ML20151Q005

Rev 2 to 1000-PLN-7200.01, Gpu Nuclear Corp Operational QA Plan for TMI-1 & Oyster Creek

ML20151Q005
Person / Time
Site:	Oyster Creek, Three Mile Island, 05000000
Issue date:	04/08/1988
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20151P997	List: ML20151P993 ML20151Q005
References
1000-PLN-7200.0, NUDOCS 8804260301
Download: ML20151Q005 (121)

Text

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ENuclear GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE MILE !SLAND UNIT i 1000 PLN-7200.01 AND OYSTER CREEK Tltle GPUNC Operational Quality Assurance Plan for Three Mile Island Unit I and Oyster Creek, Revision 2 Applicability / Scope Responsible Office This Plan Has GPUNC-Wide Applicability Except THI-2 9860 This docurrent is within QA plan scope X Yes No Effective Date Safety Reviews Required X Yes No Signature Concurring Organizational Element Date

_Oriainator /s/ R. H. Keaten Of rector Ogality Assurance Concurred /s/ M. B. Rocne Dir-Quality & Raciological Control 2/3413 _

By 3/24/88

/s/ H. D. Huktll, Jr. Dir-TMI-l 3/17/88

/s/ P. B. Fiedler Dir-Oyster Creek 3/11/88

/s/ R. F. Hilson Dir-Technical Functicns 3/11/88

/s/ R. L. Long Olf-Planning & Nuclear $afety 3/11/88~

/s/ F. F. Manganaro Dir-Administraticn 2/19/8 F

/s/ R. H. Heward, Jr. Otr Maint., Const. & Facilities 3/11/88

/s/ H. Sayers Corporate Secretary 2/10/88

/s/ C. H. Comerford Staff Analyst Policies / Procedures 2/25/88

/s/ J. D. Bansch Responsible Tecnnical Revieaer 3/31/88 Approved Office of the Presicent p 1.0 3685L 8804260301 880415 PDR ADOCK 05000219 P DCD

GPUNC OPERATICNAL QUALITY ASSURANCE ENuclear Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-72CO.01 AND OYSTER CREE <

Title GPUNC Operational Quality Assurance Plan for Tnree Mile Island and Oyster Creek Revision 2 LIST OF EFFECTIVE PAGES Page Rev. Content Page Rev. Content Page Rev. Content Page Rev. Content No. No. Changed No. No. Changed No. No. Changed No. No. Changed 1.0 2 30.0 2

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GPUNC CPERATIONAL QUALITY ASSURANCE Number Nuclear

- PLAN FCR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title GPUNC Operational Quality Assurance Plan for Three Mlle Island and Oyster Creek Revision 2 TABLE OF CCNTENTS Page LIST OF EFFECTIVE PAGES 1.0a l TABLE OF CONTENTS 2.0 DOCUMENT HISTORY 5.0 l INTRODUCTION 14.0 1.0 CRGANIZATION 1.1 Office of the President 15.0 1.2 Directors TMI-1 and Oyster Creek 16.0 1.3 Director Technical Functions 16.0 1.4 Director Administration 16.0 1.5 Director Quality & Radiological Controls 16.0 1.6 Director Maintenance, Construction & Facilities 19.0 1.7 Corporate Secretary 19.0 1.8 Director Planning and Nuclear Safety 19.0 2.0 QUALITY ASSURANCE PROGRAM 2.1 General 22.0 2.2 Scope 22.0 2.3 Graded Approach 24.0 2.4 Three-Level Assurance Approach 25.0 2.5 Operational QA Plan Control 27.0 2.6 Quality Assurance Program Review 28.0 2.7 Indoctrination and Training 29.0 2.8 Classification Process 29.0 l 2.9 Records of Regulatory Commitments 30.0 2.10 Safety Reviews 30.0 2.11 Responsibilities 32.0 3.0 CONTROL OF DOCUMENTS AND RECCRDS 3.1 Policies, Plans, Instructions, Drawings, Specifications 35.0 3.2 Document Control 37.0 3.3 Quality Assurance Records 40.0 4.0 DESIGN CONTROL 4.1 General 44.0 4.2 Requirements 44.0 4.3 Responsibilities 46.0 l

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GPUNC OPERATICNAL QUALITY ASSURANCE Number (UClear PLAN FOR THREE MZLE ISLAND UN!T 1 1000-PLN-7200.01 AND OYSTER CREEK Title GPUNC Coerational Quality Assurance Plan for Three Mlle Island and Oyster Creek Revisicn 2 TABLE OF CONTENTS (CONTINUED)

Page 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement 48.0 5.2 Identification and Control of Materials.

Parts and Ccmponents 55.0 6.0 CONTROL OF STATION ACTIVITIES 6.1 General 57.0 I 6.2 Control of Inspections 57.0 6.3 QA Monitoring 60.0 6.4 Control of Special rocesses 61.0 6.5 Test Control 62.0 6.6 Control of Measuring and lest Equicment 65.0 6.7 Handling. Storage and Shipping 67.0 6.8 Inspection, Test ano Ocerating Status 69.0 6.9 Housekeeping and Cleanliness 70.0 6.10 Equipment Control 71.0 6.11 Contrcl of Construction, Maintenance 73.0 (Preventive / Corrective) and Modifications 6.12 Control of Surveillance Testing and Inspection 77.0 6.13 Radiological Control 78.0 7.0 CONTROL OF RADI0 ACTIVE WASTES 7.1 General 80.0 l 7.2 Requirements 60.0 7.3 Responsibilities 31.0 8.0 CONTROL OF CCRRECTIVE ACTIONS AND NONCONFCRMANCES 8.1 General 33.0 l 8.2 Requirements 83.0 8.3 Responsibilities 85.0 9.0 CONTROL OF TRAINING 9.1 General 87.0 9.2 Requirements 87 0 9.3 Responsibilities 88.0 10.0 AUDITS l 10.1 General 90.0 l l 10.2 Requirements 90.0 l 10.3 Responsibilities 92.0 l

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• GPUNC OPERATIONAL QUALITY ASSURANCE Numbor hdgf PLAN FOR THREE MfLE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title GPUNC Cperational Quality Assurance Plan for Three Mlle Island and Oyster Creek Revision 2 TABLE OF CONTENTS (CCNTINUED)

Page APPENDICES: 94.0 Appendl< A - Comparisen Chart of Quality Assurance Plan Requirerrents with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards 95.0 Appendix 3 - QAD Review Requirements for Documents Within QA Plan Scope 96.0 Appendit C - NRC Regulatory Guide Ccamitroents and E<ceptions 97.0 Appendix 0 - Terms and Definitions 116.0 1

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GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-72CO.01

Title:

DOCUMENT HISTCRY Revisien 2 PREPARED BY:

EFFECTIVE REVIEHED BY:

REVISICN DATE DESCRIPTION OF CHANGE APPROVED BY:

2 General. The phrase "within the scope of this Plan" has replaced the phrase "important to safety."

2 General. The designator "ITS" has been replaced with the designator "QA Plan Scope" for activities and "Nuclear SAFETY RELATE 0" and "REGULATORY REQUIRE 0" for items. These designators are used to identify items, parts, materials and activities and their associated documents which are "within the

$ Cope of this Plan."

2 General. The subsection title "Policy" has been replaced by the subsection title "General".

2 General. The term "review" has generally but not completely replaced the term "review for approval" and "review for concurrence" with respect to the QA Depart-ment review of various documents. This will permit the QA Department to vary the timing of such reviews to grade the reduc-tion and purpose of in-line reviews of documents. Refer also to Appendix 8 of this Plan.

2 General. The "General" subsection of each section has been defined as charactert:ing the intent of the section (Refer to 2.5).

This, along with additions to Subsections t

2.2.2, 2.3, 2.8 and 3.2.2.2, should improve

the consistency of identifying activities I

and documents which are within the scope l of this Plan.

l 2 General. The phrase "regulatory require-ments and commitments" has been utilized j where appropriate throughout the text.

l 2 Section 1.0. The level of organization detail has been reduced. The activities previously assigned have been retained, i The organization plan has been explicitly added to Subsection 3.2.2.1. The current organization is described. The organi-

ation chart has been simplified.

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, GPUNC C.PERATIONAL QUALITY A$$fJNCE Number Qgggggy HAN FOR THREE MILE ISLAND LNIT 1 AND Ov5TER CREEK I M A N42CO.01

Title:

DOCUMENT HISTCRY Revision 2 PREPARED SY:

EFFECTIVE REVIEWED BY:

REVISION DATE DESCRIPTION 0F CHANGE APPROVED BY:

2 Subsection 1.5.1. The terms ' review for approval" and "review for concurrence" have generally been replaced by the term "review". The term "Selected" has been inserted to directly indicate the graded approach will be utilized in reducing the volume QA in-line review of documents.

Refer also to Appendlx B.

2 Subsection 1.5.2. The qualification requirements for the Director - Quality Assurance and QA Section Managers positions have been upgraded to require managerial and supervisory experience respectively.

This revision removes "quality assurance" experience as a sole basis of selection.

2 Subsection 1.5.2. Text related to the qualification of inspection and examination personnel that was in the previous Sub-section 2.5 has been moved to this paragraph.

2 Section 2.0. This section has been reorganized to reduce excessive subpara-grapning and to provide more direct display and discussion of principal concepts.

2 Subsection 2.1. The text has been rewritten to more directly state: (1) the objective of the Plan; (2) the importunce of adherence to documented direction; (3) the need to grade the application of plan requirements; and, (4) the responsibility of the Director QA in determining the extent of applica-bility of this Plan.

2 Subsection 2.2.1. The "nuclear safety-related" and "regulatory require 3" termin-ology is incorporated. It should be noted that these terms are correlated to "regula-tory requirements and commitments of the plant which is more specific than the previous listing provided.

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GPUNC CPERATIONAL QUALITY ASSURANCE Number Nuclear ,

i PLAN FCR THREE MILE ISLAND UN M 1 AND OYSTER CREEK 1000-PLN-7200.01

Title:

DOCUMENT HISTORY Revision 2 iPREPARED BY:

EFFECTIVE 'REVIEHED BY:

REVISION DATE DESCRIPTION OF CHANGE APPROVE 0 8Y:

2 Subsection 2.2.2. The specific activities within the sccpe of the plan are directly i identified. Some of this text was previously in Section 6.1. Some of this text was previously in Section 1.0. Further criteria has been added to be used to identify those tasks associated with the activities which would be within the scope of the plan. Refer also to Subsections 2.3 and 2.8.

2 Subsection 2.3. This subsection was previously numbered 2.3.1. A basis for grading the application of the plan to activities has been added. This method relles on those plans and documents identi-fled in addition to this Plan which specify requirements associated with activities and/or tasks within the scope of this Plan.

2 Subsection 2.4.1. This subsection was previously numbered 2.3.1.1. Technical Functions has been added as an organization which periodically performs Level 1 activities.

2 Subsecticn 2.5.2. This subsection was previously numbered 2.3.2.2. Terminology consistent with the GPUN Review and Approval Matrix has been utilized. Review and approval requirements for the plan have been revised to be consistent with the GPUN Review and Approval Matrix. Text from pre-viously numbered 2.3 has been incorporated.

2 Subsection 2.7. This subsection was previously numbered 2.5. The text has been editorialized to be consistent with the new Section 9.0. Some previous text has also

{ been moved to Subsection 1.5.2.

2 Subsecticn 2.8. This subsection was previously numbered 2.6. The text has been revised to (1) directly addr6ss activities (2) incorporate the new classification designators; and, (3) incorporate a general basis to determine if parts and materials are within the sccpe of this Plan.

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- GPUNC CPERATIONAL QUALITY ASSURANCE Numcer Nuclear et*N roR m cc Mite IStA e U m i AND OYSTER CREEK i0w go. m 0.01

Title:

DOCUMENT HISTORY Revision 2 PREPARED SY:

EFFECTIVE REVIEhED SY:

cEVISION DATE DESCRIPTICN OF CHANGE APPROVED SY:

2 Subsection 2.10. This subsection was previously numbered 2.3. The tett has teen revised to (1) refer to the CPUN Review and Approval Matrix to determine if safety reviews are reautred: (2) te censistent ditn current practice; and (3) add scme specific casks conducted during an "independen safety review."

2 Subsection 2.11.3. This subsection was previously nuncered 2.9.3. The text has been revised to more directly state the principal resconsibilities Cf the position of Director QA and reduce redundancy.

2 Subsection 3.1. The term "document" is used generically to directly recognize the use of documents other than "procedures" to prescrice methods for implementing the requirements of tne plan (e.g. , drawings, work authorizing cocuments, specifications, etc.)

2 Subsection 3.1.1. More direct implementing document compliance statement has been added.

2 Subsection 3.1.2. Editorial changes were made to make this subsection clearer and more direct. Text has been moved from other subsections. More direct text associated with implementing document compliance has been added to directly require changing the document if it cannot ce complied with.

2 Subsection 3.1.2.. The biennial review of plans, procedures and instructicns nas been changed to at least every fcur years.

2 Subsection 3.2.2.1 Specificity hei teen improved by adding document types for wnich document centrol procedures are currently in place. Those documents delineated in Subsection 3.2.2.1.a have been added.

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GPUNC OPERATIONAL QUALITY ASSURANCE Nuclear atAN r0a TsReE MILE IStAND unit i AND OYSTER CREEK Number iOOO-PtN.T2c0.0i

Title:

DOCUMENT HISTCRf Revision 2 PREPARED BY:

EFFECTIVE REVIEWED BY:

REVISICN DATE DESCRIPTION OF CHANGE APPROVED BY:

2 Subsection 3.2.2.2. Olrection for classify-Ing accuments has been added in 3.2.2.2.a and 3.2.2.2.b.

2 Section 4.0, Some editorial changes have been made. They are Indicated by a margin bar. 3revious Subsection 4.2.9.c has been renumbered 4.2.13; previous 4.2.13 is now 4.2.14.

2 Subsection 4.3.3. This subsection has been revised to indicate that audits of the design control process will include verif t-cation of the technical adequacy of the engineering produced.

2 Section 5.0. Editorial changes have been made to make this subsection clearer and more direct.

2 Subsection 5.1.2.4. A new subsection specific to the use of commercial grade items in nuclear safety related appilcations has been added to enhance and clarify the /

control of such usage, j 2 Subsection 6.1. Portions of the previous text have been moved to Sections 1.0, 2.0, and 3.0.

2 Subsections 6.2.2.2.c and 6.2.2.3. These subsections have Deen revised to delete QA review for concurrence of all maintenance and installation procedures. Review for concurrence of administrative procedures for maintenance and installation is retained.

2 Subsection 6.4 This subsection has been revised to directly identify chemittry and the precaraticn of radioactive wastes for shipment as special processes.

2 Subsection 6.5.2.3.c. This subsection has been revised to clarify MCF responsibilities associated with testing activities.

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', GPUNC OPERATIONAL QUALITY ASSURANCE Number gqlgJ~]lggjg[' PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-72CO.01 AND OYSTER CREEK

Title:

DOCUMENT HISTORY Revision 2 PREPARED BY:

EFFECTIVE REVISION DATE REVIEWED BY:

DESCRIPTION OF CHANGE APPROVED BY:

2 Subsection 6.6.1.1. This subsection has been revised to clarify that the calibration requirements of this Plan apply to both installed and portable test and measurement equipment.

2 Subsection 6.6.1.2.f. This subsecticn has been revised to clarify that some test and measurement equipment will not be callbrated because of the construction or lack of adjustability.

t' Subsection 6.9.2.2. This subsection has been added to directly state MCF Olvision's responsibility in the housekeeping activities.

2 Subsection 6.10.1.2.c. This subsection has been revised to incorporate supplemental controls for temporary modifications provided by ANS 3.2-1982.

2 Subsection 6.11. This subsection has been revised to (1) directly indicate the equiva-lence of the terms "procedure" and "instruc-tions"; (2) clarify current MCF Division responsibilities; and, (3) establish consistency with current GPUN policy (s) 2 Subsection 6.11.1.1. This subsection has been revised to directly state that the Plant Olvision Director is responsible for approving major work during plant cperations in advance. The authority to delegate this is also provided.

2 Subsection 8.1.3. This subsection has been added to define when nonconformance reports do not have to be used to report deficien-c les. Such deficiencies are required to be documented in the verification report a nd periodically analyzed as specified by Subsection 8.2.8.

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MNuziear GPUNC OPERATIONAL QUALITY ASSURANCE Number et^" r0a r"Ree "t'e IS'AND uuIT i iOOO-etN-7200.0i AND OYSTER CREEK

Title:

DOCUMENT HISTORY Revision 2 EFFECTIVE PREPARED BY:

REVISION OATE REVIEHED BY:

DESCRIPTION OF CHANGE APPROVED EY:

2 Section 9.0. This section has been added to circctly describe and, therefore, clarify the methods to be utilized to develop, implement and maintain the training associ-ated with activities within the scope of this Plan.

2 Section 10.0. Section has been renumbered; previously Section 9.0. Extensive editorial changes have been made to more clearly define the intended and current comprehen-siveness of the audit program.

2 Appendix B. This appendix has been revised to provide for varying the timing and number of QAD review of documents.

2 Apperidi x C. The commitment to Regulatory Guide 1.33 sas revised to further clarify that the requirements for the minimum frequency and topical coverage of the GPUN internal audit program are those provided by the unit's Technical Specification Section 6.

2 Appendix C. The commitment to ANSI N18.7-1976 was revised to clarify that this Plan is the "summary document" referred to in Paragraph 5.1 of that standard.

2 Appendix C.

The commitment to ANSI N18.7 was modified to use four year instead of two year perioic procedure review cycle.

This modified approach places added emphasis on the revision to procedures to permit compliance to provide the principal means to ensure that plans, procedures and instructions are appropriate for use.

2 Appendix C. The commitment to ANSI N45.2.1-1 1 973 was revised to add portions of the 1

of 980 edition of this standard for the use flitids other than water for flushing.

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GPUNC OPERATIONAL QUALITY ASSURANCE Nuolear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Number 1000-PLN-7200.01

Title:

DOCUMENT HISTORY Revision 2 EFFECTIVE PREPARED BY:

REVISION DATE REVIEHED BY:

DESCRIPTION OF CHANGE APPROVED BY:

2 Appendix C. The commitment to Regulatory Guide 1.58 was revised to further clarify that plant personnel utilized to perform visual examinations for leakage would be quallfled to the edition of ASME Section IX and related codes currently committed to.

2 Appendix C. The commitment to Regulatory Guide 1.64 was revised to clarify that a review of a "fleid change" to a previously verlfled design for effect on the design constitutes a design verification of those "field changes" which have no effect on the design.

2 Appendix C.

The commitment to ANSI N45.2.5-1974 has been revised to adopt a longer calibration interval for torque wrenches.

The basis for this adoption is that the intent of the standard is still being met in that the frequency of calibration is related to the frequency of usage.

2 Appendix C. The commitment to ANSI N45.2.13-1976 has been revised to clarify that personnel who perform audits will be qualified to Regulatory Guide 1.146, 8/80 and not ANSI N45.2.6, as may be implied.

2 Appendix C. The commitment to Regulatory Guide 1.143 has been modified to be consistent with the NRC accepted modified commitment to Regulatory Guide 1.26. The original design basis did not utilize the current version of this Regulatory Guide.

2 Appendix C. The commitment to aegulatory Guide 1.144 has been revised to clarify that the requirements for the minimum frequency and topical coverage of the GPUN i nternal audit program is specified by Section 6 of the nuclear units' Technical Specifications.

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GPUNC OPERATIONAL QUALITY ASSURANCE Nuclear Number e'A" r0R TaRee "ILE ISLANo UNIT i iOOO PtN.7200.0i AND OYSTER CREEK

Title:

DOCUMENT HISTORY Revision 2 PREPARED BY:

EFFECTIVE REVIEWE0 8Y:

REVISION DATE DESCRIPTION OF CHANGE APPROVED BY:

2 Appendix C. The commitment to Regulatory Guide 1.144 has been revised to clarify that source surveillance can be used in lieu of or addition to receipt inspection.

2 Appendix C. The commitment t' Regulatory Guide 1.144 has been revised to clarify the recical covercge and scheduling basis of external audits.

2 Appendix D. Some terms have been added.

These terms are Idertified by a margin bar.

2 Appendix 0. Some te'ms have been deleted.

They include confidential-security, design change notice, field change request, GOR 8, ITS, IOSRG, LER, QA Plan, QA Program, Safety Related, Safety Grade, Safety Review Groups and Vendor.

2 Supplements 1 and 2. These supplements have been deleted to reduce the level of specific organizational detail. As noted with regard to Section 1.0, the GPUN Organization Plan has been added to Section 3.2.2.1.

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GPUNC OPERATIONAL QUALITY ASSURANCE ggglgg7 PLAN FOR THREE MlLE ISLAND UNIT 1 Number 1000-PLN-7200.01 AND OYSTER CREEK Ti tle GPUNC Operational Quality Assurance Plan for Three Mlle Island and Oyster Creek Revision 2 INTRODUCTION GPU Nuclear (GPUN) is responsible for the operation and maintenance of TMI Unit I and Oyster Creek Nuclear Generating Stations. The Quality Assurance Plan contained herein describes the formal and comprehensive plan which has been established to ensure compliance with 10CFR20; 10CFR50, Appendix 8; 10CFR71, Subpart and H;Creek.

Oyster and applicable Regulatory Guides during the operation of TMI Unit I This plan for THI Unit 1 and Oyster replaces the Operational Quality Assurance Plans Creek.

This Operational Quality Assurance Plan is formatted in such a manner as to provide all users with a functionally useable document.

It describes how this Plan is to be functionally implemented with due regard to the safety and health of the public and the personnel on site. This Operational Quality Assurance Plan identifies Assurance organizations Program responsible for the implementation of the Quality (Section 1.0)

(Section 2.0). The remaining sections and an overall description of the Program are structured in a functional manner.

