that the require-ments for the minimum frequency and topical cover-Editorial change made to assure direct consistency between 6.5 of the units' age of the CI'UN internal audit program is specified Technical Specifications and the QA Plan. by Section 6 of the nuclear units

• Technical Specifications.

$6. Appendix C. The conani t men t to kegulatory Guide 56. Not a reduction in p r ior comuni t ment. 1.144 has been revised to clarify that source Editorial change made to ast,ure direct surveillance can be used in lieu of or addition to receipt inspection. consistency between the text of the QA Plan and the Regulatory Guide couanitted tu,

57. A pendix C.

The consnitment to Regulatory Guide 57 Not a reduction in prior conauitment. J 1.144 has been revised to clarify the minimum Clarification to directly describe intendet topical covera 6e and scheduling basis for scope of routine external audits, external audits. Me*- --h-p-s ew-.+mi _m 42791.

i ~ ATTAC M MT 1 .*l i 9000-88-236 Page12 of 12 EVALUATION OF THE CHANGES ASSOCIATED WITH REVISION 2 0F THE OQA PLAN I I I J l CHANGE l DISPOSITION I 1 1 I i 158. Appendix D. Some terms have been added. These 158. Not a reduction in prior commitment. Provided i I I terms are identified by margin bars. I for user. I I I I I I I 159. Appendix D. Some terms have been deleted. They 159. Not a reduction in prior commitment. These terms I 1 include confidential-security, design change I are not needed in this appendix to support the i I notice, field change request, GORB, ITS,10SRG, I text of the current revision. They either have i I LER, QA Plan, OA Program, Safety Related, Safety I been replaced with new terminology, can be found I ? l Grade, Safety Review Groups and Vendor. I in the text of the 10CFR, are adequately defined l l l within the text of the plan at their point of l l l use, etc. I I I I I I i 160. Supplements 1 and 2. These supolements have 160. Not a reduction in prior commitment. I i been deleted to reduce the level of specific l l l organizational detail. As noted with regard l l 1 to Section 1.0, the GPUN Organization Plan l l l has been added to Section 3.2.2.1. l I I I I i i 1 I I I I I l l 1 1 I I I I I I I I I I i 1 1 I I I I I I I I I I i 1 I 4279L l ..}}