The requirements subsequent sections.for administrative controls are generic and apply to all Control of documents and records is contained in Section 3.0; control of design is contained in Section 4.0; control of materials and services, including procurement, is contained in Section 5.0. Sections 6.0 and 7.0 contain the plan requirements for those operational, support, and assurance activities associated with the safe operation of all plants; constructicn and/or modifications associated with corrective maintenance, plant improvement, and/or repair; and the processing and preparation for the transport of radioactive wastes. Specific requirements such as control of measuring and test equipment, inspection, special processes, test control, and status of inspections, tests and operations are included therein. Sections 8.0 , 9.0 and 10.0 again apply to all activities within the scope of this Plan. Section 8.0 addresses the identification and ilisposition of nonconformances associated with all aspects of the Program. In addition, this section contains the management controls provided for evaluating collectively all conditions adverse to quality and determining what corrective actions should be taken to preclude their recurrence. Section 9.0 contains the requirements and administrative controls applicable to training; Section 10.0 contains the requirements and administrative controls applicable to the conduct of audits. Appendices A, 8 and C contain additional requirements associated with the functional areas discussed in this Plan. Appendix D contains the definitions of terms used throughout this Plan.

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Nuziear GPUNC OPERATIONAL QUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT I Number 1000-PLN-7200.01 AND OYSTER CREEK Title 1.0 Organization Revision 2 1.0 Organization i

The GPUN Organization Plan is the highest tiered document that assigns major functional responsibilities. Implementing documents assign more specific responsibilities and tasks and define the organization interface (s) involved in conducting activities and tasks within the scoce of this Plan. The requirements of this Operational Quality Assurance Plan apply to those organizations and positions which manage and perform activities within the scope of this plan. This section provides a summary of the organizational units and functions which perform activities within the scope of this plan.

The GPUN organization is structured on the basis that the attainment of the objectives of this plan relles on those who manage, perform, and support the performance of activities within the scope of this plan; and, assurance of this attainment relies on those who have no direct responsibility for managing or performing the activity.

The organizations responsible for the conduct, support and assurance of operation, maintenance, modification, repair, inservice inspection and refueling of the nuclear generating stations is illustrated in Figure 1. These organizations have functions located both on site and off site.

1.1 Office of the President The President and the Executive Vice President constitute the Office of the President. The Executive Vice President-GPUN reports directly to the President-GPUN, The two officers work in close cooperation and share the executive duties of GPUN. As used in this plan, the Office of the President (OP) means either the President or the Executive Vice President.

The President-GPUN has the overall responsibility for the establish-ment, implementation and evaluation of the effectiveness of the Quality Assurance Program applicable to THI Unit 1, and Oyster Creek. This responsibility is administered through his management staff, including:

Corporate Secretary Director - OCNGS Director - TMI Unit i Director - Technical Functions Director - Administracion Director - Quality & Radiological Controls Director - Maintenance, Construction, & Facilities Director - Planning & Nuclear Safety These OP management staff members give their full support to the requirements set forth in this plan ensuring full compliance by their respective staffs.

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ENuSlear GPUNC OPERATIONAL QUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 10CO-PLN-7200.01 AND OYSTER CREEK Title 1.0 Organization Revision 2 1.2 Director-THI Unit I and Oyster Creek Each of the Directors of the nuclear generating stations reports to the Office of the President. They are each responsible to cperate, maintain, and refuel their respective generating station in a safe, reliable and efficient manner in accordance with corporate policies and all applicable laws, regulations, licenses and technical require-ments. The Olvision Director-0yster Creek is the senior GPUN representative at Oyster Creek and as such assures consistent implementation of policies and procedures at the plant and at GPUN off-site facilities in the Oyster Creek area. The Olvision Director-TMI-I is the senior GPUN representative at the THI site and as such assures consistent implementation of policies and procedures at the plant and at GPUN off-site facilities in the TMI area.

1.3 Director - Technical Functions The Of rector-Technical Functions reports directly to the Office of the President. The Director's Quality Assurance plan responsibilities consist of providing the requisite engineering and/or technical support to: maintain the design basis of the nuclear plant; maintain the cor. figuration control documents; conduct operating experience assessment (s); provide nuclear fuel management; provide core performance monitoring; staff and direct shift technical advisors; analyse the technical performance and reliability of systems and components; provide selective review of plant operations and testing procedures, and associated training; provide technical control and coordination of plant modifications; and, conduct startup testing.

1.4 Olrector - Administration The Of rector-Administratico reports directly to the Office of the Prestcent. The Ofrector's Quality Assurance Plan responsibilities consist of establishing, maintaining, and implementing procurement, warehousing, training and education and plant securlty programs.

1.5 Director - Quality & Radiological Controls The Director-Quality & Radiological Cor,:rols raports directly to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of establishing and implementing uniform radiological controls, radiological environmental monitoring, emergency preparedness, and quality assurance plans, policies, practices and procedures sufficient to assure safe, reliable and efficient operation in accordance with Corporate Policies and all applicable laws, regulations and licenses.

16.0

') O 9 t% i

- GPUNC CPERATIONAL QUALITY ASSURANCE Number Nr~lar P'AN roa TNaee "t'e is'AND UNIT i AND OYSTER CREEK ioco-etN-7200.oi Title 1.0 Organization Revision 2 1.5.1 Ofrector - Quality Assurance The Director-Quality Assurance has the functional authority, independence and responsibility to assure the effective implementation of and compliance to the Quality Assurance Program.

Consistent with this responsibility is the authority to render interpretrtions in writing on those activities to which this plan applies and the extent to which the plan applies to those activities.

The Olrector-Quality Assurance reports directly to the Director-Quality and Radiological Controls. Addi tionally, The Director-Quality Assurance has direct unencumbered access to the Office of the President and the Directors of each of the nuclear stations with regard to quality activities. This reporting relationship has been established to provide the Quality Assurance organization with sufficient independence from the influence of costs and schedules to be able to effectively assure conformance to Quality Assurance Program requirements. Figure 2 identifies the Quality Assurance Department (QAD) sections.

The Director-Quality Assurance has no duties or responsibilities unrelated to Quality Assurance that would prevent his full attention to quality assurance matters. The Director-Quality Assurance has the authority and responsibility to:

a. Develop and administer the maintenance of the Operaticnal Quality Assurance Plan and the Quality Assurance Department procedures required to assure that all GPUN activities provide the required high degree of safety and reliability.

b. Audit, inspect and monitor the conduct of GPUN activities to assure that they provide the required high degree of safety and reliability and are carried out consistent with all applicable j laws, regulations, regulatory commitments, licenses, corporate policies and other requirements.

c. Provide welding, inservice inspection and nondestructive examination program develcpment and maintenance. Perform nondes tructive examinations.

d. Identify and report nonconformances as they may exist.

Initiate, recommend or provide solutions through designated channels. Verify implementation of resolutions,

e. Stop work or further processing, delivery or installation or take other comparable actions when warranted to control and/or prevent the use of nonconforming materials or continuance of nonconforming activities.

f. Initiate unit shutdown recommendations when warranted by a safety concern and obtain unit shutdown with appropriate upper-management concurrence.

17.0 3820L

Nu"lear cPuNc OPERATION ^t ouAtIrY AssuaANcE Ncmoer PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Ti tle 1.0 Organization Revision 2

g. Provide for a review of selected documents which prescribe methods for activities and quality requirements for items, parts and materials within the scope of this Plan.

h. Provide for a review for concurrence of Contractor and Vendor Quality Assurance Programs.

1. Provide for the QA review of selected design and engineering documents within the scope of this plan.

j. Provide for QA review of selected procurement documents within the scope of this plan.

k. Direct and manage the Quality Assurance Department.

1. Frovide a working interface and line of communication with other divisions and other appropriate industry and regulatory groups for all QA matters.

m. Provide indoctrination, certification, and/or training programs for the QA Department.

n. Assure QA indoctrination of appropriate personnel outside of the QA organization is provided.

o. Immediately notify the Office of the President and ar:propriate Unit Director of any significant quality related problem or deficiency.

p. Perform assessments on a planned and periodic basis to

comprehensively determine the effectiveness of the program and its implementation; and, cetect adverse trends as may be present,

q. Issue periodic reports to the Office of the President and Division Directors on the effectiveness of implementation of activities within the scope of this plan,

r. Provide for and maintain records generated by QAD until turnover to the record storage facility (s) for storage.

1.5.2 Minimum Qualifications of Quality Assurance Personnel The Director-Quality Assurance shall have, as a minimum, a baccalaureate degree in Engineering or Science, with at least fifteen (15) years of technical experience and ten (10) years of managerial / supervisory experience in nuclear power plant activities which require involvement in the assurance of the implementation of Quality Assurance Plan requirements. Additionally, the Director-Quality Assurance must be knowledgeable in operating license conditions, other regulatory requirements and commitments, plans, procedures and quality and technical staadards.

18.0

E Nuclear GPUNC CPERATIONAL QUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000-PLN-7200.01 AND OYSTER CREE < _

Title 1.0 Organization Revision 2 Quality Assurance Department Section Managers are required to have a degree in Engineering or Science and experience in a position (s) having responsibility for the supervision and performance of operational, technical and/or quality assurance activities. The degree requirament associated with these management positions may be waived for personnel with demonstrated exceptional capability and a minimum of ten (10) years of equivalent experience.

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

The qualification requirements and experience levels for other key Quality Assurance personnel are such as to assure competence commensurate with the responsibilities of and the Regulatory Guides associated with the activities performed by the position.

l.6 Director - Maintenance, Construction and Facilities

" rector-Maintenance, Construction and Facilities reports ly to the Office of the President. The Director's Quality

. ice Plan responsibilities consist of establishing, maintaining e :mplementing policies, practices and procedures for managing, planning and conducting all maintenance, repair, and construction activities; and to conduct all plant modifications, maintenance, repair, construction and welding activities as assigned in accordance with Corporate Policies and all applicable laws, regulations, licenses and technical requirements.

1.7 Corporate Secretary l The Corporate Secretary reports directly to the Office of the l President. The Corporate Secretary's Quality Assurance Plan l responsibilities consist of establishing, implementing and i

maintaining document distribution and record retention programs and facilities.

1.8 Director - Planning & Nuclear Safety The Director-Planning & Nuclear Safety reports directly to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of the maintenance of the of the nuclear plants' operating licenses and the establishment and conduct of nuclear safety assessment activities.

19.0

4 Nu21 ear GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title 1.0 Organization Revision 2 Figure 1 office of the President s

Direc tor D irec tor Oyster '

Director Director TM[ 1 Ovality &

Cre+k Planning &

Wadiological Wuclear Controls Safety Director Director Technical Director Corporate Administra t ion Maintenarce

, unctions Secretary Construction i 4 ,aci n ues f l

l l

l 20.0

Nualear aguNc ceERarloNat ou4tirr assua4Ncc sumeer PtAN FOR rHREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Tltie 1.0 Organization Revision 2 Figure 2 Director Quality Assurance Manager Manager Manager Special QA Design CA Program Processes & & Procurement Develevent Programs & Audit Manager Manager TMI QA OC QA Modifications / Modifications /

Operations operations l

1 l

l 71 A

~

r GPUNC OPERATIONAL QUALITY ASSURANCE Number l

Nuclear ,

, No PLAN FOR THREE MILE ISLAND UNIT 1 OYSTER CREtx 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 2.0 Quality Assurance Program 2.1 G_eneral '

This Operational Quality Assurance Plan is the highest GPUN document which provides the generic and some specific requirements and methods to control activities. The term "Program" as used herein includes this Plan and the approved documents which are used to implement this Plan.

This Plan is implemented through such approved documents.

The GPUN Quality Assurance Program has been established to control the activities performed by GPU Nuclear within the scope of this Plan. This control is exerted primarily through the provisten of and compliance with implementing documents and assurance that such documents are adequate and consistently used.

Adherence to the requirements of this Plan is mandatory for all GPUN organizations and for all external organizations providing items, parts, materials or conducting activities which are within the sccpe of this Plan.

The purpose and intent of this Plan is to establish the principles which, when implemented, will provide the level of management control and assurance which is appropriate for each item, part, material or activity within the scope of this Plan. It is recognized that the extent of management control and assurance to be applied varies with different items and activities, and the extent of applicability of this Plan tvill differ from item to item and activlty to activity.

The Director - Quality Assurance is authorized and responsible 'or determining if and to what degree this Plan applies to a given activity and/or task. In those situations where interpretation of the Plan is required to provide clarity or resolve disagreements, such interpre-trations shall be documented and approved by the Director - Quality Assurance.

l 2.2 Scope Tne scope of the GPUN Operational Quality Assurance Plan includes but is not limited to items and activities related to safe nuclear plant operation, protection of personnel and protection of the public. To ensure consistency in identifying those items, parts, materials and activities within the scope of this Plan, a classification process has been developed and documented. This process relles on the use of the terms "nuclear safety related," "regulatory required," and "QA Plan Scope."

22.0 3687L

\

l GPUNC OPERATIONAL QUALITY ASSURANCE Number g

gy PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 l

Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 2.2.1 Items to which this Plan applies are designated as "nuclear safety related" or "regulatory required." The definitions of these terms are provided in Appendix 0 of this Plan. A Quality Classification process for items has been developed. This classification process produces a Quality Classification List which identifies the permanent plant structures, systems, and components that are within the scope of this Plan and their specific classification. New items to which this Plan applies shall be added to the Quality Classification List subsequent to their installation.

The classification of parts, materials and consumable items (such as chemicals, radwaste liners, diesel fuel, etc.) and the technical and quality requirements will be specified, documented and approved as part of the procurement process.

This Plan may be applied to items, parts, and materials other than those designated as "nuclear safety related" or "regulatory required" as specified by GPUN management.

2.2.2 Activities to which this Plan applies are designated as within "QA Plan Scope." Activites that are within the scope of this Plan are those directly related to nuclear and radiological safety and protection of the public and are delineated below.

Support activities within the scope of this Plan are system / component /

part classification, operating expericace assessment, design, main-tenance of environmental and fire protection qualification, nuclear fuel management, procurement, fabrication, handling, shipping, storage, cleaning, erecting, installing, testing, repairing, training, welding, inservice inspection, heat treatment, document control, and records management.

Operational activities within the scope of this Plan are normal, abnormal and emergency ooeration, chemistry control, core performance monitoring, shift technical advice, equipment control, surveillance testing, inservice testing, maintenance, housekeeping, fire protection, security, radiological controls, radiological environmental monitoring, radwaste preparation for shipment, radwaste shipment, fuel handling /

refueling, technical specification compilance, and emergency preparedness.

Assurance activities within the scope of this Plan are audit, document review, nondestructive examination, inspection, monitoring, surveillance, and safety review.

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• GPUNC CPERATIONAL QUALITY ASSURANCE N SLAND UNIT 1 100 PLN-7200.01 Af D 0 ER EE Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 The above activities are controlled through the use of approved documents which are, as a minimum, consistent with the requirements of this Plan, the unit Operating License, specific Regulatory Guides to the extent listed and committed to in Appendix C of this Plan, the Final Safety Analysis Report, and other regulatory requirements and commitments. Those approved documents wnich specifically prescribe the methods to implement this Plan will be identified as prescribed by 3.2.2.2 of this Plan.

A scecific task (s) associated with the above activities will be classified as within scope of this Plan or not depending upon:

a. Statements within the text and the regulatory guides identified in Appendix C of this Plan;

b. The relationship of the task (s) t r> the safe operation of the nuclear plant;

c. The relationship of the task (s) to the protection of personnel from the effects of radiation;

d. The relationship of the task (s) to protection of the health itad safety of the public;

e. The relationship of the task (s) to regulatory requirements and commitments, and;

f. Other factors as may be specified by GPUN management.

2.3 Graded Approach The extent to which the requirements of this Plan and its implementing documents are applied to an item will be based upon the following:

a. The effect of a malfunction or failure of the item on nuclear safety or safe plant operation.

b. The design and fabrication complexity or uniqueness of the item.

c. The need for special centrols, surveillance or monitoring of processes, equipment and operational activities,

d. The degree to which functionality can be demonstrated by inspection or test.

e. The quality history and degree of standardization of the item.

24.0 3687L

GPUNC OPERATIONAL QUALITY ASSURANCE Number hdgy PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revisicn 2 The quality requirements for items shall be established using approved procedures based on the "General Logic Considerations" listed in the Appendix to ANSI N45.2.13-1976. Quality requirements will be estabilshed by the responsible department and reviewed by the Quality Assurance Department consistent with Appendix 8 of this Plan.

The extent to which the requirements of this plan apply to activities will be based as a minimum on operating license conditions and other plans previously submitted to the NRC for approval, other regulatory commitments as may have been made associated with activities, the text of this Plan, the unit's technical specifications, and Appendi< C of this Plan. Such other plans or regulatory commitments include but are not limited to those associated with emergency planning, physical plant security, safeguard contingency planning, radiological controls, radiological environrrental controls, fire protection, inservice inspection, inservice testing, licensed operator qualification and requalification, process control, offsite dose calculation, shift technical advisor training, environmental qualification of electrical equipment, security guard training and qualification, etc.

2.4 Three Level Assurance Approach GPUN is committed to a comprehensive assurance process consisting of a three level approach to assure consistent and complete implementation of this Plan.

2.4.1 Level I - Activities at this level include inspections, checks, or tests performed for the purpose of establishing acceptance and/or verification of items and activities within the scope of this Plan.

Level I activities are performed by the Quality Assurance, Operations, Plant Maintenance, Radiologicai Controls, Maintenance, Construction and Facilities, Technical Functions, and contractor personnel. Where the first-level activities involve independent inspection for purposes of l acceptance and/or verification, the activity will be performed by the CA Department or by organizations authorized to perform those activities by the QA Department.

l Operations, Plant Maintenance Maintenance, Construction and i Facilities, Radiological Controls, and Startup and Test personnel l perform activities such as tests, calibration of instruments,

) radiation surveys, analyses of samples, valve line-ups, etc.

Guality Control cersonnel perform receipt inspecticn and checks and l Inspections of mcdifications and maintenance activities.

Contractors perform inspections as applicable to their scope of work.

Technical Functions personnei periodically perform walkdowns.

cbservations, measurements, etc. to revalidate the physical or functional configuration or condition of plant systems or components.

25.0 3687L

GPUNC OPERATIONAL QUALITY ASSURANCE Number

'gggy PLAN FOR THREE MILE TSLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PRCGRAM Revision 2 In all cases, the inspection, check and testing activities are performed by individuals who are knowledgeable of the activity being performed and are qualified to perform the work (refer to Section 6.2). Checklists, weld history records, travelers, reports, etc., are used for documenting the results of the activity and for providing a record of the performance of the activity.

2.4.2 Level II - The activities at this level are primarily those of survey, surveillance, monitoring, and document review and are performed as deemed necessary by the QA Modifications / Operations or QA Design and Procurement Sections. The level of surveillince or monitoring applied is consistent with the importance of the item to safety and the extent of administrative controls utilized for the Level I activity. For activities where GPUN Quality Control is performing first-level inspection, no second-level activity is required.

At this level, procedures and instructions are established and surveillance and/or monitoring records will be completed and maintained. Such surveillance / monitoring normally includes observation of tests and inspections, observation of selected operations, review of records, verifications of test reports, and direct inspection on a spot-check basis. The organizations performing this activity have the levels of authority, the lines of internal and external communication, management direction, and properly trained personnel for implemeiitatico of these activities.

2.4.3 Leve' III - The purpm e of this level of activity is to assure, through a comprenensive program of review and audit, that the first and secono levels of the program are properly functioning, and that all organiza-tions conducting activities within the scope of this Plan are properly satisfy!ng all the requirements of the Operational Quality Assurance Program.

At this le9c.l. procedures and instructions are established, including the use of comprehensive checklists or detailed reports for documenta- l tion of the audit or third-level activity. The program requirements of ANSI N45.2.12 shall be satisfied. Lead auditors shall be utilized who are quallfled to the requirements of ANSI N45.2.23. Additional technical suppor t personnel, frcm areas with administrative reporting outside the function that is being audited, will be utilized as Audit Program Management deems necessary. The organization performing this audit activity has sufficient authority, independence and lines of internal and external communications to obtain the necessary access tc management to conduct the review and audit, resolve any issues which may arise from the review and audit and secure additional technical support for the performance of audits as may be required.

26.0 3687L

GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear P'^" roa tsaer "tu ts'AND uNIr i iOOO.PtN.,200*Oi AND OYSTER CREEK Tltle 2.0 QUALITY ASSURANCE PROGRAM Revision 2 2.5 Operational Quality Assurance Plan Control This Plan is authorized by the Office of the President and requires that the appropriate levels of management, as designated herein, implement the Program. This Plan is controlled to ensure that only the latest approved revision is implemented. This Plan is implemented through approved documents (refer to Section 3.0).

Appendix A provides a correlation of the sections of this Plan with the requirements of 10CFR50 Appendix 8; 10CFR71, Subpart H; ANSI N45.2; and ANSI N18.7.

With the exception of Section 1.0 and Section 2.0, each section of this Plan contains three major subsections:

General - A summary description of the general approach of GPUN with regard to controlling the specific subject (s) of the section. It characterizes the intent of the section by stating the overall objectives to be met and/or the results to be achieved.

Requirements - A description of the requirements applicable to the specific subject of the section.

Responsibilities - Identification of those organizations and their responsibilities relative to the specific subject of the section.

2.5.1 Approval This Plan shall be originated by the Olrector-QA and be approved by the Office of the President after being reviewed for concurrence by the following:

Director - OCNGS Director - THI Unit 1 Director - Technical Functions Director - Administration Director - Quality and Radiological Control Director - Maintenance, Construction and Facilities Corporate Secretary Director - Planning and Nuclear Safety 2.5.2 Revisions The Director - Quality Assurance, with the assistance of the Licensing and Regulatory Affairs Director, shall, for each revision to this Quality Assurance Plan, determine if the changes do or do not reduce the commitments in the Operational Quality Assurance Plan previously i

accepted by the NRC.

l l

27.0 3687L

GPUNC CPERATIONAL QUALITY ASSURANCE Number g gp PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 Revisions to the Quality Assurance Plan that do not reduce the commitments in the Operational Quality Assurance Plan previously accepted by the NRC shall be originated by the Director Quality Assurance and approved by the Office of the President with the concurrence of the Director - Quality and Radiological Controls and any Division Director affected. Revisions of this type do not require approval by the NRC prior to implementation, but must be submitted to the NRC at least annually. The Cover Page containing the approval and concurrence signatures of the Office of the President and the Divisicn Directors shall not be modified. The Record of Change page will be utilized to identify the changes and document the concurrence and approval.

Revisions of this Operational Quality Assurance Plan that reduce the commitments in the Operational Quality Assurance Plan previously accepted by the NRC shall be submitted to the NRC and receive NRC approval prior to implementation. Such revisions shall be regarded as approved by the NRC upon receipt of a letter to this effect from the appropriate reviewing office or 60 days after submittal to the NRC whichever comes first. The submittal of the revision to the Quality Assurance Plan must include all pages affected by that change and must be accompanied by a transmittal letter identifying the change, and the basis for concluding that the revision continues to satisfy 10CFR50, Appendix B and to provide a suitable level of control. The letter need not provide the basis for changes that correct spelling, punctuation, or editorial items. A copy of this letter must be maintained as a facility record for three years. Revisions of this type shall be originated by the Director - Quality Assurance approved by the Office of the Presidert with the concurrence of the Division Directors as indicated by their signctures on the revised Cover Page.

2.5.3 Distribution Copies of the Operational Quality Assurance Plan may be distribut6d a: l "Controlled" or "Uncontrolled" in accorde.nce with the requirements established in Section 3.

2.5.4 Effective Date of Implementation Changes to this Plan shall be incorporated in the implementing documents within 60 days of the issuance date of the Plan unless an l Interim action plan is defined and approved by the Director - Quality Assurance.

2.6 Quality Assurance Program Review The effectiveness of the implementation of the QA Program is evaluated '

and reported by the QA Department through the auditing, monitoring, and surveillance functions. The results are reported to the GPUN Board of Directors, Office of the President, and Division Directors. The divisions provide additional evaluations as appropriate.

28.0 3637L

! GPUNC OPERATIONAL CVALITY ASSURANCE Number Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 In addition to the assurance activities performed by the QA Department, the Office of the Pre:Ident shall have, at least once per year, an independent assessment performed of the QA Program implementation to assure that the QA Program is effective in ensuring that regulatory requirements and commitments and GPUN policies are met. This assessment may be performed utilizing the safety review groups, an independent consultant, representatives of other utilities and/or his own staff. Any corrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution.

2.7 Indoctrination and Training Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are required to be established and maintained. Training departments are established and staffed at the Corporate office and at each plant site. These training departments are each responsible for planning, scheduling and providing training to GPUN personnel . The specific needs, the subject material to be covered and the specific means to deliver (e.g., on the job, classroom, etc.), the indoctrination and training programs are established by both on-site and off-site organizational units responsible for the performance or verification of activities within the scope of this Plan. These training programs are developed, implemented and maintained as delineated in Section 9.0 of this Plan.

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

l Items within the scope of this Plan shal! be ciassified and identified as "Nuclear Safety Related" or "Regulatory Required." A procedure (s) shall be prepared to establish, implement and maintain a classification process for items. This procedure (s) and changes thereto shall be reviewed for concurrence by the Director - Quality Assurance prior to l issuance.

Structures, systems and components, but not parts thereof, shall be

identified on a Quality Classification List (QCL). A QCL shall be l established and maintained, by Technical Functions, for each plant.

l The classification of structures, systems and components will be subject to independent design review as part of the classification process.

r 29.0 a687L L

GPUNC CPERATIONAL QUALITY ASSURANCE Number Nuclear Puu rca mRee Mite ISue uuri i nNO OYSTER CREEK iOx a Na2*.0i Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts and materials that perform or contribute to the performance of a nuclear safety-related or regulatory required function are within the scope of this Plan and classified similarly as the component of which it is a part. For procurement of spare or replacement parts which are of a different classification, the classification will be determined by Plant Engineering or Technical Functions. The determinations will be documented, reviewed by Quality Assurance consistent with Appendix 8 of this Plan, and retained. Refer to Section 5.0 for specific requirements.

2.9 Records of Regulatory Commitments Records of regulatory commitments are maintained by Licensing and Regulatory Affairs. Appendix C herein lists those Regulatory Guides which contain specific quality assurance requirements with the stated GPUN position, exceptions and/or clarifications provided. Appendix C will be revised, as necessary, to reflert any change in the GPUN commitment to the Regulatory Guides.

2.10 Safety Reviews The safety review program involves four major elements:

2.10.1 The first element of the safety review program consists of technical review and, as necessary, an independent safety review.

The technical review is a thorough review conducted by someone other than the individual who prepared the work. This review is performed by a quallfled Responsible Technical Reviewer on documents and substantive revisions of documents as specified by the GPUN Review ano Approval i Matrix.

The independent safety review is an independent review of documents and substantive revisions of dccuments as specified by the GPUN Review and Approval Matrix. It incluces a review of a safety evaluation. This l review is conducted by a qualified Independent Safety Reviewer on l Safety evaluations associated with documents and substantive revisions l to documents as specified by the GPUN Review and Approva'. Hatrix. The

) ISR shall not have direct responsibility for the activitj reviewed.

30.0 3687L /

GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 2.10.2 The second element of the safety review program is the Independent On-Site Safety Review Group (IOSRG). An IOSRG shall be located at each generating station. The IOSRG has no line responsibilities or line functions and is devoted solely to safety matters. It is independent of the plant staff and reports off-site to the Nuclear Safety Assessment Olrector. Each IOSRG will consist of a Manager, Nuclear Safety who reports to the Nuclear Safety Assessment Director and a minimum staff of three members, each of whom shall have an academic degree in engineering or a physical science field and 3 years of professional level experience in the nuclear power field including technical supporting functions or 8 years of appropriate experience.

Credit toward experience will be given for advanced degrees on a one-to-one basis up to a maximum of two years.

Each IOSRG shall have access to the Unit and unit records as necessary to perform its evaluations and assessments. Based on its reviews, the 10SRG shall provide recommendations to the management positions responsible for the areas reviewed. 10SRG reports of evaluations and assessments shall be prepared, approved, and transmitted to the Nuclear Safety Assessment Director, Director - Planning and Nuclear Safety, and the management positions responsible for the areas reviewed. l 2.10.3 The third element of the safety review program is the review by the Nuclear Safety Assessment Department (NSAD).

NSAD is an independent organization reporting to the Ofrector -

Planning and Nuclear Safety.

In addition to overseeing the IOSRG, the Nuclear Safety Assessment Department, through its headquarters staff, will assess all aspects of l GPUN activities as well as developments elsewhere in the nuclear industry. It shall provide the following safety review functions:

l

a. An overview of activities affecting or potentially affecting safety. This is a broadly defined responsibility which involves no specific tasks thus making it possible to assess the adequacy of the entire safetj review program and identify areas for

! Improvement.

l l b. A Corporate Ombudsman accessible on a confidential basis to anyone in the company having a nuclear or radiation safety concern he or she considers is not being adequately addressed. The Ombudsman is empowered to investigate such matters, identify any needed action and seek its resolution. The Cmbudsman will reply to the individual who raised the matter.

31.0 3687L

GPUNC OPERATICNAL CUALITY ASSURANCE Number Nuclear

" u" f0R THREE Mi d I M UNIT 1 1%0AN-72%.01 AND 0/ STER CREEK Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 2.10.4 The fourth element of the safety review program is the General Office Review Board. This is a group of senior level individuals with diverse backgrounds. It reports to and takes general direction from the Cffice of the President but has direct acces: to the Chief Executive Officer and the Board of Ofrectors. Its cnarter is broadly defined to enccmpass all matters potentially affecting nuclear safety so as to foresee potentially significant nuclear safety and radiation problems.

2.11 Responsibilities 2.11.1 Office of the President The Office of the President - GPUN is responsible to regularly assess the scope, status, adequacy and compliance of the Quality Assurance Program to the requirements of ICCFR50. Appendi x 8,10CFR20, and 10CFR71, Subpart H. This assessment shall be the combined rescit of:

a. Review of audit reports, periodic status reports, etc. on the effectiveness and implementation of the Quality Assurance Program.

b. Derformance at least once a year of in assessment of the effectiveness of the Quality Assurance Program to assure that this program ensures compliance with regulatory requirements, commitments and GPUN policies. This assessment may be performed utilizing the safety review groups, an independent consultant, representatives from other utilities and/or the President's own staff.

Any corrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution.

2.11.2 Director - Quality & Radiological Controls The Director-Quality & Radiological Controls has overall responsibility for establishment of the GPUN Ooeraticnal Quality Assurance Plan. The Director shall provide periodic status reports to the Office of the ~~ ~,_

President en tne effectiveness and implementation of~~~~~ tne Qutlly i

Assurance Program. ,___

~~'

2.11.3 Director - w ' y Kisurance The Olrector-Quality Assurance has the authori ty and responsibility to verify the effective implementation of this Quality AssJrance Plan.

This responsibility is principally discharged through the review of documents which implement this Plan, the verification that such documents are effectivel/ and consistently inplemented, and providing the requisite leadership to assure tnat required corrective action is promotly defined and implemented.

32.0 3687L

'GPUNC OPERATIONAL QUALITY ASSURANCE jggy PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Numoer 1000-PLN-7200.01 Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 The Director-Quality Assurance shall establish and implement a formally documented and procedurally controlled process to evaluate and report to the Director-Quality & Radiological Controls on the adequacy and continued effectiveness of this Plan and its implementation. The basis for the evaluation reports to the Director-Quality & Radiological Controls includes reports of audits; monitoring of station activities; evaluations of suppliers, source surveillance of equipment suppliers; audits of external service organizations; and quality trend analyses based on nonconformance and deficiency reports and reports of inspections, examinaticns, surveillance / monitoring and audits. These actions may involve specific actions to provide compliance with this Plan and may include follow-up audits and revision to the Quality Assurance Program.

The Ofrector-Quality Assurance is responsible for the content of this Plan and for ersuring that the Plan is modified and updated as regulations and experience dictate. Proposed revisions to this Plan l

may be suggested by GPUN personnel by submitting the request, in writing, to the Director-Quality Assurance for review and action.

2.11.4 Director - Technical Functions The Director-Technical Functions is responsible for development and maintenance of the Quality Classification List. l 2.11.5 Director - Planning and Nuclear Safety The Director-Planning and NLclear Safety through Licensing and Regulatory Affairs is responsible for providing GPUN documented positions on all other regulatory guides not contained in Appendix C of this Plan as may be required.

2.11.6 GPUN - Management Management personnel in each division are responsible for the l implerrentation of the Quality Assurance Plan by their division, department or group, including the development and implementation of approved documents; and, the training and Indoctrination of their personnel associated with those of their activities within the scope of this Plan.

Management personnel in each division are responsible for the conduct of the technical and independent safety reviews althin their division, departTent or group. This includes the identification and qualifica-tien of persennel as Responsible Technical Revleaers and Independent Safety Reviewers; the review and approval of docurrents within their functional area of responsibility as assigned by the CPUN Revied and Approval Matrix and other activity as may be required to implement Technical Specifications Appendix A, Section 6.5, requirements.

33.0 3637L

'GPUNC OPERATZONAL QUALITY ASSURANCE Number

- gdgy PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title 2.0 QUALITY ASSURANCE PROGRAM Revision 2 Management personnel in each division are responsible to take positive action to evaluate and correct nonconformances identified in the conduct of those of their activities within the scope of this Plan.

This responsibility to correct includes adverse trends as may be identified by apprcpriate analysis.

2.11.7 External Organizations Suppliers who provide items, parts, materials, consummables, and/or services which are within the scope of this Plan shall have a QA Plan and implementing procedures appropriate for the items, parts, materials, consummables, and/or services. The supplier's QA prog am shall be subject to review for concurrence by the Director-Quality Assurance or his designee. The extent to which the supplier's QA program will be applied will be specified by procurement documents.

2.11.8 Resolution of Discutes and Escalations Disputes involving quality arising from a difference of opinion between QA/QC personnel and another organization (s) (engineering, procurement, manufacturing, construction, operation, maintenance, etc.) personnel shall, if possible, be resolved at the level at which such disputes occur. If this is not possible, the difference of opinion shall be escalated through supervisory / management levels until resolution is achieved.

The Director-Quality Assurance shall make the decision on matters related to if and to what degree this Plan applies to activities, quality requirements, and verificaticn and acceptance to established requirements.

The Director-Technical functions shall make the decision on matters related to classification of items, garts, materials, and technical requirements.

The Director-Quality Assurance shall be responsible for evaluating deficiencies for trends. Significant or repetitive failures to ccmply with administrative, technical, operational or this Plan's requirements will be further evaluated to determine the safety significance of the condi tion. In these cases, management of the organization shall be notified of the condition and shall be afforded an opportunity to take approorlate corrective action. If this action is not taken, a Stop Hork Notificaticn will be issued.

34.0 3687L

GPUNC CPERATIONAL QUALIT/ ASSURANCE Numcer El%lLJiCiltB4Bir' PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 3.0 CONTROL OF DOCUMENTS AND RECORDS Revision 2 3.0 CONTRO.L OF DOCUMENTS AND RE. CORDS 3.1 _ Policies, Plans, Procedures, Instructions, Drawings, 50ecific3tions 3.1.1 Ceneral Activities which are within the sccpe of this Plan sb111 be prescribed by documents of a type appropriate to the circumstances.

These documents shall be complied with in the performance of the activity or changed prior to proceeding with the activity. These documents typically include but are not limited to those termed plans, procecures, instructions, directives, drawings and specifications. All personnel shall be indoctrinated in the use or content of such documents prior to commencement of the activity.

3.1.2 Requirements Documents which prescribe the methods for the performance of activities within the scope of this Plan shall be consistent with the requirements of this Plan. These Plan requirements include compliance with the text of this Plan and the Regulatory Guices and ANSI standards to the extent delineated in Appendix C. To eccomplish this, these cocuments shall:

a. Define the responsibilities and authorities of personnel performing the activity.

b. Describe interfaces between GPUN organizational units and/or external crganizations that participate in or are affected by the conduct of the activity.

c. Prescribe actions to be taken or the results to be achieved which are consistent with the requirements of this Plan,

d. Include quantitative (such as dimensions, tolerances, ana operating limits) and/or qualitative (such as workmansnip) acceptance criteria sufficient for determinirig that such activities have been satisfactorily accomplished.

l

e. Identify and specify the content of records to be generated in conducting the activity.

l

f. Include references a: 16eded to implement the activity. When such references are utilized, the specific requirements of the references which are applicable shall be identified or I

incorporated into the document.

i 35.0 3314L

. GPUNC OPERATIONAL QUALITY ASSURANCE Humber J

Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 3.0 CONTROL OF DOCUMENTS AND RECORDS Revision 2

g. Se approved and concurred with by responsible personnel prior to the initiation of the activity.

h. Be distributed in a controlled manner to preclude the use of obsolete documents and with sufficient number of copies to assure availab!11ty to responsible personnel.

Reviews of such documents shall be conducted by the Quality Assurance Department (QAD). The timing of QA document reviews shall be as detailed in Appendix 8. These OAD reviews are conducted to independently verify that the document is apprcpriate for use. These QAD reviews assure, as a minimum, that the reviewed document is consistent with the pertinent QA Plan requirements; contain inspection and verification requirements where applicable; contain quantitative and/or qualitative acceptance criteria; contain clear definition of the extent of documenting results of completed actions when required; and, has been (after implementing approval) prepared and reviewed consistent with QA Plan requirements;.

Documents which prescribe methods for implementing this Plan shall be followed as written or changed. The requirements for use of such documents and how to proceed if such documents cannot be compiled with as written shall be prescribed by procedure (s).

Plans, procedures, and instructions shall be revised as needed to ensure that such documents can be implemented as written. Appropriate documents shall be thoroughly reviewed following plant transients, incidents, and/or events and revised as needed. Such documents shall be reviewed by an individual knowledgeable in the area affected by the document (s) no less frequently than every four years to determine if cnanges are necessary or desirable. A revision of the document (s) may constitute the above review provided the results of the review are documented.

3.1.3 Responsibilities 3.1.3.1 Department Managers The Director or Manager of each department performing activities within the scope of this Plan is responsible for tne preparation, approval and implementation of documents which prescribe actions necessary to effectively implement this Plan. This responsibility includes ensuring that provisions are made for interface controls for internal and ext?rnal lines of cenmunications among participating I organizations and technical disciplines.

36.0 3814L 0

GPUNC CPERATIONAL CUALITY ASSURANCE Nuclear PLAN FCR THREE MILE ISLAND UNIT I AND OYSTER CREEK Numcer 1%04N-H%.m Title 3.0 CONTROL OF CCGMENTS AND RECOROS Revision 2 3.1.3.2 Qualltv Assurance Department (QAD)

QAD shall review those documents wnich prescribe the methods of complying with the reputrements of tnis Plan. When specifi9d in i procure'nent documents, contractor and vendor Quality Assurance Plans / Manuals, special process orocedures, and inspection and test procedures shall be reviewed for concurrence by QA0 prior to l authorizing the contractor or supplier to start work.

3.1.3.3 External Organizations Those an activities external within the scope of this Plan which ?re performed by organizaticn(s) shall be prescribed by approved documents (s). The extent and type of such approved documents to be utilized by the external organization shall be prescribed within approved procurement documents. Compliance shall typically be verified through audit or survalliance.

3.2 Occument Control 3.2.1 General Document control procedures shall be established to control and coordinate the classification, review, approval, issuance, revision, and change of approved documents which prescribe methods or provide the technical requirements for acti/ities and items within the scope of this plan.

These document control procedures shall ensure that such documents are reviewed for adequacy, approved for release and use, and distributed to the location where the activity is performed.

3.2.2 Requirements 3.2.2.1 Written document cort ol procedures shall be established to provide i for the control of the following types of documents:

a.

Operational Quality Assurance Plan, GPUN Organization Plan, GPUN Review and Approval Matrix, Qut.lity Classification List.

Enviro, mental Qualification Master List (s), and Supplier Quality Classification List (s).

b.

Plans, p*ocedures, directt'/es, and/or instructions as rec,uired to implement the provisions of this Plan and the Regulatory Guides to the extent delineated l' Appendix C.

c. Quality Assurance Ceoartment Plans, Procedures, and Standards.

L 37.0 3814L

Nuclear

. 'GPUNC OPERATIONAL QUALITY ASSURANCE Numler

, '^" roR 7"REE MtLE ISLAND UNIT i i OOO.glN. m . ,i

.AND OYSTER CREEK Titie 3.0 CONTROL OF 00CUMENTS AND RECORDS Revis1on 2 d.

Oper& ting, Surveillance Testing, Refueling and Equipment Control Procedures and Instructions.

e.

Maintenance Work Authorizing Documents, Procedures. Instructions, Vendor Manuals and Vendor Information, f.

Engineering Configuration Control documents which inc % saf(ty analysis, safety evaluations, calculations, standards, specifications, system / modification design descriptions, design reviews and/or verifications, drawings and lists.

g.

Computer codes utilized for calculational tasks associated with activities within the scope of this Plan.

h.

Engineering, Manufacturing, Construction, Modification, Installation, Welding, Test, Inspection and Nondestructive Examination Procedures, Instructions, Standards, and Specifications.

1.

Procuroment Documents, Specifications, and Contracts.

j. Final Safety Analysis Reoort(s), Fire Protection Plan (s). Fire Hazards Analysis Report (s), Emergency Plan (s), Security Plan (s),

Safeguard Contingency Plan (s), Guard Force Training and Qualification Plar's) and Offs 1te Oose Calculation Manual (s).

k.

Nonconformance, Deficiency and Deviation Reports or Reques ts.

1. Operating and Special Orders.

m.

Procurement and Material Control Procedures and Instructions.

n.

Radiological Control, Process Control, Radiological Environmental Monitoring, Radwaste Shipping and Chemistry Control Plans, Procedures, Instructions, Standards, and Specifications.

3.2.2.2 Procedures established for document control shall prescribe the following requirements:

a.

Drawings, design descriptions and specifications for items, parts, and uaterials des:gnated as Nuclear Safety Related shall be marked as such.

b.

Documents which prescribe how to perform activities within the scope of this Plan shall be marked as within "QA Plan Scope" These documents typically will be those termed plans, procedures, instructions, and Jirectives. Specifications and drawings will be marked as stated in 3.2.2.2.a above.

38.0 3814L

- Nuclear GPUNC OPERATIONAL QUALITY ASSURANCENumber P'AN FOR TsREE srtE iSue uNir i

.AND OYSTER CREE < ioco.glN_noc o, iltie 3.0 CONTROL OF DOCUMENTS AND RECORDS Revision 2 c.

Review and approval requirements for documents and their  !

revisions shall be specified to ensure that appropriate, technical and quality requirements are incorporated prior to issue.

Issuance requirements shall be specified to ensure adequate dissemination for use.

d.

The organizations or positions resconsible for reviewing, approving specified. and issuing documents and their revision shall be e.

Revisions being shall be documented, approved, and issued prior to implemented.

Temporary changes shall be reviewed and approved consistent with Technical Specification requirements.

f.

Revisions and changes shall be reviewed and approved by tne same organizations that performed the original review and approval or by organizations designated t,y the originating organizations outside GPUN.

except for documents originated by organizations In this case, GPUN may designate the review and approval organizations.

Approved changes shall be promptly transmitted for incorporation into documents and obsolete or superceded documents shall be eliminated from uso.

g.

Document distribution shall be sufficient to assure that the documents to commencementare readily of work,available to responsible personnel prior l h.

The user of approved documents is responsible for assuring that the latest issue of the document is being used to perform work, thusused.

not assuring that voloed, superseded or obsolete documents are Master lists or indices which identifv current revision status of approved documents will be maintained to assist users. In addition to master lists or indices, documents may be stamped "Controlled Copy" Holders of controlleo documents or master lists are responsible for maintaining their assigned copies in a current status.

stamped as information only will not teDocuments considered distributed and to be l current, and, as such, will not be used in performing an activity within the scope of this Plan. I i.

In the special case of documents contlining information portaining to plant security, provisions shall be made to prohibit unauthorized disclosure of certain safeguards information. These provisions shall include identification of the documents, restrictions on tnetr dist'ibution and storage in locked security storage containers.

3814L 39 0 l -

jGPUNC GPERATIONAL QUALITY ASSURANCE

Nuclear g"ggggg MIu tsuNo uNii i gNumbr gn.noo.0, Title 3.0 CONTROL OF DOCUMENTS AND RECORDS Revision 2 3.2.3 Responsibilities 3.2.3.1 Corcorate Secretary I Responsible via the Information Management Center Managers to establish and maintain approved documents to implement the GPUN Document Control Program.

3.2.3.2 Director - Administration Responsible procedures to develop and administer a corporate policies and systen.

3.2.3.3 Director - Quality & Radiological Controls Responsible via the Director-Quality Assurance for the review of GPUN document control procedures and the evalt4 tion of the overall document control system effectiveness through document review to the extent described in Appendic B and audit.

3.2.3.4 All Functional Managers / Supervisor Responsible to provide specific docurent control procedures, as required, to Ircolement the corporate document control policy.

Responsible to ensure that documents are available when required; to properly review and approve documents such as procedures, instructions, specifications, drawings, etc. to ensure that changes to documents are reviewed and approved by the same organization that performed the original review and approval of the document; to ensure that approved changes are promptly transmitted for  !

incorporation into documents; to ensure that obsolete or superseded documents are eliminated from use.

3.3 Records 3.3.1 General Records related to items, parts, materials and activities within the scope of this Plan shall be identified, reviewed, retained, and retrievable. These requirements are imposed on all organizations performing activities within the scope of this plan. Records shall be described and controlled by approved written procedures or instructions. As a minimum, these procedures or instructions shall address the identification, generation, collection, storage, maintenance, retention, and retrieval of such records.

l l

3814L 40.0 l

t

GPUNC CPERATIONAL QUALITY ASSURANCE 4 Numb:r

Nuclear n^"gggg,E sIu ISue UNIT > icco m N_ m o 0, Title 3.0 CONTROL OF DOCUME4TS AND RECORDS Revision 2 3.3.2 Recuirements Approved documents shall bi established for the identification, l gereration, collection, storage, maintenance, retention and retrieval of records and shall provide for the following minimum requirements:

3.

Design specifications, procurement documents, and/or GPUN procedures shall specify the records to be generated, supplied and maintair.ed by or for GPUN, including retention times.

Typical records to be specified include operating logs, maintenance and modification procedures and related inspection results, reporta0le occurrencet, inspection and verification procedures (excluding completed checklists when results are documented in a separate report), results of reviews, inspections, tests, audits, and material analysis; qualification of personnel, procedures, and equipment; other i documentation such as calculations, computer codes, design verifications, drawings, specifications, proctrement documents, calibration procedures and reports; nonconformance reports; corrective action reports; and other records required by Technical Soecifications.

b.

Sufficient records shall be maintained to provide evidence of the acceptability of items, parts, materials or activities within the scope of this plan. Inspection and test records shall contain the following where applicable:

1. Identification of the type of observation.

2. The date and results of the inspection or test.

3. Identification of any conditions adverse to quality.

4. Inspector or data recorder identification.

5. Evidence as to the acceptability of the results.

6. Action taken to resolve any discrepancies noted.

c.

Record storage facilities shall be established and util! Zed to prevent destruction of quality records by fire, flooding, theft and deterioration by environmental conditions such as temperature or humidity in compilance with the standards, codes and regulatory guides endorsed in Appendl< C of this Plan.

l d.

All records shall be legible in original or reproduced form.

41.0 3814L

'GPUNC CPERATIONAL QUALITY ASSURANCE 1 Nuclear ,"g"JUMHEFEtS'^" " " " '

I Number

'o" -*'"-72

• o' Title 3.0 CONTROL OF DOCUMENTS AND RECCROS Revision 2 3.3.3 Responsibilities 3.3.3.1 Director - Quality & Radioloolcal Controls TheOf the Director-Ouality & Radiological rector Quality Assurance, fer: Centrols is respo,sible through a.

Reviewing procedures related to the identificaticn, generation, collection, records.

retention, storage, retrieval, and maintenance of b.

Establishing procedures and/cr instructions for the identification, generation, collection, retention, storage, retrieval, and maintenance of records generated by QAO, until they are turned over for storage.

c.

Performing planned and pericdic audits to verify the effective implementation of records requirements by both GPUN internal organizations and suppliers cf services.

d.

Performing source surveillance or receipt inspection to verify that required records nave been generated and supplied with items, parts or materials.

3.3.3.2 GPUN Division Directors Each Division Director is responsible for:

a.

The identification, generaticn, collection, maintenance, and storage of records in accordance with approved written procedures or instructions which conform to the requirements of this section until sucn time as they are transferred to the applicable Information Management Center for storage.

b.

Providing direction in implementing documents to ensure the identification and generatten of records with sufficient detail to furnish CDjective evidence that activities within the scope of this Plan were conducted in ccmpliance with the standards, codes and regulatory guides endorsed by this Plan.

3.3.3.3 Corporate Secretary The Corporate Secretary is responsible through the Informaticn Management Center Managers for:

a.

The collection, maintenance, and storage of records and record storage facilities / mediums in accordance with approved written procedures and instructions which conform to the requirements of this section.

3814L 42.0

l GPUNC OPERATIONAL CUALITY ASSURANCE

. Nuclear .

PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Number 1000-PLN-7200.01 Title 3.0 CONTROL OF DOCUMENTS AND RECCROS Revision 2 b.

Providing procedures and/or instructions which ensure the retrievability of records.

1 c.

Establishing and.imelementing the GPUN Records Control System.

3.3.3.4 External Organizations Records generated by suppliers shall be controlled according to the supplier's or GPUN procedures until such time as they are turned over to the GPUN for review, acceptance, and transmittal to the permanent records file.

Purchased equipment records snall be retained by the vendor until the eaulpment is released for shipment at which time the records required by procurement documents are to be submitted to GPUN.

When required by the procurement documents, contractors and vendors shall establish procedures to control records. Implementation of these procedures shall be assured by performance of source surveillance, monitoring and audits performed by QAD.

Records to be submitted with the shipment or retained by the vendor will be specifically identified in procurement documents. If records are to be retained by the external organization for GPUN, then the storage condition and retention period shall be specified in the procurement document (s).

These records will be reviewed by QAD and/or Engineering to provide the required degree of confidence i in the adequacy of compliance of the vendor with the requirements of this section.

43.0 3814L

ENuclear GPUNC OPERATIONAL CUALITY ASSURANCE

,gN gH P

e MILE ISLAND UNIT 1 Number 1000-PLN-7200.01 Title 4.0 Design Control Revision 2 4.0 DESIGN CONTROL 4.1 General Measures shall be established and documented to assure that the appilcable specified design requirements, such as design cases, regulatory requirements. codes and standards are correctly translated into soecifications, drawings, procedures or instructions. These measures shall include provisions to assure that appropriate quality standards are specifled and included or referenced in design documents for design of systems and structures.

4.2 Requirements Design control measures require that:

4.2.1 The organizational structure be defined, and authority and responsibility of personnel involved in preparing, reviewing, approving and verifying design documents be delineated.

4.2.2 The design bases, safety analysis, regulations, codes and standards and Plant Technical Specifications including all effective amendments will be utilized in, reviewed for revision, and revised, as necessary, during the design process.

4.2.3 The materials, parts and processes selected by design are reviewed to. assure that they are suitable for the intended application, including compatibility of materials, accessibility for laservice inspection, maintenance and repair, ALARA Considerations, personnel safety, fire hazards analysis, and quality standards. The review will also evaluate suitability with regard to human factors which may affect safe operation and the suitability of commercial grade materials, parts and equipment to the application.

4.2.4 Internal and external design interface controls, procedures, and lines of communication among participating design organintions and across technical disciplines are established and described for the preparation, review, approval, release, distribution, and revision of documents involving design interfaces.

4 ?.5 Errors and deficiencies in approved design documents, including design methods (such as computer codes) that could adversely affect items and activities within QA Plan scope shall be documented, and l action shall be taken to assure that these errors or deficiencies are corrected. In addition, any errors or deficiencies resulting from the application or use of the design documents shall be identified and corrected.

t 44.0 3815L

GPUNC OPERATIONAL QUALITY ASSURANCE ' Numb YUClear R QANgTERCREEK 0 7200.01 Title 4.0 Design Control Revision 2 4.2.6 Deviations in specified quality standards shall be identified and procedures shall b) control. established to assure their resolution and 4.2.7 Review of commercial grade items for suitability of use in structures, systems or components within the sccpe of this Plan shall be conducted prior to such use.

4.2.8 Design verification methods (design review, alternate calculations or qualification testing) shall be established an? completed prior to turnover for operation.

4.2.9 Design verification procedures shall be established which assure the following:

a. The verifier is quallfled and is not directly responsible for the design,

b. Verification, incluoing acsroved field charges, shall be complete prior to turnover of the component or system to Operations,

c. The responsibilities of the verifter, the areas and features to be verified, and the extent of documenting the verification shall be specified.

4.2.10 When verifications are to be accomplished solely by test:

l

a. Prototype, component or feature testing shll be performed prior to installation of the equipment, or prior to the point when the installation would become irreversible.

b. Verification by test shall be performed whenever practical under conditions thet simulate the most adverse design conditions as determined by analysis.

4.2.11 Procedures shall be established to assure that ccmputer codes, and changes thereto, are verified, certified and controlled to prevent unautt. prized changes.

4.2.12 Changes to approved engineering documents, including field changes, will be subject to design control measures. Design changes shall be reviewed and approved by the organizaticn responsible for the original desig, or by another organization with comparable e<pertise designated to review and approve changes.

45.0 3815L

.- ENuclear GPUNC OPERAT10NAL CUALITY ASSURANCE Pt^" rcR taREE stte tstano uur7 i AND OYSTER CREEK Number ioco-etn-T200.oi Title 4.0 Design Centrol Revisten 2 4.2.13 Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, design descriptions, and drawings, including flow diagrams, L' ping and instrument diagrams, system diagrams, facility drawings showing equipment locations and site arrangements.

4.2.14 Measures, which include procedure changes, shall be provided to assure that responsible plant personnel are made aware of design changes and/or modifications, which may affect the performance of their duties.

4.3 Responsibilities 4.3.1 Director - iMI Unit 1, and Oyster Creek The Di acters - TMI Unit 1, and Oyster Creek are each responsible through their respective Plant Engineering Directors for the implementation of design control measures in accordance with approved Technical Functions procedures.

4.3.2 Director-TechnicalFhnctions The Director - Technical Functions is responsible for tne development and implementation of the de'igns control measures utilized by Technical Functions and Plant Engineering departments.

4.3.1.)

The Director - Technical Functions is responsible through the Director - Engineering Projects and the Director Engineering and Design for coordination and direction of plant modification projects which are outside of the scope of Plant Engineering. To fulfill these responsibilities, the Director - Engineering Projects and/or the Directcr - Engineering and Design will:

a. Control and coordinate the activities of all contractors with design responsibility.

b. Coordinate the efforts of the System Engineering Department as may be needed to support design related projects. l

c. Provide for the review and approval, as appropriate, of l baseline design documents such as selected design criteria, flow diagrams, system descriptions, arrangement drawings, one-line dit. grams and logic diagrams,

d. Ensure Quality Assurance review of applicable design criteria documents and specifications, and changes thereto.

46.0 38151 l -

• NQClgg7 GPUNC CPERATIONAL QUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT I Number 1000-PLN-7200.01 AND OYSTER CREEK Title 4.0 Design Centrol Revision 2 4.3.2.2 The Director - Technical Functions, through the Director - Systems Engineering, is responsible for:

a. Pcoviding conceptual and analytical engineering service to other engineering groups as required.

b. Providing technical administration of nuclear fuel-related engineering activities.

c. Providing direct technical support to the Plant operating staff by providing Shift Technical Acvisors.

4.3.2.3 The Director - Technical Functions is responsible, through the Engineering Services Director, for providing detailed desiga and l draf ting services and for the preparation and maintenance of the Quality classification List (QCL).

4.3.2.4 The Director - Technical Functions is responsible through the Director - Engineering and Design for providing centralized technical capabilities in conventional engineering disciplines as required to produce engineering documents for plant modifications and for the technical performance of components and systems within the nuclear plants.

4.3.3 Director - Qualltv & Radiological Controls The Director - Quality & Radiological Controls is responsible through the Director - Quality Assurance for providing Quality Assurance review of design and engineering documents to assure that appropriate quality requirements have been included. In addition, Quality Assurance will perform planned and periodic audits of responsible design organizations to verify the effective implementation of design control measures and the technical adequacy of engineering results produced.

47.0 3815L

GPUNC CPERATIONAL CUALITY AS

Nuclear "

o,g s,1 ,y , y m e 3URANCE

,",'^o i cer s e T200.01 Title 5.0 PROCUREMENT AND MATERIAL CONTROL Revision 2 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurement 5.1.1 General 5.1.1.1 Procurement of items, materials, parts, consumables, equipment, and services which are within the scope of this Plan shall be performed in accordance with approved documents which shall establish methods for preparation, review, approval, and control of procurement documents.

These methods shall ensure that technical, quality and regulatory requirements and regulatory commitments applicable to the procurement are met as a minimum.

These methods shall also ensure that procurement sources are evaluated and that the activities of consultants, vendors and contractors, and purchased items conform to procurement document requirements.

The programs of all participants shall be in accordance and/or compatible with the applicable requirements of this GPUN Operational Quality Assurance Plan.

5.1.1.2 The general and specific requirements for the Quality Assurance Program of all suppliers and contractors, including their subsuppliers and subcontractors supplying items, parts, materials or conducting activities within the scope of this Plan shall be prescribed by procurement documents. These quality program requirements shall be consistent with Section 2.3 of this Plan.

5.1.1.3 Quality Assurance Plan measures shall be applied with a graded approach to the procurement of spare parts, replacement parts, commercial grade items and consumables. Procurement of spare or replacement parts shall be to codes, standards, technical and quality requirements equal to, or better than, original, as may have been superseded or upgraded by regulatory requirements or commitments. As a minimum, when documented quality and technical requirements are not available, then the procurement of spare parts, replacement parts, and consumables within the scope of this Plan shall be in accordance with an approved specification or the use justified by a documented engineering determination. The use of commercial grade items in nuclear safety-related applications shall be controlled as specified by Section 5.1.2.4 of this Plan.

5.1.2 Requirements 5.1.2.1 Procurement Documents The requirements for the preparation, review, approval and control of procurement documents shall be prescribed in detailed I procedures.

These procedures shall prescribe requirements to ensure that procurement documents:

48.0 3816L m

GPUNC OPERATIONAL QUALITY ASSURANCENumoer

Nuclear *

,g"JgJHRC E SLAND UNIT 1 1000-PLN-72CO.01 Title 5.0 PROCUREMENT AND MATERIAL CONTROL Revision 2

a. Specify the technical and quality assurance requirements commensurate with regulatory requirements and commitments and I this Plan.

b. Require applicable quality assurance requirements to be imposed I on subvendors and subcontractors.

c. Specify or reference design basis technical requirements, including applicable regulatory requirements, regulatory commitments, material and component identification requirements, drawings, specifications, codes and standards, test, calibra-tion, and inspection requirements, handling, storage and shipping requirements, and special process instructions,

d. Identify the documentation to be prepared, maintained, and submitted for review, approval and record information as applicable.

e. Include GPUN QAan identification Plan scope. of those items and activities within l

f. Identify those records which vendors or contractors shalt retain, maintain, and control; and those which vendors or contractors item.

shall deliver prior to use or installation of the

g. Include right of access _to vendors or contractors. Include right of access to their subtier vendor and contractor facilities and records for source inspection and/or audit when deemed necessary.

h. For spare or replacement parts, contain technical requirements at least equivalent to those used for the original procurement.

1. Include the provision that suppliers shall refrain from implementing procedures which require owner approval prior to obtaining such approval.

j. Require design organizations performing design activities for GPUN to have and implement quality programs which include  ;

design control provisions equiv>'ent to those provided in this Plan. l

k. Identify the programs, procedures, activities or conditions that require GPUN approval and/or release.

49.0 3316L

- g gy GPUNC CPERATIONAL QUALITY ASSURANCE Number PLAN FCR THREE MILE ISLAND UNIT I 1000-PLN-72CO.01 AND OYSTER CREEK Title 5.0 PROCUREMENT AND MATERIAL CONTROL Revision 2

- Heasures shall be established for the review, approval, and release of procurement documents and subsequent revisions.

The reviews shall assure the inclusion of the applicable technical, quality, regulatory, pricr anduse.

to their administrative requirements in procurement documents These reviews shall be documented to provide objective evidence of the approval prior to release.

S.I.2.2 Qualification and Selecticn of External Organizaticns Evaluations of prosoective suppliers shall be conducted and documented the followingtocriteria:

demonstrate qualifications based upon one or more of o

Review of performance histories based on records of suppliers' previous capability via accredited agencies; records associated with previous similar procurements; and/or, associated with identical or products.

o Review of the external organization's capability to comply with the GPUN Quality Assurance Program, as applicable to the items or services to be supplied.

o Conduct of a pre-award survey of the external organization's facillttes and Quality Assurance program to determire his capability to meet the tecnnical and quality requirements of the procurement documents.

Procecure. shall DJ establis'ned to prescribe the evaluation and sa'sction of extertial organizations. Contracts or purchase orders for items, s terials, parts, censumables, equipment or services tilthin the scope of this Plan shall be awarded either to:

o External organizations whose Quality Assurance Program has been reviewed and accepted by GPUN Quality Assurance Department as l being commensurate with the equipment or services to be orovided, or o

External organization who will be required, by procurement documents, to corrply with the GPUN Quality Assurance Program.

When GPUN's approval of an external organization's quality assurance l program is required, it shall be reviewed for concurrence by GPUN prior to initiation of the activity affected by their program.

In the case of "commercial grade items" the supplier does not have to be evaluated; however, the procurement documents shall specifically describe the items to be provided to ensure the appropriate quality requirements are specified.

50.0 3316L

O ENuclear GPUNC OPERAT10NAL QUALITY ASSURANCE PtAN rcR ThREE Mite tstANo uN1T i AND OYSTER CREEK Number icoo-PtN-7200.oi Title 5.0 PROCUREMENT AND MATERIAL CONTROL Revision 2 5.1.2.3 Manufacturing Assurance Measures activities ofshall te established to provide control of manufacturing suppliers.

detailed written procedures. These methods shall be described in The attributes of the manufacturing assurance program shall include:

a.

Provtsions for the review and approval of the supplier's drawings, Quality procedures Assurance manual, manufacturing and quality prior to fabrication.

When specified in approved until written notice of GPUN approval is received. procure b.

Established supplier inspection plans that delineate, as required, process forthe hold and/or specified review,witness points in the manufacturing i

i inspection, verification and test.

c.

Methods for identifying and reportir.g nonconformances and resolving of nonconformances where the supplier's suggested disposition is "Use-as-is" or "Repair". Sucn methods shall require the approval of the supplier disposition of nonconformances by the responsible engineer.

d.

Notification of site QC Receipt Inspection of outstanding nonconformances to item shipment from and/or incomplete pre-shipment inspection prior the supplier.

e.

Planned and systematic audit, source inspection and/ or surveillance of supplier activities or products. Scope of coverage and frequency shall be determined by the criticality of I the furnished items or services and the evaluated results of supplier qualifications, including pre-award surveys and quality procedure reviews and the extent of GPUN engineering / technical review of the baseline and/or detailed engineering produced.

Revisions to surveillance plans shall be made as warranted by supplier performance.

Typically, audits will be conducted of suppliers of services, source inspection surveillances, and/or receipt inspection will be conducted of suppliers of hardware.

f.

Control and of supplier documents including review for completeness acceptability.

status of item (s) Inadequate records which render the quality cause for rejection of the item (s). furnished indeterminate shall be sufficie 3816L 51.0 .

GPUNC OPERATIONAL QUALITY ASSURANCE Numo

Nuclear gMggggpE ISue UNIT i icoo.er m .noo.0, Title 5.0 PROCUREMENT AND MATERIAL CCNTROL Revision 2 g.

' Assessments of supplier control of quality shall be made at a l

frequency and depth ccmmensurate and quantity of the items furnished. with the importance, complexity These assessments shall utilize the qualitative and Quantitative information provided by l supplier noncompliance documents; surveillance, inspection and audit reports; and receiving inspection and test records,

h. Material acceptance procedures that assure:

1.

The material, component, or equipment is cle6rly identified and that the identification and quantity cor respond to tne information on the shipping documents and quality records.

2.

The handling and shipping requirements have been met by the supplier and maintained by the carrier. l 3.

The record package or compliance certificate is complete and adequate.

4 The material, component or equipment treets the technical requirements specified in the procuretrent documents, inspection plans, checklists or other special engineering documents.

5. Items delivered which are not in compilance with requirements are cocumented in accordance with the nonconformance procedure, tagged (As item configuration or storage conditions permit. Additional administrative controls shall be used if tagging is not possible.),

segregated (if possible), and prevented from being inadvertently issued for installation or use.

6. Items accepted and released are identified as to their inspection status prior to forwarding them to a controlled storage area or releasing them for installation or further work.

5.1.2.4 Commercial Grade Oedication for NSR Appilcations The process of acceptance of commercial grade items intended for use in nuclear safety related application shall include the following in order for the item to be consicered for dedication:

a. Identification of the characteristics wnich are important to verify to assure the item will function in its intended application.

b.

Documentation of the technical basis of the engineering determination that the commercial grade item is acceptable for use in a nuclear safety related appilcation.

52.0 3816L

' GPUNC CPERATIONAL QUALITf ASSURANCE Nuclear N

g"ogs,ml,EEMILEISLANDUNIT1 100 - LN-7200.01 Title 5.0 PROCUREMENT AND MATERI AL CCNTROL Reviston 2 c.

, Verification by one or moreof the characteristics of the following: related to item functionality 1.

Receipt testing. inspection, receipt testing and/or post-installaticn 2.

Conduct of an audit or surveillance of the supplier to assure adequate centrols of critical characteristics.

3.

Performance of surveillance to witness and/or verify the supplier's controls of the critical characteristics.

4.

Establishment of a commercial grade supplier history or part performance history that would provide a sufficient confidence level to justify acceptance of the item.

Items a. through c. above may be accomplished by procuring the item as commercial grade and GPUN performs the acceptance; or the item may be procured from an approved supplier with a 10CFR50 Appendix B program that is invoked on the item acceptance and the supplier is responsible for reporting per 10CFR21.

This an dedication approved process procedure (s).shall be cor, trolled and implemented through This process shall result in the documented basis for use of the commercial grade item for the specific nuclear safety related application.

5.1.3 Responsibilities 5.1.3.1 Director Administration The Director-Administration is responsible through the Otrector Materials Management for the:

a.

Administration and operation of contracting, procurement and warehousing activities of GPUN, b.

Assurance that the technical and quality requiretrents, as established by requisitioners, are incorporated into contract / procurement documents without revision,

c. Assurance that the contractual, legal and commercial requirements are incorporated into the procurement documents in a manner which will enforce the technical and quality requirements.

53.0 3816L

GPUNC OPERATICNAL QUALgy ASSURANCc I

- UNU 1 IOC -PLN-7200,0]

AN OY ER CREE Ti tle 5.0 DROCUREMENT AND MATERIAL CCNTROL Revision 2 d.

Assurance that documents and records, as required by procurement complete andare documents, submitted in a timely manner and that they are legible.

e.

Assurance that purchase orders and contracts for items and services within the scope of this Plan, except for commercial grade items, Quality are issuedList.

Classification to suppliers listed on the Suppliers 5.1.3.2 Director - Quality & Radiological Controls TheDirector-Quality the Director-QualityAssurance

& Radiological to: Controls is responsible through a.

Assure that QAD procedures for the control of purchased equipment, Implementedmaterial and services are established, approved.

and effective, b.

Review selected GPUN procedures necessary for the control of purchased equipment, scope of this Plan. material, and services that are althin the c.

Review supplier Quality Assurance Programs for concurrence to the extent required in the procurement documents, l d.

Review for concurrence supplier record packages as required by apolicable procedures or procurement docunients.

e.

Establish and implement an adequate program of source inspection, source survell!ance and/or receipt inspection to assure that items, parts, materials and consumables within the sccpe of this Plan comply with requirements.

f.

Review procurement documents to assure that Quality requirements are adequatt are correctly stated, inspectable arid controllable, that there acceptance / rejection criteria; that source surveillance or receipt inspection is specified; that minimum documentation to be supplied is specified; and that the procurement documents have been processed in accordance with established requirements.

This review may include sampling review of previously approved procurement documents or in-line reviews of selected purchase requisitions or orders prior to placement.

9 Establish and maintain a Supplier Quality Classification List (SQCL) whichsuppliers.

prospective documents the results of the evaluations of 54.0 3816L

' GPUNC OPERATIONAL GUAllfY ASSURANCE Nuclear ,"g"Jgg"gp tsuNo um i Numde ix tN_ m u l Title 5.0 PROCUREMENT AND MATERIAL CCNTROL Reviston 2 5.2 Identification and Control of Materials, Parts and Cceponents 5.2.1 General Measures shall be established to provide for the identification and control of items, parts, materials, and consummaeles within the scope of this Plan.

These measures shall assure that incorrect or nonconforming items are identified and controlled in order to prevent their inadvertent installation or use. Where required by design documents, the system established shall provide traceaoility of components installation andfrom the receipt of material tnrough fabrication, testing.

Verificaticn shall include review of objective evidence of inspecticns and tests shich demonstrate that product of identification manufacture, and control installation, is maintained at various stages or erection. Idenr!fication requirements shall procurement documents. be specified in the applicable design and 5.2.2 Requirements 5.2.2.1 Identification and traceability requirements shall be included in specifications and drawings.

5.2.2.2 Material, parts, and comocnents, including partially fabricated subassemblies preclude the useorofsubdivided incorrect ormaterials defectiveshall be identified to items.

5.2.2.3 Items, materials, parts, consumables, and equipment within the scoce of this Plan that are not designated as commercial grade shall be identified so that they can be traced to documentation, which provides objective evidence of the technical and quality requirements met; such documents include but are not limited to:

a. Specifications

b. Drawings (including as-builts)

c. Procurement Documents

d. Physical and Chemical Test Reports

e. Nonconformance Reports

f. Inspecticn Reports and Checklists 9 Storage Maintenance Instructions

h. Nondestructive Examination Reports

1. Vendor Certificates of Compliance 55.0 3816L

CPUNC CPERATIONAL QUALITY ASSURAhCE

,' ggglggy PLAN FOR THREE MILE ISLAND UNIT 1 Nuteer AND OYSTER CREEK IDCO PL'-7:M . 01 Title 5.0 PROCUREMENT AND MATERIAL CONTROL Revision :

The identification and/or end use of items, materials, parts, consumables, and equipment shall be specified in procurement documents and work authori:Ing documents to provide this traceability, i

5.2.2.4 Thetolocation not andform, affect tne method of identification shall be specified so as identified. fit, function or quality of the item being 5.2.2.5

-Co~rrect identification of materials, parts and cccconents shall be verified and prior to release for fabrication, shipping, installation, testing.

5.2.2.6 Where physical identification is determined not to be needed, such not when as items required are uniquely by codes or identifled and specific traceability is be imposed. standards, only segregation controls need 5.2.2.7 A receipt inspection, when scecified by procurement documents, shall be performed at the site to verify that identification for received l items is complete and accompanied by specified documentation.

Alternatively, verification of proper identification may also be made by inspection personnel prior to installation.

5.2.3 Responsibilities 5.2.3.1 Responsible Department Manager Each Department Manager is responsible for ensuring that procurement documents contain appropriate requirements for the identification and control of materials, parts, or components and that only materials, used. parts or components wnich have been accepted by OAD are 5.2.3.2 Director - Quality & Radiological Controls TheDirector-Quality the Director-QualityAssurance

& Radiologicalfor: Controls is responsible through i

a.

Review of procedures for mairtaining identification in accordance with the requirements of this section.

D.

Verification of identification during receipt inspection or prior to installation.

c.

Conducting surveillances, inspections, and/or monitoring to verify conformance to the requirements of this section.

5.2.3.3 Director - Administration The Director-Administration is responsible tnrough the Director Materials Management for assuring that correct identification of materials, parts, and components are verified prior to release for fabrication, snipping, installation and testing.

56.0 3816L

GPUNC CPERATIONAL QUALIT( ASSURANCE

Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Number 1000-PLN-7200.01 Title 6.0 CONTROL OF STATICN ACTIVITIES Revision 2 6.0 CONTROL OF STATION ACTIVITIES 6.1 General This section provides general requirements which are applicable to the operational, support, and assurance activities which are directly related to the safe operation, maintenance and modification of the nuclear station.

6.2 Control of Inspecticns 6.2.1 Requirements 6.2.1.1 A program for performance of inspections of activities within the scope of this Plan shall be established and executed by, or for, the organization performing the activity to serify conformance to the documented instructions, procedures, specifications and drawings for accomplishing the activity. Design specifications, drawings, procedures, or instructions shall include the necessary requirements for performance of inspections. These requirements include acceptance criteria and reference to codes, standards, and regulatory requirements and commitments. These requirements shall be further translated into procedures, instructions, or checklists l which shall contain, as required, the following:

a. Identification inspected.

of characteristics and activities to be

b. Methods to be used including necessary measuring and test equipment and the accuracy requirements,

c. Identification of organization responsible for performing the inspection.

d. Acceptance and rejection criteria,

e. Identification of required procedures, drawings and specifications, including the applicable revisions,

f. Documentation of inspection results including identification of the Individual performing the inspection.

6.2.1.2 Inspectors (including NDE personnel) shall te qualified in accordance with applicable codes, standards and GPUN training programs and their qualification and certification shall be kept current and documented.

57.0 3818L 9

Nuclear GPUNC CPERATIONAL QUALITY ASSURANCE sun rcR TsRec mu IsuNo UNIT i U,0 OYSTER CREE <

NJmber ioc0.Pum0.m Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.2.1,3 Individuals performing inspections shall be other than those who performed or directly supervised the activity being inspected and shall not report directly to the immediate supervisors who are responsible for tne work activity being inspected. !f the individuals performing the inspections are not part of the responsible Quality Assurance organt:ation, the procedures and personnel qualification criteria shall be reviewed and concurred with by the responsible Quality Assurance organization prior to the initiation of the activity. Inspections may te conducted by second line supervisory personnel cr by other qualified personnel not assigned first line supervisory responsibility for the conduct of work. These activities, i.e. , those performed by individuals not assigned first line supervisory responsibility, are not intended to dilute or replace the clear responsibility of first line supervisors for the quality of work performed under their supervision. When inspections associated with normal operations of the plant (such as routine maintenance, surveillance and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group (reporting to different supervisors). tne following controls shall be met:

a. The quality of the work can be demonstrated through a functional test item, when the activity involves breaching a pressure retaining

b. The qualification criteria for the personnel are reviewed and found acceptable by the Quality Assurance organization prior to initiating the inspecticn.

6.2.1.4 The Quality Assurance Department shall establish documented methods to review work activities prior to implementation to determine the need for inspection and the specification of the requisite hold and/or witness points.

6.2.1.5 When QA Hold Points have been established, either contractually, by procurement, or internally by plant procedures, work may not proceed beyond the Hold Point until either inspection is perforced or waived by the responsible Quality Assurance organizatien.

6.2.1.6 Inspections of modifications, recairs, and replacerrents shall be by the same method and to the same criteria as the original or by an approved, documented, engineering and QA alternate. Where verification of inspection is being performed on previcusly accepted lots, sampling inscection shall te representative and only to the extent necessary to assure adequacy of control. The sampling plan shall be determined by Quality Assurance. Inspection personnel shall be provided with suitable equiprent and tools, anich are calibrated as necessary, and controlled to assure that accuracy requirements are satisfied and that inspections are complete.

58.0 3818L

Nuclear GPUNC CPERATIONAL QUALITY ASSURANCE atAN rCR TsneE sttE t5tANo UNIT i AND OYSTER CREEK Number ioco-gtN-72co.oi Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.2.1.7 Inspection data and results shall be evaluated by designated personnel to assure that the objectives have been met and that items requiring action or follow-up are identified and documented.

6.2.1.8 Records shall be kept in sufficient detail to provide adequate confirmation of an inspection program.

6.2.2 Responsibilities 6.2.2.1 Director Technical Functions The Director - Technical Functions is responsible for ensuring that requirements fo- inspections are included in design specifications, drawings, procedures and instructions and that these requirements include acceptance criteria and, as apolicable, references to codes, standards and regulatory requirements and commitments.

6.2.2.2 Director - Quality & Radiological Controls The Director - Quality &. Radiological Controls, through the Director - Quality Assurance, is responsible for:

a. Assuring that inspectors are quallfled in accordance with applicable codes, standards, regulatory requirements and commitments, and GPUN qualification programs.

b. Reviewing maintenance and installation documents for inclusion of inspection and test requirements and QA hold and/or witness points.

c. Reviewing and concurring with the personnel qualification criteria cf Individuals performing inspections, including those who are not part of the QA organization.

d. Identification of inspection plans to be used for verification of inspections on previously accepted lots.

6.2.2.3 Responsible Department Manager Each responsible Department Manager performing work requiring inspections is resoonsible for:

a. Notifying the QA Cepartment of the work being performed.

b. Obtaining QA review for concurrence of administrative control procedures for maintenance and modification work,

c. Assuring that established QA Hold Points are not bypassed without prior QA authorization.

d. Assuring that all information, records or copies of records associated with their work are made available to QA perscnnel, 59.0 3818L

9

Nuclear GPUNC CPERATIONAL CUALITY ASSURANCE Pu N r0a TaREE MILE Ista o UNIT i AND OYSTER CREEK Number icoo-PtN-noo.oi Title 6.0 CONTROL CF STATION ACTIVITIES Revision 2 Each responsible Department Manager performing inspections is responsible for:

e. Assuring that the personnel performing inspections are quallfled in accordance with apolicable codes, standards, regulatory requirements and commitments, and GPUN qualification programs.

f.

Assuring that tne results of all inspections are property documented and the results are evaluated by designated personnel.

6.3 CA Monitoring 6.3.1 Requirements 6.3.1.1 A program for QA Monitoring of activities affecting items or  ;

processes within the scope of this Plan snall be established and i executed by the QA Cepartment.

6.3.1.2 Monitoring is us?d to establish adecuate confidence levels that activities within the scope of this Plan are being performed in accordance with the QA Program reautrements and plant administrative {

controls. Monitoring will be performed on a graded approach and the degree of monitoring performed shall be based typically upon the status and nuclear safety importance of activities, extent of previous experience, thoroughness of overall coverage, uniqueness of testing or operating activities and trending data.

6.3.1.3 Monitors shall be quallfled in accordance with a documented QA Department procedure that ensures that Monitors are knowledgeable in the activities they are monitoring to the extent that they can readily verify compilance of the activity being performed.

6.3.1.4 '

Monitoring reports shall contain as a minimum the following:

a. Identification of activity being monitored including specific reference to the program or procedural requirements governing the activity.

b. Indication of ccmpliance.

c. Identification of Monitor

d. Appropriate distribution to supervisory or managerial personnel that have responsibility for the performance of the activity.

e. Identification of each nonconformance document when such nonconformances exist and are identified as a result of the monitoring.

6.3.1.5 Records shall be kept in sufficient detail to provide adequate documentation of a monitoring program.

60.0 3818L

ENuclear GPUNC CPERATIONAL QUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Number 1000-PLN-7200.01 Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.3.2 Responsibilities 6.3.2.1 Director - Quality L Radiological Controls The Director - Quality & Radiological Controls through the Director - Quality Assurance, is responsible for:

a. Establishing the recuirements for QA monitoring of activities and practices affecting items or processes within the scope of this Plan,

b. A15uring that QA Monitors are adequately trained and are qualified to perform their duties.

c. Assuring that reports of the monitoring activities have sufficient details and Orovide adequate confirmation of the monitoring program.

6.4 Control of Special Processes 6.4.1 Requirements 6.4.1.1 Special processes are those processes that require interim in-process controls in addition to final inspection to assure quality. Such processes include, but are not limited to -;lding, heat treating, chemical cleaning, nondestructive examination, plant chemistry control, and the processing and preparation for shipment of radioactive wastes.

6.4.1.2 Measures shall be established and documented to assure that special processes are accomplished under controlled conditions in accordance with applicable codes, standards, applications criteria, regulatory requirements and commitments, and other special requirements including the use of qualified personnel and procecures.

6.4.1.3 Procedures for special processes shall be established to meet the requirements of applicable codes, standards, and regulatory requirements and commitments or to meet the requirements of special process specifications whicn may be produced by or for GPUN. These procedures shall provide for recording evidence of acceptable completion of special processes. Procedures and instructions for the control of special processes shall be reviewed and approved by quallfled personnel. Procedures, equipment, and personnel performing special processes shall be qualified in accordance with applicable codes, standards, and specifications. Organizational responsibilities shall be delineated for the qualification of special processes, equipment and personnel. Qualification records of personnel, equipment, and procedures associated with special processes shall be established, prepared and kept current. For l

special processes not covered by the esisting codes or star.dards, or when item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures and equipment shall be defined in the procedure.

61.0 3818L

GPUNC OPERATICNAL QUALITY ASSURA'NCE Numcer MUClear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 6.0 CONTROL CF STATION ACTIVITIES Revision 2 6.4.2 Responsibilities 6.4.2.1 Responsible Department Manager Each resocnsible Department Ofrector/ Manager performing special processes is responsible for:

a. Assuring that the established program requirements for controlling and accomplishing special processes are implemented.

b. Assuring that the procedures, including changes, are reviewed, approved and ouallfled prior to use.

c. Assuring that personnel and equipment used in the performance of special processes are qualified and the records of qualification are maintained.

6.5 Test Control 6.5.1 Requirements 6.5.1.1 A documented test orogram shall oe established to assure that all testing required to demonstrate tnat the structures, systems or components within the scope of this Plan will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test procedures or instructions which incorporate or reference the requirements and acceptance standards contaired in the aoplicable design documents. The extent of testing shall be based on the complexity of the modification, replacement, or repair. Testing, including proof tests prior to installation, hydro testing, Inservice Testing (IST) and preoperational tests, necessary to demonstrate that the installed or modified structures, systems and components will perform l satisfactorily in service, shall be accomplished in accordance with written approved procedures or instructions. These procedures shall be consistent with or incorporate the technical and quality requirements and m eptance limits specified by aoplicable design and procurement documents. These test procedures or instructions shall provide for the following as required;

a. A description of the test objective,

b. Instructions for performing the test, including caution or safety notes in sufficient detail to avoid operator interpretatten,

c. Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including accuracy requ;rements, completeness of item to be tested, suitable and controlled environmental conditions, and personnel to be provided to conduct testing under the direction of a qualified l test supervisor or engineer.

62.0 3818L

Nuclear GPUNC CPERATICNAL QUALITY ASSURANCE PLAN roR m EE m tE IStAno u m T i AND OYSTER CREEK Number ic e -PtN.n w .oi Title 6.0 CCNTROL Or STATION ACTIVITIES Revisten

d. Provisions for data collection and storage.

e. Acceptance and rejection criteria as specified in design and procurerent d0cuments,

f. Methods of documenting or recording test data and results, in sufficient detail to prevert misinterpretation.

g. Mancatory hold or witness points for inspection by GPUN Quality Assurance and/or other designated personnel.

h. Provisions for control of jumpers, lifted leads and jurisdictional or safety tags.

i.

Provisions for returning a system to normal configuration upcn ccmpletion of the test, including verification.

J. Provisions for assuring test prerequisites have been met.

6.5.1.2 Test results shall be documented, evaluated, and their acceptability determir.ed by a responsible individual or group. '

6.5.1.3 The test program shall Cover all required tests including:

a. Precperational tests of components or systems to demonstrate that performance is in accordance with the design intent.

b. Tests during initial operation to demonstrate system performance (that could not be tested prior to operation) to confirm compliants to design criteria,

c. Tests during the operational p# a to 0: ovide assurance that fallores or substandard performsite do not remain undetected and t

• k.t he required reliability of systems witnin QA Plan scope is rain: tined.

d. Testi during activities associated with plant maintenance during the operational phase and to demonstrate satisfactory performance ,

following plant maintenance or procedural changes.

6.5.1.4 Tests performed following plant repairs or replacements shall be conducted in accordance with the original des?gn and testing requirements or approved. documented alternatives. Testing shall be sufficient to confirn that the changes reasonably produce expected results and that ths' change does not reduce safety of cperaticns.

63.0 3818L

~

ENuclear 'GPUNC OPERATICNAL QUALITY ASSURANCE PLAN FOR TsREE MILE ISLANo UNIT i AND OYSTER CREEK Number icoo-PtN-7200.oi Title 6.0 CCNTROL OF STATION ACTIVITIES Revision 2 6.5.2 Responsibilities 6.5.2.1 Directors TMI Unit i, and Oyster Creek The Director of the nuclear generating stations are each resperisible for assuring that testing performed at their assigned Station is performed in accordance with the requirements of this Plan including, as a minimum, the folMwing:

a. Assuring that testing is perf0rmed in accordance with written, approved and controlled procacures or instructions.

b. Assuring that onerations perscnnel have the required special training and skills,

c. Assuring that the test results are documented and are evaluated for acceptaollity by a responsible individual or group.

d. Assuring that identified discrepancies are addressed, resolved and reported as required by tne Operating License and Technica Specifications of the Unit.

6.5.2.2 Olrector - Technical Functions The Director - Technical Functions, through the Director - Startup and Tt st is responsible to perform a startuo and test function to assure new or substantially modified plants, facilities and systems are tested. These responsibilities shall 11clude:

a. Preparing test plans and implementing procedures.

b. Directing testing and assuring test engineers have the required special training and skills.

c. Ensuring that test documertation is completed, as required, and reviewed prior to turnover to Operations.

d. Coordinating technical assistance of testing.

6.5.2.3 Director - Maintenance, Constr uction and Facilities The Director - Maintenance, Ccnstruction and Facilities (MCF),

through the applicable station Maintenance, Construction and Facilities Director, is responsible for:

a. Ensuring supporting personnel have the required special training and skills.

b. Prescribing the construction or post-maintenance test requirements for the work performed by MCF,

c. Ensuring that all construction or cost-maintenance testing performed by MCF, including hydrotesting, is performed, documented and the results at:epted prior to turnover.

64.0 3318L

M, Nuclear !GPUNC CPERATICNAL CUALITY ASSURANCE a'4" rca t"act "t'e ts'AND UNIT 1 AND OYSTER CREEK Number 1000-PLN-M00.01 Title 6.0 CCNTROL OF STATION ACTIVITIES Revision 2 6.6 Control of Measuring and Test Equipment 6.6.1 Requiiements 6.6.1.1 Measures shall be established to control installed and portable equipment which are used to conduct measurements or tests related to determining the functicnality or quality of structures, systems and comoonents within the scoce of this Plan. Such equipment typically include tools, gauges, meters and other devices. Such measurerrents and tests include as a mininum those asscciated with the activities of operation, maintenance, nocificatien, chenistry, radiological and environmental controls, nondestructive examination and inspection.

Such measures shall ensure that instruments are properly identified and calibrated or adjusted at specified periods to maintain accuracy within specified limits.

Measures shall also te established to ensure that range, type, accuracy and use of the equipment conforms to specified requirements.

6.6.1.2 Requirements for each coni;rol program shall include inspection and verification of accuracy upon receipt of equipment, identification of all gauges and Instruw ts, calibration and scheduled recall for calibration and traceability to an accepted Standard. These activities shall be subject to CAD monitoring and auditing.

Procedures shall be estaDllshed to implement the following requirements:

a. Establish the calibration technique and frequency requirements, maintenance requirements , and controls for all measuring and test equipment which are used in the measurement, inspecticn, and monitoring of components, systems, and structures covered under the scope of the Quality Assurance Program (instruments, tools, gauges, fixtures, reference and transfer standards, and nondeitructive examination equipment).

b. The identification of measuring ard test eculpment traceable to the calibration test data,

c. Installed plant instrumentation and measurement and test equipment requiring calibration shall te icentified and controlled in accordance with written, approved procedures to assure that approved calibration intervals are not exceedea.

Portable measuring and test equipmen* may te similarly controlled; but sull, as a minimum, be clear'y labelled to indicate the date on which the current Calibration espires.

Measuring and test eaulpment that has eiceeded the accroved calibration interval shall not be used for meastrements or tests.

65.0 3818L

l jQ'jg7 GPUNC OPERATICNAL QUALI*Y ASSURANCE PLAN FOR THREE MILE ISLAND UNIT !

Number 1000-PLN-7200.01 AND 0(STER CREEK Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2

d. Establish calibrattori frequency for measuring and test eculpment based on required accuracy, purpose, degree of usage, stability characteristics, and/or any other condition which may affect the measurement. A calibration recall system shall be implemented to assure recalibration within the required period for each piece of measuring and test equipment covered under the scope of this program.

e. Establish methods for determining the validity of previous inspections cerformed when the measuring and test equipment is found to be out of calibration. Inspections or tests are repeated on items determined to be suspect. Such determination is to be documented in suitable form. If any calibration, testing or measuring device is consistently found to be out of calibration, it shall be repaired or replaced.

f. Measuring anc Test equipment (M &TE) used to calibrate instruments and gages (flowmeters, pressure gauges, level indicators, etc.) shall have ceen calibrated against working standards with accuracies at least four times greater than that of the equipment being calibrated. The instrument or gage calibration accuracy in reference to the M & TE shall be at least 1:1.

In cases where the instrument or gage is calibrated directly against working standards, the working standard shall have an accuracy of at least 1:1 and the secondary standards used to calibrate the working standards shall have an accuracy of four times greater than that of the working standards.

When the above requirements cannot be met, the standards used shall have a precision and repeatability that assures the equipment being cslibrated will be within the required tolerance. The casts of acceptance will be documented and authorized by the supervisor of the calibrating organization.

Some measuring tools because of their construction (such as mechanical dial indicators) or because they are not adjustable (such as rulers) need not be periodically calibrated. Hcwever, they shall be maintained in good norking condition.

g. A status of all measuring and test equipment under the calibration program is to be maintained.

h. Utilization of reference and transfer standards traceable to nationally recognized standards. Where national standards do not exist, provisions shall be established to document the basis for the calibration.

1. NDE equipment shall be controlled and calibrated in accordance with the industry code governing its use.

66.0 3818L

1 c l GPUNC OPERATIONAL QUALITY ASSURANCE Number

.' l4L3L :ltB43r PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 l AND OYSTER CREEK Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.6.2 Respcns10111 ties 6.6.2.1 Responsible Department Manager Each Department Manager utilizing tools, gauges, instruments and other measuring and testing devices in activities affecting the function or quality of structures, systems, comoonents and activities within QA Plan scope shall assure that the equipment is controlled in accordance dith an approved calibration control program which complies with the requirements of this Plan.

6.7 Handling, Storage and Shipping 6.7.1 Requirements 6.7.1.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, cackaging, and preservation of items within QA Plan scope in accoraance with established instructions. procedures, and drawings to prevent damage, deterioration or loss. The requirements for handling, storage, packaging and shipping of radioactive wastes are contained in Section 7.0 of this Plan.

6.7.1.2 Procedures shall be established to control the cleaning, handling, storage, packaging, and shipping of materials, components, systems in accordance with design and procurement requirements to preclude damage loss or deterioration by environmental conditions such as temperature or humidity. These procedures shall be implemented by suitably trained individuals. The procedures shall include but not be limited to, the following:

a. Packaging and preservation procedures to provide assurance of adequate protection against corrosion, contamination, physical damage or any effect which would lower the quality of the items or cause deterioration during shipping, handling or storage.

Special protective environments, special coverings, inert gas atmospheres, moisture contents, and temperature controls shall be specified as required and their existence verified and documented.

b. Cleaning methods to provide assurance that necessary cleaning operations are carried out prior to packaging, storage or installation. The level of cleanliness required, and verification and documentation requiremenet shall be specifiec in the procedures.

67.0 3818L

GP ENuslear e'UNC OPERATIONAL 4" roa rNaec AND OYSTER CREEK "t'e tS'ANDQUALITY unit i Number ASSURANCE ic00.gLN_7200.0i Title 6.0 CONTROL OF STATION ACTI'/ITIES Revision 2

c. Detailed handling methods for all items that require special handling. Special handling tools and equipment shall be provided and controlled to ensure safe and adequate handling.

These tools and equipment shall be maintained, inspected and tested in accordance with written procedures at established intervals to ensure their reliability and availability for use.

d. Storage practices to provide for methods of storace and the centrol of items in storage which will mialmize the possibilit/

of damage or deterioration during stordge. Periodic inspections of storage areas snall be performed and doct;mented to verify ccmpliance with storage procedures. Release of items for installation shall also be procedurally controlled.

e. Provisions to assuco that proper marking and labeling of items and containers is acccmplished to provide identification and necessary instructions during packaging, shipment and storage.

f. Provisions for documenting and reporting nonconformance to handling, and shipping requirements.

g. Provisions for the storage of chemicals, reagents, lubricants and other consumable materials which will be used in conjunction

.vith Systems which are within QA Plan scope.

h. Provisions for "Limited Life" requirements (including "Shelf Life" and "Service i.ife" for applicable materials).

6.7.2 Responsibilities 6.7.2.1 Responsible Department Managers Each responsible Department Director /Managn is responsible for identifying in procedures, drawings, specifications or procurement documents those handling, storage and shipping requirements necessary to assure compliance with the requirements of this Plan.

6.7.2.2 Director - Admini s tra tion The Director-Administration, through the Director-Materials Management, is responsible for:

a. Providing the procedures for the receiving and storage of materials, parts and components.

b. Assuring that the personnel respcnsible for the handling and storage of materials, parts and components are adequately trained in the performance of their duties and that they implement the procedures properly,

c. Providing adequate storage of items, materials, and parts within the scope of this Plan.

68.0 3818L i

9 GPUNC OPERATIONAL QUALITY ASSURANCE

Nuslear etAn F0a TsReE site ISLANo uuIT i AND_0YSTER CREEK Numcer iOc0-etn-7200.0i Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2

6. 7. 2. 3 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for assuring that the handling, cleaning and storage activities, under their direction, associated with the operation and maintenance of their assigned station are performed in accordance dith the requirements of this Plan.

6. 7. 2. 4 Director - Maintenance, Construction and Facilities The Director-Maintenance, Construction and Facilities is responsible for assuring that the handling, cleaning and storage requirements of this Plan are incorporated in the procedures and are properly implemented on all maintenance and mo;ification projects performed at the generating stations.

6.8 Inspection, Test, and Operating Status 6.8.1 Requirements 6.8.1.1 Measures shall be established and documented to ensure that the required insper.tions and tests are performed and that the acceptability of items with regard to inspection and tests performed is known throughout manufacturing, installation, and operation.

Status of items covered by the scope of this Plan shall be controlled in accordance with approved procedures. These procedures shall include the use of appropriate tags, markings, lists, logs, diagrams, electrical and mechanical jumpers, or other suitable means, to assure that required inspections and tests are satisfactorily completed to prevent inadvertent bypassing of required inspections and tests and to prevent inadvertent operation.

6.8.1.2 The requirements for an acceptable inspection, test and operating status program for structures, systems, and comoonents throughout f abr i ca tion, installation, test and operation include:

a. Design and quality documents which address the requirements for the identification of inspection, test, and operating status of structures, systems and components.

b. Procedures which include controls for the application and removal of inspection and welding stamps, and other status indicators such as tags, jumpers, markings, labels, and stamps.

c. Procedures for controlling the bypassing or altering of the sequence of required inspections, tests or other critical <

operations are ciocedurally controlled with concurrence by the Quality Assurance or;anization. The procedures shall provide for the identification cf items which have satisfactorily passed such inspections and tests, where necessary to preclude inadvertent bypassing of required inspection and tests.

69.0 3818L l

l GPUNC CPERATIONAL QUALITY ASSURANCE Number lklLj(~Il(){Ilf PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK _

i Title 6.0 CCNTROL OF STATION ACTIVITIES Revision 2 1

d. In cases where documentary evidence is not available to confirm that an item has passed required inspections and tests, that item shall be considered nonconforming until such evidence beccmes available. Affected systems shall also be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

r

e. Procedures requiring identification of the operating status of systems, components, controls, or support equipment in order to prevent inadvertent or unauthorized operation. These procedures shall require control measures such as locking or tagging to secure and identify equipment in a controlled status.

Independent verification shall be required, where appropriate, to ensure that necessary measures, such as tagging equipment, have been implemented correctly.

f. Methods which ensure temporary modifications / variations shall be controlled by approved procedures which include a requirement for independent verification. A log shall be maintained of the current status of such temporary modifications / variations.

g. l'ethods which ensure that nonconforming services and inoperative or malfunctioning structures, system, components or materials shall be identified in accoriance with the requirements of this Plan.

6.8.2 Responsibilities 6.8.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for assuring that the appropriate requirements for controlling the inspection, test and operating status, including independent verification, are incorporated in the procedures used on all fabrications, installation, test and operation activities performed at their respective stations.

6.9 Housekeeping and Cleanliness 6.9.1 Requirements 6.9.1.1 Good housekeeping practices shall be ucitized at all times to maintain the facilities in a neat and clean condition and to assure the control of radioactive contamination areas and the control of work activities, conditions and environments that can affect the quality of QA Plan scope parts of the nuclear plant.

70.0 3318L

GPUNC OPERATICNAL CUALITY ASSURANCE Number

Nullear etAN r0R TsReE nite IStANa UNIT i ic00 atN-7200.Di AND OYSTER CREEK Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.9.1.2 Housekeeping encompasses all activities related to the control of

' cleanliness of facilities, materials and equipment; fire prevention and protection including disposal of combustible material and debris; control of access to areas, protection of equipment, radioactive contamination control; and, storage of solid radioactive waste.

6.9.1.3 Housekeeping practices shall assure that only proper materials, equipment, processes, and procedures are utilized and that the quality of the item is not degraded as a result of housekeeping practices or *echniques. During maintenance activities, certain portions of safety-related systens or components may be subject to potential contamination with foreign materials. To prevent such contamination, control measures, including measures for access control, and tool accountability shall be established. Additiona'ly, immediately prior to closure of system (s) or component (s), an inspection shall be conducted and documented to ensure cleanliness.

Special housekeeping considerations shall be made for maintenance of radioactively contaminated systems and components.

6.9.2 Responsibilities 6.9.2.1 Directors THI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining programs and practices for housekeeping and cleanliness control of all work activities performed by the plant site staff, support organizations and contractors in accordance with the requirements of the GPUN QA Program.

6.9.2.2 Dj rector - Maintenance, Construction and Facili ties The Director-Maintenance Construction and Facilities through the site Maintenance, Construction and Facilities Directors is responsible to implement housekeeping and cleanliness control plans, procedures, instructions or practices associated with all work activities performed by MCF personnel and contractors.

6.9.2.3 Director - Quality & Radiological Co nrols The Director-Quality & Radiological Controls, through the Director-Quality Assurance is responsible for monitoring the housekeeping and cleanliness practices at the nuclear generating stations.

6.10 Equipment Control j 6.10.1 Requirements 6.10.1.1 Authorization to remove plant installed operational equipment or systems from service, for maintenance or modification, shall be granted by the cn-duty Shift Supervisor.

71.0 l 3818L

GPUNC OPERATIONAL QUALITY ASSURANCE Nuncer Nun ~ lear Plas r0a inReE nite IStAno unIr i AND OYSTER CREEK iOOO etn-7200.01 Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.10.1.2 Procedures shall be provided for control of equipment, as necessary, to maintain perscnnel and reactor safety, to avoid unauthort;'ed operation of equipment, and to assure that operational equipment is in a ready status. Work en equipment and systems, critical to the safe cperation of the plant, shall not be performed whfle the plant is operating without specific advanced approval by the designated )

Operations management personnel in each instance. The procedures for controlling the removal from service and the return to service of equipment shall require:

a. Centrol measures such as locking or tagging to secure and identify equi] ment in a controlled status,

b. Independent verifications when necessary to ensure that measures, such as tagging equipment, have been implemented correctly.

c. Temporary mcdificattor.s/ variations, such as temporary bypass lines, blank flanges or similar mechanical ir.serts, electrical jumpers, lif ted electrical leads and temporary trip point settings shall be controlled by approved procedures which shall include a requirement for independent verification by either a second persen or by functional test which conclusively proves the proper installation and subsequent remove.1 of the temporary modification. A log or equivalent documented evidence shall be maintained 'of the current status of such temporary modifications which are installed.

d. Control of inspection and test status on individual items by the use of markings such as stamps, tags, labels, routing cards or other suitable means.

e. When equipment is ready to be returned to service, operating personnel shall place the equipment in operation and verify and document its functional acceptability,

f. The equipment shall be adequately identified on the documentation to assure traceability.

6.10.2 Responsi bil i ti e s 6.10.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for establishing and maintaining proccdures and assuring

implementation cf the procedures for identification and control of l equipment 9 avoid unautnorized use and to assure that operational equipment is in a ready status. These requirements shall include independent /erifications to ensure proper implementation.

l 3818L 1

l g ;- ] g 7 GPUNC OPERATIONAL GUALITY ASSURANCENumcer PLAN FOR THREE MILE ISLAND UNIT 1

AND OYSTER CREEK 1000-PLN-7200.01 Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.11 _

Control of Construction, Maintenance (Preventive / Corrective)

Modi fi ca tions and 6.11.1 Requirements 6.11.1.1 Construction, maintenance or modificatf or which have the potential to affect the functioning of Nuclear Safe.y Related or Regulatory Required structures, systems or components shall be performed in a I manner to ensure quality at least equivalent to that specified in the original and inspection design basis and requirements, materials specifications requirements.

A suitable level of confidence in structures, systems or components on which malr.tenance or modifica-tionsperformance and have beentes performed ting. shall be attained by apprcpriate inspection Construction, maintenance or modification of equipment shall be pre-planned and performed in accordance with written procedures, instructions or drawings appropriate to the circumstances specifications,whichand conform criteria. to applicable codes, standards, work in areas and systems of the plant, critical to the safeIn this rega operation of the plant, shall not be performed while the plant is Director orwithout operating specific designate (s). advance approval by the Plant Division 6.11.1.2 Detailed step by step procedures are not required for all maintenance and modification work. The supervisor planning the job must consider the skills required to ensure proper completion of the work and identify the procedural requirements accordingly. Work such as replacing chart or drive speed gears, replacing fuses or tightening valve packing may not require written procedures.

Whereas, work involving inter-departmental coordination or risk of nuclear or personnel safety requires a higher level of administrative control such as approved procedures and sign offs to properly coordinate, direct and document the activity.

6.11.1.3 Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delineations in a written procedure but are subject to general administrative procedural controls that govern or define the following areas.

a.

Methods for obtaining permission and clearance from Operation personnel to work and for logging such work.

b. Factors to be taken into account, maintaining occupational radiation exposure as icw as isincluding the reasonably achievable (ALARA).

c.

Method for identification of what procedural coverage is activity. for the maintenance, construction and modification necessary 3818L 73.0

~

'GPUNC OPERATIONAL QUALITY ASSURANCE Number

? _MUCIOSr PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2

d. Considerations for system / equipment cleanliness centrol. ,

e. Method for 'de6t'fication of post maintenance, construction or modification, testing, including system / equipment functional capability to meet operational requirements in all respects.

f. Method for ensurir.g that maintenance, construction or modification activities, performed ei ther on-si te or of f-si te, are properly reviewed.

g. Considerations for other activities already taking place in the general area.

6.11.1.4 Means (for example, insoections, measurements, tests, welding, heat treatment, cleaning, nondestructive examination and worker qualifications in accordance with applicable codes and standards) for assuring quality of maintenance, modifications or construction activities and measures to document the performance thereof shall be established. Measures shall be established and documented to identify the inspection and test status of items to be used in maintenance, modification, and construction activities.

6.11.1.5 A corrective maintenance program shall be developed to maintain structures, systems and components within QA Plan scope at the quality required for them to perform their intended functions.

Corrective maintenance shall be performed in a timely manner to ensure that QA Plan scope items are adequately maintained in the original, as designed, functional status.

6.11.1.6 A preventive maintenance program including procedures as appropriate I for structures, systems, and components within QA Plan scope shall be established which prescribes tne frequency and type of maintenance to be performed. In all cases, maintenance shall be scheduled and planned so as not to compromise the safety of the plant. Planning shall consider the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Preventive maintenance shall be performed in a timely manner to ensure that QA Plan scope items are adequately maintained in the original, as designed. functional status.

! 6.11.1.7 Proposed modifications shall be reviewed, approved and controlled in accordance with the applicable requirements of the Operating License and Technical Spscifications and procedures governing the design, procurement, cons truc tion, testing and inspection. Modifications to structurcs, systems and components within QA Plan scope shall be reviewed and accepted in accordance with the requirements of Section 2.8 of this Plan.

74.0 3818L '

• GPUNC OPERATIONAL QUALITY ASSURANCE Number glgJ;']lggggg*

PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 5.11.1.8 Design, procurement, construction, testing and inspection of all modifications shall be performed in accordance with the applicable portions of this Plar,.

6.11.1.9 Upon completion of the design phase, the project is turned over to Maintenance, Construction and Facilities for installation with an engineering document package. Procurement of the required materials, parts and components is generally initiated by Technical Functions, but may be initiated by other organizations as necessary.

Maintenance, Construction and Facilities prepares the necessary installation procedures or instructions consistent with engineering requirements, completes the installation and construction testing and compiles the records which it generated for record retention.

Engineering problems identified during installatten shall be (

identified to Tecnnical Functions for resolution using the appropriate documentation as identified in the implementing procedures. Maintenance, Construction and Facilities shall notify Quality Assurance and, where applicable, the Authorized Inspection Agency of all witness and hold points in sufficient time for performance of the inspection. Hitness and hold points may be waived only with prior written authorization from the QA Department.

6.11.2 Responsibilities 6.11.2.1 Directors TMI Unit 1, and Ovster Creek The Directors of the nuclear generating stations are each responsible for:

a. Establishing and implementing preventive and corrective maintenance programs consistent with company policies to maintain the station in a cafe, reliable and efficient condition.

b. Ensuring that maintenance and modification activities are performed in accordance with the requirements of this Plan and the applicable Operating License and Technical Specifications,

c. Establishing administrative control procedures for maintenance and modification work consistent with company policies. (

75.0 3818L

GPUNC OPERATIONAL QUALITY ASSURANCE Number i

Nuclear eta" f0a Tsace MIts IStan0 unit i AND OYSTER CREEK iooo-Ptn-7200.oi Title 6.0 CCNTROL OF STATION ACTIVITIES Revision 2 6.11.2.2 Director - Technical Functions The Director-Technical Functions is responsible for:

a. Reviewing and approving the procedures which define the scope and limits of responsibilities of plant engineering with regards to modifications.

b. Ensuring that design and procurement activities associated with plant modifications are implemented in accordance with approved procedures.

c. Controlling the drawings and specifications used for plant modifications.

d. Preparing and issuing as-built drawings of plant modifications, as appropriate.

e. Ensuring that modifications are designed, procured and installed in accordance with requirements which are either equal to or better than the original requirements,

f. Preparing and filing design, engineering and Technical Functions initiated procurement records in accordance with the QA Records requirements of this Plan.

g. Providing the design and engineering support during installation and testing of plant modifications including the resolution of engineering problems identified during installation.

h. Maintaining control of technical configuration of the plants and maintaining the associated drawings current.

6.11.2.3 Director - Maintenance, Construction and Facilities The Director-Maintenance, Construction and Facilities, through the applicable station Maintenance, Construction and Facilities Director, l 1s responsible for:

a. Planning, scheduling and directing construction, modifications, assigned major maintenance at TMI-1, and all maintenance at Oyster Creek, including those involved in planned and forced outages. '

b. Providing the supervision and labor necessary to complete assigned work.

76.0 3818L L

GPUNC OPERATIONAL QUALITY ASSURANCE Number i

Nu lear PLAN FOR THREE MILE ISLAND UNIT I AND OYSTER CREEX 1000-PLN-7200.01 Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2

c. Ensuring that installations and modifications are implemented in conformance with engineering requirements. Deviations from engineering requirements are not authorized except as specifically approved by Technical Functions and concurred with by QA, in advance.

d. Providing Technical Functions with the information necessary to prepare and issue as-built drawings.

e. Preparing and filing installation records in acccrdance with the QA Records requirements of this Plan.

6.11.2.4 Ofrector - Quality & Radiological Controls The Director-Quality & Radiological Controls, through the Director-Quality Assurance, is responsible for:

a. Reviewing installation and maintenance procedures to assign QA hold and/or witness points to selected documents.

b. Performing inspections and/or examinations required for the acceptance of the installation.

c. Verification of the quality requirements in fabrication and installation specifications.

6.12 Control of Surveillance Testing and Inspection 6.12.1 Requirements 6.12.1.1 A surveillance testing and inspection prog:am shall be established and implemented in accordance with the Operating License and Technical Specification requirements of the plant to ensure that structures, systems, and components within QA Plan scope will continue to operate, keeping parameters within normal bounds, or will act to put the plant in a safe condition if they exceed normal bounds.

6.12.1.2 Provisions shall be made for performing required surveillance testing and inspections, including inservice inspections. Such provisions shall include the establishment of a Technical Specifications surveillance testing schedule reflecting the status of all planned inplant surveillance tests and inspections. Frequency of surveillance tests and inspections may be related to the results of reliability analyses, the frequency and type of service, or age of the iten or system, as appropriate.

77.0 3818L

Nuclear GPUNC OPERATICNAL QUALITY ASSURANCE etAN rCR rsREE "ILE IStANo UNIT i AND OYSTER CREEK Number icoo-etN-7200.oi Title 6.0 CONTROL Or STATION ACTIVITIES Revision 2 6.12.1.3 Additional control procedures shall be instituted, as necessary, to assure timely conduct of surveillance tests and inspections and appropriate documentation, reporting, and evaluation of the results. Procedures shall be established to assure proper review of surveillance test data and the return of systems to an operable status following the completion of testing. These procedures shall include provisions for the documentation of authority, ccnduct, responsibility, and verification involved in returning the system to an operable status. Such provisions shall include the use of procedures, checklists, and independent verification as appropriate, considering the degree that system status was altered during the performance of the test.

6.12.2 Responsibilities 6.12.2.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations are each responsible for:

a. Providing the procedures and schedules necessary to implement l the Surveillance Testing and Inspection requirements of the Operating License and Tecnnical Specifications as applicable to the assigned unit.

b. Ensuring that the requirements for Surveillance Testing and Inspection are completed as required.

6.13 Radiological Control 6.13.1 Requirements 6.13.1.1 A radiological controls program shall be established and implemented at each station to:

a. Control radiation hazards

b. Avoid accidental radiation exposures

c. Maintain exposures to workers and the general population as low as reasonably achievable (ALARA) and within regulatory requirements.

d. Provide guidance and specify appropriate methods or techniques to ensure that the performance of activities are in accordance with sound radiological control principles and in compliance with applicable regulatory requirements.

78.0 3818L

MNuolear GPUNC CPERATIONAL QUALITY ASSURANCE P'^n r0a TsREe site IStAND uNIr i AND OYSTER CREEK Number loo 0.ptN.7200.oi Title 6.0 CONTROL OF STATION ACTIVITIES Revision 2 6.13.1.2 The radiological controls program is to be fully integrated into the applicable activities of each and every phase of cperations at the nuclear generating stations.

6.13.1.3 Procedures shall be provided for the implementation of the radiological controls program. These procedures shall contain the requirements for implementation of the program by the Radiological Controls Department and the requirements for inclusion of radiological controls in the plant cperation, maintenance and testing procedures.

6.13.1.4 The radiological controls program includes the acquisition of data and provision of equipment to perform necessary radiation surveys, measurements conditions. and evaluations for assessment and centrol of radiation 6.13.2 Responsibilities 6.13.2.1 Division Directors Each Division Director is responsible for assuring that the requirements of the radiological controls program as applicable to

' their activities are adequately included in procedures and that the procedures are implemented prcoerly.

6.13.2.2 Director - Quality & Radiolcalcal Controls The Director-Quality & Radiological Controls is responsible for:

a.

Establishing and maintaining the radiological controls program.

b. Providing the personnel, procedures and administrative controls to implement the radiological controls program.

c. Providing administrative and technical guidance applicable to radiological controls, radioactive materials, respiratory protection and radiological engineering including ALARA programs and dosimetry control.

79.0 3318L

%Qjgg[' GPUNC GPERATIONAL CUALITY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000-PLN-7200.01 AND OYSTER CREEK Title 7.0 CONTROL OF RADI0 ACTIVE WASTE Revision 2 7.0 CONTROL OF RADI0 ACTIVE WASTE 7.1 General l

7.1.1 Measures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71 Title 10, Part 20, and Title 49, Parts 100 tnrough 199 applicable to the packaging and transporting of radioactive wastes are satisfied.

7.1.2 Subpart H to 10 CFR 71 identifies the quality assurance criteria applicable to the control of radioactive waste. The portions of this Plan that relate to the criteria in Subpart H to 10 CFR 71 describe to a large extent the administrative controls and quality requirements to be applied in the control, packaging and transportation of radioactive material. A comparison of the r3quirements of 10 CFR 71, Subpart H and the applicable sections of this Plan are listed in Appendix A. These sections of this Plan will be implemented to satisfy the requirements of Subpart H to 10 CFR 71.

7.1.3 It is the policy of GPUN to minimize the generation of radwaste materials consistent with the ALARA concept to minimize personnel exposures and environmental contamination.

7.1.4 Title 10, Part 20, requires that a quality control program be implemented to verify compliance with Title 10, Part 61.55 (Waste Classification) and Title 10, Part 61.56 (Waste Characteristics).

This Plan will be implemented to the extent necessary to assure compilance with those Parts of Title 10 (using a graded approach.)

7.2 Requirements 7.2.1 Procedures and administrative controls shall be developed and implemented to cover the following:

a. Processing of radioactive wastes including the collection, handling and preparation for shipment of radioactive liquids and solids. These procedures shall be consistent with the ALARA program and shall clearly identify the administrative controls and organizational respcnsibilities.

b. Training and cualification of personnel operating radioactive waste processing equipment, health physics monitoring, packaging and shipping (which includes Waste Classification and establishment of Waste Characteristics) and other cperations deemed appropriate by management.

80.0 3688L

ENu:: lear GPUNC OPERATICNAL QUALITY ASSURANCE etAN F0a TsaeE Mite IStANo UNIT i Number AND OYSTER CREEK iOOO-etN_7200.0i Ti tle 7.0 CONTROL OF RADI0 ACTIVE WASTE Revision 2

c. The activities associated with the packaging of radioactive wastes to include tne prcoer selection of the receptacles to be used for containing the waste materials, the selection of the shipring containers (structures used to contain and support the receptacle and its contents) es tablishment of Waste Characteristics, Radiological control inspections of the packaging prior to release, proper markings on the cutside of the package and the preparation of shipping papers and certificates. The activities shall be in accordance with 10CFR20, 10CFR71, and 49CFR.

d.

Movement of radioactive materials within and outside the protected ared to assure personnel protection at all times.

e. The shipment of radioactive material from the Station to be in accordance with the regulations of the U.S. Department of Transportation for the transportation of hazardous materials (49CFR) and of the NRC (10CFR71 and 10CFR20).

f.

The packaging used for transporting of radioactive wastes, whether purchased from an outside supplier or designed by GPUN, shall meet the applicable requirements of 10CFR20, 10CFR71 and 49CFR.

g.

Minimization of the generation of radwaste materials through training programs, prudent scheduling and use of equipment and personnel and good housekeeping practices.

7.2.2 The carriers to be used for transporting of radioactive wastes shall be selected on the basis of their experience, knowledge of 00T regulations, control and maintenance of their equipment and the selection and control of their drivers. The carrier is required to have or shall be supplied documented procedures covering acceptance of materials from a shipper, certification requirements, placarding, storage control, reporting of incidents and security.

7.2.3 Radwaste cperations shall be controlled to minimize personnel exposures or environmental contamination consistent with ALARA.

7.2.4 Operations procedures relating to radwaste shipping and packaging shall be reviewed by QAD to establish any necessary witness or hold points or activities to be monitored.

7.3 Responsibilities 7.3.1 Directors TMI Unit 1, and Oyster Creek The Directors of the nuclear generating stations, thru their on-site staffs shall develop and implement procedures for minimizing the generation of radwaste materials and the processing of radioactive waste and movement of radioactive materials. These procedures shall include the following:

81.0 3688L

r-

?

ENuylear GPUNC OPERATIONAL QUALITY ASSURANCE PUN FCR THREE MILE ISU@ UNIT I AND OYSTER CREEK Numoer 10% A N-72 M .01 Title 7.0 CONTROL OF RADI0 ACTIVE WASTE Revision 2

a. Training of personnel in the methods to minimize the generation of radwaste materials.

b. Processing and packaging of liquid and solid wastes,

c. Collection and identification of radioactive solids sucn as rags, papers, boots, gloves, etc. and have then moved to the Radwaste facility for packaging.

d. Selection of the proper packaging for the specific contents to be shipped, taking into consideration the radiation levels, contamination limits and shipping requirements. Radiological Control surveys the packaging for radiation level and, if acceptable, the Operations Department marks the outside of the package with the appropriate markings, ccmpletes the shipping papers / manifests and certificates, attaches the security seal and advises the carrier that the shipment is ready.

e. Review and acceptance of carrier procedures specified by the procurement documents covering the acceptance of radioactive waste materials for shipment.

f. Review and acceptance of the designs of packaging purchased from an outside supplier.

7.3.2 Director - Quality & Radiological Controls The Director - Quality & Radiological Controls is responsible, for monitoring all radiological activities associated with the processing and handling of radioactive wastes and for providing advice on radiological matters relating to processing, packaging and shipping.

The Director - Quality & Radiological Controls is additionally resporsible, through the Director Quality Assurance:

a. For review and concurrence with procedures describing control of radioactive waste,

b. To monitor, inspect and audit radioactive waste processing operations and radioactive material packaging and shipping to the extent necessary to verify they are cerformed in accordance with established procedures, applicable administrative controls and regulatory requirements.

7.3.3 Responsible Department Managers Each manager shall establish the requirements for personnel qualification and institute training and indoctrination to satisfy these requirements. Training requirements shall be commensurate with the importance and complexity of the activity perforned.

82.0 3688L

NuDiear ' GPUNC OPERATIONAL QUALITY ASSURANCE etAN r0a TsaeE Mite IStANo UNIT i Number iOOO-atN-T200.0i AND OYSTER CREEK Title 8.0 Control of Corrective Actions and Nonconformances Revision 2 80 CONTROL OF CORRECTI'/E ACTIONS AND NONCONFORMANCES

{

8.1 General 8.1.1 Nonconforming materials, parts, components, services or activities within the scope of the GPUN Quality Assurance Program shall be identified and controlled to prevent their inadvertent utilization.

Measures shall be established which ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, j deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The cause of significant conditions adverse to quality shall be determined and appropriate action taken to prevent recurrence. The identification, cause, and actions taken to correct significant conditions adverse to quality shall be documented and reported to the appropriate levels of management.

8.1.2 Significant conditions within the intent of 10 CFR 21 shall be reported to appropriate management levels within the affected organization for review and evaluation.

8.1.3 }

Some deficiencies can be promptly corrected without initiating defined deficiency and/or nonconformance reports.

Such deficiencies are typically those which are isolated to singular occurrences, not repetitive in nature, and/or are generally such that appropriate action to prevent recurrence can be initiated at the time the deficiency is identified may not need any action other than reporting the occurrence. Such deficiencies, when discovered during verification activities, verification activity. shall be documented in the report of the Such deficiencies shall be analyzed as specified by Subsection 8.2.8.

8.2 Requirements 8.2.1 Nonconformances include both hardware problems involving materials, parts, components or systems which do not comply with established requirements and non-hardware problems such as failure to comply with the Operating License and Technical Specifications, procedures, regulations and/or other established requirements.

8.2.2 It is the responsibility of all organizations and individuals involved with the THI-l and Oyster Creek Nuclear Stations to identify and report all nonconformances that affect structures, systems, equipment, materials, parts and components within QA Plan scope.

These nonconformances may be of a minor nature as a result of work activities, inspections, monitoring or reviews, or of a major nature such as those reportable directly to the NRC under 10 CFR Parts 21, 50 and 71 or the station's Operating License and Technical Specifications.

83.0 3898L

GPUNC OPERATIONAL QUALITY ASSURANCE

/ Nu21 ear euN roa TmE snE ISuNO uN1T i Number ioco m N m oo.oi AND OYSTER CREEK Title 8.0 Control of Corrective Actions and Nonconformances Revision 2 8.2.3 Activities such as examinations or checks performed to assess the condition of equipment or its operaticn are not considered to be nonconformances until it has been determined that it does not comply with established acceptance criteria. These activities shall, however, be documented on an appropriate form to control the activity.

Cnce it has been determined that a nonconformance exists the conditicn shall be reported as a ncnconformance and the item controlled to prevent inadvertent use prior to correction.

3.2.4 Procejures shall be established which detali and implement the following corrective action system measures:

a. Conditions adverse to quality shall be evaluated to determine the need for corrective action,

b. Corrective action documentaticn of significant deficiencies snail include identification, cause, and actions taken to correct and to preclude recurrence. CAD concurrence is required for corrective action disposition for all QA0 identified nonconformances.

l

c. Follow-up activities shall be conducted to verify implementation of corrective timely manner. actions and to close out corrective actions in a d.

Significant deficiencies, nonconformances and defects wiilch are potentially reportable to the NRC shall be identified to appropriate management levels for evaluation and reporting to the NRC, as appropriate.

8.2.5 Procedures shall be established which detail and implement the requirements for identification and control of nonconforming items and activities and for the identification of the cause of the conditions prevent and the actions to be taken to correct the conditions to recurrence.

These procedures shall include requirements for the following:

a. Identification of the form to be used for reporting the nonconformance.

b. Description of the nonconforming item or activity and date of identificktion.

c. Identification of the initiator of the nonconformance report.

d. Description of the nenconformance, including identification of the requirement violated.

e. Identification of nonconforming items by appropriate means (tags, labels, etc.) and segregation, if practical, until disposition of the nonconforming item has been determined.

84.0 3898L

GPUNC OPERATIONAL Q'JALITY ASSURANCE Number Nuclear PLAN FOR THREE MILE ISLAND UNIT I AND OYSTER CREEK 1000-PLN-7200.01 Title 8.0 Control of Corrective Actions and Nonconformances Revision 2

f. Disposition of nonconformance. The disposition shall be determined by the organization responsible for the nonconformance. Rework and scrap dispositions are made by the material user without engineering review; use-as-is and repair dispositions require concurrence and justification of cognizant engineering organizations. QA concurrence is required for all dispositions.

g. Notification to the affected organizations of the nonconformance.

h. Verification method verification and close out.

i. Record retention.

j. Required approval signatures of the disposition and the verification.

k. Evidence of review for reportability to the NRC.

8.2.6 Reworked, repaired, and replacement items shall be inspected and tested in accordance with the original inspection and test requirements or acceptable alternatives as determined by Engineering and Quality Assurance. All inspection, testing, rework, and repairs shall be controlled by approved procedures and the results documented.

8.2.7 Prior to the initiation of a preoperational test on a safety related item all nonconformances shall be evaluated for significance or impact on further testing or operation and shall be dispositioned as appropriate. The evaluation / disposition shall be documented.

8.2.8 Nonconformance reports and those deficiencies addressed in 8.1.3 shall be periodically analyzed to detect adverse trends as may be present.

Such analysis will be based upon severity, number, frequency of nonconformances, the causes of the nonconformances and the timeliness of the reporting and resolution of nonconformances. The results of analyses shall be periodically reported to management for review and assessment. When significant conditions are identified or when actions are required by upper management to correct problems, such as a generic problem identified by the trend analysis or repetitive failure to disposition nonconformances, these problems shall be elevated to upper levels of management for resolution.

8.3 Responsibilities 8.3.1 Director - Quality & Radiological Controls The Director - Quality & Radiological Controls through the Director - Quality Assurance is responsible for the following:

a. Review and concurrence of all procedures for reporting and controlling of nonconformances for compliance with the requirements of this Plan.

1 85.0 3898- j

Nuclear GPUNC CPERATICNAL QUALITY ASSURANCE euN roa TsReE Mne IsuND uNIr i AND OYSTER CREEK Number ioco-etn-noo.oi Title 8.0 Control of Corrective Actions and Nonconformances Revision 2 8.3.2 Of rector TMI Unit 1 and oyster Creek The Directors TMI Unit I and OCNGS are each responsible for ensuring that nonconfornances are reported and corrected for all activities within QA Plan scope. Plant items such as failures, malfunctions, deficiencies, deviations and defective materials, parts or .

compcnents are handled in a manner consistent with their importance to nuclear safety and reviewed in accordance with apprcpriate l procedures and the applicable Technical Specification.

8.3.3 Responsible Department Manager 8.3.3.1 Each Director / Manager is responsible for the dispositicn and corrective action of nonconformances identified as within the scope of his responsibilities.

In the specific case of materials, parts, components, or systems which have not been installed or accepted as operational at the Station, the responsible Director / Manager approves and the Quality Assurance Department concurs with the disposition of nonconformances.

8.3.3.2 Each Director / Manager is responsible for ensuring that nonconforming conditions are identifiea and controlled in accordance with approved procedures.

96.0 3898L

[

GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK

Title:

9.0 CONTROL OF TRAINING Revision 2 9.0 CONTROL OF TRAINING 1 9.1 General GPU Nuclear is committed to the safe operation of its nuclear generating stations and the protection of the public health and safety. This commitment is accomplished, in part, by developing or maintaining the knowledge and skills necessary to manage, supervise, perform and verify activities within the scope of this Plan.

GPU Nuclear considers training to be an important means of effectively developing and maintaining proficiency and solving or avoiding performance problems. Therefore, training shall be provided as determined to be necessary which develops, maintains and supplements the skills and knowledge necessary to perform activities within the scope of this Plan.

Training shall be based on training need assessment. The extent to which prior education, training and experience is sufficient to provide for the requisited job proficiency will be considered in deciding whether and what training will be provided for an individual. The content of the training provided shall be consistent with regulatory requirements and commitments.

9.2 Requirements 9.2.1 Programs accredited by INPO and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security Force Training Programs shall be ceveloped and maintained in accordance with a Training System Deve'opment (TS0) process. Such a process provides a systematic approach to the design, development, and delivery of effective training programs. TSD is based upon behavioral learning objectives which are linked directly to job performance requirements.

9.2.2 The accuments associated with the training programs accredited by INPO and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security Force Training Programs shall be reviewed, concurred with, and approved in accordance with the Training Management Control Documentation System procedure to assure that related regulatory, management, technical, and functional requirements and ccmmitments are incorporated.

l l

l 87.0 4162L

Nu'olear GPUNC CPERATICNAL QUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.31 AND OYSTER CREEK

Title:

9.0 CONTROL OF TRAINING Revision 2 9.2.3 Technical content review and interface process shall be established between the user department and the Training and Education Department to assure programs accredited by INP0 and the Radiation Worker, Respiratory Protection, Emergency Preparedness, Fire Brigade, and Security Force Training Programs are updated to reflect job performance, plant modifications, procedure changes, regulation changes, and job scope chang s.

9.2.4 The review and approval of tne specific training program documents developed and/or implemented by organizations, including contractors and/or vendors, other than Training and Education Department shall be delineated in procedure (s) or plan (s). The extent of Training and Education review of such training shall be as defined by a procedure (s) or plan (s).

9.2.5 Procedures shall be established for the qualification and certification of instructors for programs accredited by INPO and the Radiation Worker, Respiratory Protection Emergency Preparedness, Fire Brigade, and Security Force Training Programs.

9.2.6 To assure the integrity of qualification processes which utilize examinations, procedures for the control of examinations shall be used to address examination security.

92.7 A program and course evaluation process (s) shall be used to evaluate the effectiveness of training programs and courses in meeting training objectives and in improving job performance. Such a process (s) and the extent of its usage shall be delineated in the appropriate procedure (s) or plan (s).

9.2.8 Procedures shall be established to assure that all required records associated with training provided within the scope of this Plan shall be identified, generated, maintained, and retrievable.

9.3 Responsibilities 9.3.1 The Director, Administration is resconsible through the Director, Training and Education for providing selected training to GPU Nuclear and specified contractor personnel as necessary to prepare them to carry out their assignea duties and to meet corporate policies, applicable laws, regulaticns, licenses, and technical requirements.

Specifically, the Director, Training and Education, shall be responsible for the establishment and maintenance of a training organization to:

i 38.0 l 4162L t

GPUNC OPERATIONAL QUALITY ASSURANCE ' Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK

Title:

9.0 CONTROL OF TRAINING Revision 2

a. Manage the training function censistent with regulatc'y requirements and commitments, corporate priorities, and the Training and Education Department TSD Process.

b. Provide personnel with training which supports the develcoment and maintenance of knowlecge and skills required to perform activities within the scope of this Plan in & manner that will ensure the safe and effective execution of their duties,

c. Assure that the content of training provided the Training Department is consistent with and incorporates apprcpriate GPUN, local, state and federal regulatory requirements and ccmmitments, including timely requalificaticn.

9.3.2 Department Directors and Managers are responsible for assuring that their staff meltbers are quallfled to carry out assigned ictivities within the scope of this Pian. Training activities perf: armed under their direction shal' be performed consistent with the requirements of this Section of this Plan.

i 1

l 89.0 4162L

/

MNuclear GPUNC OPERATIONAL QUALITY ASSURANCE eta" r0R rsace "t'E ISLANo uNIr ,

AND OYSTER CREEK Number iOOO PLN_7200.0i

Title:

10.0 AUDITS Revision 2 10.0 AUDITS 10.1 General A comprenensive and documented audit system snall be established, implemented and maintained to ensure that:

>.. Policies, plans, procedures and instructions define sufficient organizational responsibilities, prescribe methods and provide results consistent with Operating License requirements, other regulatory requirements and commitments, technical requirements, contractual requirements, anj this Plan.

b. Plans, procedures and instructions are effectively implemented.

c. Cort ective action systems and management reviews provide for timely completicn of requisite action for identified deficiencies /nonconformances/ occurrences / events.

d. Corrective action systems and management reviews provide effective identification and prevention of recurrent and/or significant program nonconformances.

e. Data is provided for GPUN management to optimize the efficiency of methods utilized to ensure regulatory compliance.

f. Data is provided for the continuing assessment of the effectivenes. GPUN Quality Assurance Plan and implementing documents.

10.2 Requirements 10.2.1 A comprehensive sy-tem of audits shall be established and conducted for both internal and external activities which are within the scope of this Plan.

10.2.2 Planned and scheduled audits shall verify compliance with the following:

a. Operating License conditions, Technical Specification requirements, other regulatory requirements and commitments and the requirements of thi: Plan.

b. Regulatory Guides, ANSI Standards, and other codes an> standards as endorsed by Appendix C of this Plan or other regulatory requirements or ecmmitments.

90.0 3899L

CPUNC OPERATIONAL. QUALITY ASSURANCE Number O OY TER RE

Title:

(0.0 AUDITS Revision 2

c. Docurrents which prescrite methods and provide the technical requirerrents for activities or items within the scope of this Plan.

d. Contractural requirements associt ted with dxtcnal organizations providing nuclear fuel, in-core components and selected technical support and engineering services within the scope of this Plan.

10.2.3' The audit system shall include;

a. Delineation of the authority, respcnsibility, and organizational independence of those responsible for the management and conduct of audit program.

b. Procedure (s) for the qualification and certification of lead auditors.

c. Procedure (s) for the scheduling, preparation, performance, reporting of the results of audits, and distribution to aopropriate levels of management.

d. Periodic analysis of audit results and the reporting of such results to appropriate levels of management.

e. Follow-up action to be taken based upon individual and collective audit results.

10.2.4 The frs.iuency of conducting scheduled internal audits shall be as specified in the nuclear units' Technical Specifications.

Unscheduled audits may be conducted at any time. Re-audits shall be scheduled as may be required to assure that corrective action (s) to previous audit results has been effectively implemented.

10.2.5 The frequency of conducting external audits of selectr.d suppliers of technical support, environmental monitoring, radwaste shipping, ccmputer, radioanalytical, and engineering services shall be scheduled once within the life of the activity or every three years depending on the duration of the contractual relationship. Audits of the design fabrication and shipping activities associated with nuclear fuel and in-core components shall be scheduled and conducted as necessary to assure conformance to procurement document requirements.

10.2.6 Each audit shall be led by a GPUN certified lead auditor. Audit team members shall be utilized as required and will be classified as l either auditors or technical specialists, depending on their function on the audit team.

10.2.7 Those GPUN and external organizations providing items and/or conducting activities within the scope of this Plan are subject to audit consistent with the requirements of this Plan.

l 91.0 3899L

c ENuclear GPUNC OPERATIONAL QUALIT( ASSURANCE etAN fcR TsREE "t'E 15taso ustr i AND OYSTER CREEK Number i0c0. Pts 7200.0i

Title:

10.0 AUDITS Revision 2 10.2.3 Audits shall be performed in accordance with pre-established written procedures or checklists. The personnel utilized to perform on an audit shall not have any responsibility for the activity audited.

10.2.9 Audits shall consist of reviews of approved documents and records and observation (s) of selected activities in sufflClent detail to determine the appropriateness of the documents for use, effectiveness of implementation and the effectiveness of actions taken to correct previous nonconformances.

10.2.10 Auditea organizations shall provide sufficient support to assure the accuracy of the audit results, review and response to audit nonconformantes, and effective resolution / prevention of deficiencies.

The corrective actions required to resolve adverse audit findings shall be defined and implemented in a timely manner.

10.2.11 Audit finding nonconformances shall be followed up in a timely manner. Such adverse audit findings shall typically not be closed until the effective implementation of corrective action (s) is verified.

10.2.12 Sufficient records shall be generated and maintained to provide documentation of audit system scope of coverage, individual audit coverage (i.e., audit plans, checklists, or equivalent), audit reports, lead auditor certifications, followup and verification and results of periodic analysis of audit results.

10.3 Responsibilities 10.3.1 Director - Quality & Radiological Controls The Director - Quality & Radiological Centrols is responsible through the Director - Quality Assurance to:

a. Establish and implement the audit program and assure all required areas are audited.

b. Provide the auditing organization which meets the requirements of this Plan.

c. Evaluate the effectiveness of the audit program.

d. Ensure the development and implementation of the audit schedule,

e. Periodically analyze the results of audits and inform the Office of the Fresident and the affected Division Director (s) of the results.

l l

l 92.0 l 3899L

GPUNC OPERATIONAL QUALITY ASSURANCE llL) }l()(3l* PLAN FOR THREE MILE ISLAND UNIT 1 Numcer 1000-PLN-7200.01 AND OYSTER CREEK

Title:

10.0 AUDITS Revision 2 10.3.2 Director (s) - Audited Organization (s)

The Director (s) of the audited organization (s) are responsible through Directors / Managers to ensure:

a.

Sufficient support is given to the audit procsss to optimize the accuracy of the audit results.

b.

Sufficient review of audit results is conducted to assure that effective preventive measures for audit nonccnformances are defined and implemented.

c. Responses to audit finding nonconformance(s) are reviewed and approved by the responding organizatica prior to submittal to the auditing organization.

d. Response to an audit finding nonconformance(s) is submitted to the auditing organization in a timely manner as defined in implementing plans, procedures and/or instructions.

e.

Corrective action (s) to resolve the audit finding i nonconformance(s) is taken in a timely manner.

93.0 3899L

a

/ Nusiear GPUNC OPERATIONAL C'UALITY ASSURANC;.'

PLAN FOR THREE MILE ISLAND UNIT I Nuncer 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDICES APPENDIX A Comparison Chart of Operational Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards APPENDIX B QAD Documents Review Requirements APPENDIX C NRC Regulatory Guide Ccmmitments and Exceptions APPENDIX 0 Terms and Definitions 94.0 3900L 9

u o

C) r-22 c,

e APPENDIX A 2,

u COMPARISON CHARLQLDELRAllDItAL_DUAllILASSURetfCLPL AN RE0'llRLMLftIS "

WlI1L1HOSL0f VARIQUS_ PARIS _Df_IMI CQQLQf_[1DERAL REGULATIDMS_A!iQ_hWCLEAR INDUSTRY SIAhDARDS a 2

C A

W

n. mums 10_ Cf!L50.Jop._ B . A.NSLhi5 Z_ 10 CfR m _Subparl N Calenon OA Pllo Paraoraoh OA PIAD CUltrJ 90__QLEl3fL . __ . ._ _

Edf3gEdph _ _ f MSI_ H IL 7 : _19M _ .__ _

QA fla!1 P3rjgraph___QA _Eja0 I 1.0 2.0 2.0 71.103 1.0 3.1 II 2.0 3.6 1.0 78.105 1.0 S.2.12 3.3 2.0 3.2 III 4.0 4.0 4.0 71.107 4.0 I.0 5.2.33 5.0 IV 5.1 3.3 1.0;2.5 5.2.14 5.0 5.1 78.109 5.1 3.4 8.0 >> 10 c)

V 3.1 6.0 3.1 71.111 3.1 1.0; 5.2.15 3.0 VI 3.2 Supplements 5.2.I6 @$S[2E

'.0 3.2 71.113 3.2 6.6 ;c ;c VII 5.8 4.0 1.0:2.4:2.8; 5.2.17 8.0 5.1 71.115 5.1 6.2 b2 ,, C

VIII 5.2 9.0 9.0 5.2.18 5.2 71.117 5.2 '. . I 6.4 to C) C)

IX 6.4.6.11 2.0 5.2.19 10.0 6.4;6.11 71.119 6.4;6.11 5.2.1 1.4 5.3.1 6.5 siPOj' j3 x 6.2 11.0 6.2 7.0 3.1 20 -4 po

. x1 6.5 12.0 Supplenents 5.3.2 3.1 CD x11 6.6 13.0 6.5 6.6 71.121 6.2 5.2.2 3.1 5.3.3 3.1 r)553 23 rn -4 7.0 5.2.3 3.1 XIII 6.7 14.0 6.7 71.123 6.5 5.3.4 3.1 XIV 6.8;6.10 15.0 6.s;6.IO 5.2.4 3.1 5.3.5 6.11

['"'[]

XV 7.0 5.2.5 3.1 7% 3r x-8.0 16.0 8.0 71.125 6.6 5.3.6 6.13 "2 F-xv1 5.2.6 6.8;6.10 8.0 17.0 8.0 7.0 5.3.7 6.6 ni 43 5.2.7 6.11 xv11 xvIII 3.3 9.0 15.0 19.0 3.3 9.0 71.127 6.7 5.2.8 6.12 5.3.8 5.3.9 6.13 3.1

,, jj 7.0 5.2.9 -

5.3.10 on r,r-71.129 6.5;6.8 r 6.8:6.10 5.2.10 6.9 7.0 5.2.11 8.0 $$22 71.131 8.0 CJ 71.133 8.0 c=c[$,

71.135 3.3 u

• • c:

71.737 9.0 -4 ao 2-

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O O.

Nuclear GPUNC OPERATICNAL QUALIT( ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number IO00-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APOENDIX 8 QA3 Documents Review Requirements QAD shall salectively review documents which prescribe methods to implement activities within the scope of this Plan or provide the analytical basis or technical requirements for items, parts, materials and activities that are althin the sccoe of this Plan.

The purpose of such reviews is to verify that such dcccments will be or are apprcpriate for use. The minimum review criteria to be used, as appropriate to the document reviewed, to meet this criteria is proviced in Subsection 3.1.2 of this Plan.

The classes of documents typically reviewed include plans, procedures and instructions, and changes; procurement documents; engineering documents; maintenance authorizing documents; cperating orders; special orders; and temporary proceduras. Refer to Section 3.2.2.1 for specific types of documents which will periodically be verified by document review.

The timing (i.e., prior to or after implementing approval) and extent of such reviews will be prescribed by precedures. These procedure (s) will be censistent with the following:

o The text and Appendix C of this Plan.

o Plans, procedures, instructions and changes thereto that shall be reviewed by Quality Assurance personnel prior to implementing approval shall be identified on GPUN Review and Approval Matrix.

o Changes to the quality classification procedure (s) and the GPUN Review and Approval Matrix shall be reviewed for concurrence oy thc Director-QA prior to implementation of the change, o Procurement and engineering documents which prescribe technical and/or quality requirements for items, parts, materials, and changes to existing Diant may or may not be reviewed by QA prior to authorizaticn to issue. Such documents and changes shall be reviewed prior to autho'17.ation to issue if inspection points are to be specified, revised or affected.

o Maintanance and installation documents and changes shall be reviewed prior to implementation to specify inspection points.

96.0 3900L

gggy GPUNC CPERATICNAL QUALITY ASSURANCE PLAN FOR ;HREE MILE ISLAND UNIT 1 Numoer AND OYSTER CREEK 1000-PLN-7200.01 Title Appendices Revision 2 APPENDIX C QUALITY ASSURANCE PROGRAM NRC REGULATORY GUIDE CCMMITMENTS A_ND EXCEPTIONS This Appendix identifies those Regulatory Guides which contain Quality Assurance Program requirements and identifies the GPUN positions relative to compliance. Part I of the Appendix is a tabulation of the Regulatory Guides the corresponding ANSI Standard and of theRemarks.

Appendis. Alternatives or clarifications are detailed in Part 2 Compliance with these Regulatory Guides will apply to modifications, additions and activities performed af ter issue of this QA Plan and does not imply backfitting and/or retroactive compilance. It is also to be recognized that existing plant conditions, may prevent or preclude the satisfaction of all requirements of a specific Regulatory Guide. These conditions will be documented and, along with the justification, will be approved by the Director - Quality Assurance.

97.0 3900L

e L.s o

o O

r-APPENDIX C. PART I

-4 CGtillMENT30 SUALIIL ASSUBM#CLREGULATORLGUIDES_FOR GPUN n RIG d VIDE DEGRE L Df 1.8 MSLSID.

5/77. Rev. IR Perse c.;s Selection and Training N18.1 CDtiELIMCL ELMAPP$ d U

g 1.26 2/76 Rev. 3 3971 Modified See attached ccennents.

3 C

4A Classifications and Standards Modified for Water Stream and Radioactive See attached conments.

• Waste Containing Components of "

Nuclear Power Plants 1.28 2/79 kev. 2 Quality Assurance Program Requir ements (Design and N45.2 1977 tull Coniply with Regulatory Pudition. N Construction) 1.29 9/78 Rev. 3 Seismic Design Classification Modified Same coment as for Reg. Guide 1.26 >%a l.30 B/ll/72 QA Reauirements ror tae Instaii- N45.2.4 i972 nodified 2(( =

action. Inspection and Testing See attacned con.nents. 9 ,o=

of Instrumentation and Electrical Equipment MOO M"M 4

1.31 4/78 Rev. 3 Control of Ferrite Content in full xgg Om

@ Stainless Steel Weld Metal Congly with Regulatory Position. mm --4 e-.

pmg O 1.33 2/78 Rev. 2 Quality Assura,1ce Program N18.7 Requirements (Operation) 1976 Modified AZ>

See attached consnents. *F r-1.37 3/16/73 QA kequirements hr Cleaning of N45.2.1 fluid Systems and As Jciated 1973 Modified See attached Consnents. +- >0 Components of Water asoled M r-Nuclear Power Plants {]

z .<

1.38 5/77. Rev. 2 o OA Requirements for Packaging. N45.2.2 >

Shipping. Recetving. Storage and 1972 Modified See attached coments. c vi Handlifeq of Items for Water My

--4 m Cooled huclear Power Plants *

-z 3 39 9/77. Rev. 2 Housekeeping Requiren(nts f or Water Cooled Nuclear Power 94 W -- 39 3 Modified See attached consnents.

O Plants 1.54 e/73 04 Requirements for Protective 101.4 a J 2 Coatings Applied to Water 1972 Modified Cooled Nuclear Power Plants See attached consnents.

]

b5 1.55 9/80. Res. 1 -

O{

y, Qualifications of Nuclear power N45.2.6 Plant Inspection. E= amination i97a Modiried See attacned consnents. b C and Testing Personnel " r*

a'v O

O O

w u3 C) APPENDIX C, PART I r2 -4 REG _GUIDI ENSI_SIQ.

DLCREL .Df CQMPLIAN[L ELMARE$ --

m 1.64 6/76 Rev. 2 Quality Assurance Requirements N45.2.ll 1974 Modified for the Design of Nuclear See attached comments, Power Plants ((

13 1.74 2/74 Quality Assurance Terms and N45.2.10 1973 full Comply with RegulJtory Position. 1:

Definttions C[

r3 1.88 10/76 Rev. 2 Collection Storage and Hain- g3 mums N45.2.9 1974 Hodified See attached comments. ^

tenance of Nuclear Power Plant Quality Assurance Records 1.94 4/76. Fe. 1 QA RcQuirements for Instal- N45.2.5 1974 Hodified 9 lation. Inspection and Testiig of See a t t ached c omment s .

Structural Concrete & Steel during Nuclear Power Plant Construction 2- na c%

2 r-o w c'-

1.116 5/77. Rev. OR QA Requirements for Installa- N45.2.8 1975 Modified LE 2r tion. Inspection and Testing of See attached comments. $f ,, r)

Mechanical Equipment and Systems on C) C)

~* >

jj 1.123 7/77 Rev.) QA Requirements for Control of N45.2.33 1976 Modified rn Jo -1 30 r'n' Procurement of Items and Serv- See attached comments. c3$53; C) ices for Nuclear Po-cr Plants xJrn rn P1 C)

-4 1.142 10/s1, Rev. 1 Safety-Related Cuncrete Struc- N45.2.5 1974 Modified X '3l: >

tures for Nuclear Power Plants ANS6.4 See attached comments.

1977 77 F-(Other than Reactar vessels AC1318 1977 ni and Containments) ,, ,,

1.143 10/79. Rev. 1 E2[,'

Design Guidance for Radioactive Modified 1. -4 Waste Management Systems. See attached comments. '

LE -<

Structures, and Components C3 3,

nstalled in tight-Water. c: Ln Er u, Couled Nuclear Power Plants

• l.144 1/79 Requis ements f or Aud. ting of " M. r N45.2.12 1977 Modified See ats. acned comments.

Quality Assurance Programs for ~~ [5 Nuclear Power Plants rn 1.146 e/Ea Qualification of Quality N45.2.23 1978 full Comply with Regulatory Position.

Assurance Progran Auditors for Nuclear Power Plants $f jf

                                                                                                                             <           c) -3
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c Nuclear GPun: OPERATICNAL QUALIT( ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000-PLN 7200.01 AND_Of STER CREEK Title Appendices Revision 2 l APPENDIX C - PART 2 NRC Regulatory Guide 1.3, Rev. 1-R, May 1977 Personnel Selec on and Training Guidelines have long been established in tre company with respect to avar '- jobs to plant maintenance, operations, and other bargaini, nit personnel ano may be involved in testing, evaminatfor, and inspection activities. Personnel are qualified in accordance with the Jco Description Manual. GPUN oelieves that the requirements specified in tne Job Description Manual meet the intent, and in many cases, exceed the requirements of ANSI N18.1. In certain specific cases, we envision that there may be individuals in the future who will be quallfled by GPUN because it feels the individual is capable of performing a job cven though the individual does not meet the detailed guidance contained in ANSI N18.1 with respect to length of experience and formal training. The non-bargaining unit nuclear station and Corporate-based personnel have been upgraded to meet ANSI /ANS 3.1-1978 except as otherwise noted in the Technical Specifications. NRC Regulatory Guide 1.26. Rev. 3, February 1976 Quality Group Classification and Standerd fer Water, Steam and Radioactive Haste Containing Ccmponents of NJClear Power Plants Since the original design and construction of TMI 1 and Oyster Creek was to different classi"ication criteria than contained in this guide; GPUN will comply with the regulatory position of this guide with the following clarifications:

1. For modifications to existing plant systems and for new construction, items will be classified by Technical Functions consistent with the original design basis utilizing the classification process described in 2.2.1 and 2.3 of this Plan. This classification will not degrade the safety of the system being modified.

2. Tie-in's to existing plant systems will be made to the sare or more recent acplicable code, standard and technical requirements which were originally 30 plied to the system to which the tie-in is to be made.

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• GPUNC CPERATIONAL QUALITY ASSURANCE Number PLAN FOR THREE Mf:." ISLAND UNIT 1 100U-PLN-7200.01 AND OYSTER CREEK _

Ti tle Appendices Revision 2 APPENDIX C - PART 2 NRC Regulatory Guide 1.30, August 1972 Quality Assurance Requirements for the Installation, Insoection and Testing of Instrumentation and Electric Equipment GPUN shall comply with the Regulatory Position established in this Regulatory Guide !n that QA programmatic / administrative requirements included therein shall apply to maintenance and modification activities even thougn sucn requirements were not in effect originally. Technical requirements associated with maintenance and modifications shall be the original technical requirements or better (e.g., code requirements, material properties, detign margins, manufacturing processes, and inspection requirements). Sections 5.2 and 6.2 of ANSI N45.2.4 list tests which are to be conducted during the construction phase. In lieu of this, GPUN utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test procedures during the operational phase. NRC Regulatory Guide 1.33. Rev. 2, February 1973 Quality Assurance Program Requirements (Operation) The GPUN QA Program complies with the regulatory position of this guide with the following clarifications:

1. Regulatory Position C.4 of the regulatory guide The frequency of performance and the minimum topical coverage of internal audits will be consistent witn Section 6 of the nuclear units' Technical Specifications. Paragraph C.4.a is inter-'eted to mean audits will be conducted once each 6 months to verify ;nat the nonconformance and corrective action program is properly implemented and documented, particularly as related to actions taken to correct deficiencies that affect items classified as nuclear safety related or regulatory required.

2. Paragraph 5.1 of ANSI N18.7-1976 titled "Program Description" This paragrapn refers to the compilation of a "summary document" to identify the sources, index the source documents to the requirements of this standard and to provide a consolidated base for the description of the program. For the purpose of clarity, this "Cperational Quality Assurance Plan for Three Mile Island Unit I and Oyster Creek" is tne "summary" document required. Appendix A correlates the sections of this Plan to ANSI 18.7-1976. Section 2.0 provides the "consolida+ed" base and description for the program.

Implementing documents are identified in Section 3.0, are required to be consistent with this Plan and Appendix C of this Plan, and are marked as stated in Section 3.0. 101.0 3900L

b ENuclear GPUNC OPERATNL QUAUTY ASSURMCE PLAN FOR THREE MILE ISLAND UNIT 1 AND 0/ STER CREEK Number 1000-PLN-7200.01 Title Accendices Revision 2 APPENDIX C - PART 2

3. Daragraph 5.2.2 of ANSI N18.7-1976 titled "Procedure Adherence" In accordance with Section 6.8.3 of both the Oyster Creek and THI-I Technical Specifications, temporary changes shall be approved by two members of GPUNC Management Staff quallfled as Responsible Technical Reviewers and knowledgeaole in the area affected by the procedure.

For changes which may affect the cperational status of facility systems or eaulcment, at least one of these individuals shall be a mencer of facility management or supervision holding a Senior Reactor Operator's License on the facility.

4. Paragraph 5.2.8 cf ANSI N18.7 - 1076 titled "Surveillance Testing and Inspection" In lieu of a "master surveillance" schedule, a technical specification surseillance testing schedule shall be established reflecting the status of all inplant surveillance tests and inspections required by technical specifications.

5. Paragraph 5.2.15 of ANSI N18.7 - 1976 titled "Review, Approval and Centrol of Procedures" The third sentence of the third paragraph is interpreted to mean applicable procedures shall be reviewed following a reportable incident such as an accident, an unexLected transient, significant cperator error, or equipment malfunction.

6. Paragraph 5.2.15 of ANSI N18.7 - 1976 titled "Review, Approval and Centrol of Procedures" Plant procedures shall be revised as necessary to permit compliance.

Plant procedures that are infrequently used snall be reviewed at least once every four years instead of every two years.

7. Paragraph 5.2.17 of ANSI N18.7 - 1976 titled "Inspections" Not all inspections will require a separate inspection report.

Inspection requirements may be integrated into appropriate procedures or other documents with the procedures or documents serving as the record; however, records of inspections will be identified and retrievable. 102.0 3900L

J Nuclear @UNC OPERATIONE WAUTY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000 PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2 NRC Regulatory Golde 1,37, March 16, 1973 Quality Assurance Requirements for Cleaning Fluids Systems and Associated Components of Water Ccoled Nuclear Power Plants The GPljN Qu311ty Assurance Program complies with the regulatory positicn of this guide with the following clarifications:

1. The second sentence of paragraph C.3 should be amenced to reaa:

                 "The water quality for final flushes of fluid systems and associated components sha'l be at least equivalent to the quality required for normal operation.

This reautrement does not apply to disolved oxygen or nitrogen limits nor does it infer that chromates or other additives normally in the system water will be added to the flush water."

2. Paragraph C.4 should be amended to add:

Material such as inks, temperature indicating crayons, labels, wrapping materials (other than polyethylene), water soluble materials, lubricants, NDT penetrant materials and couplants, which contact stainless steel or nickle alloy material surfaces snall contain no more tnan trace elements of lead, :'inc, copper, mercury or other low melting alloys or compounds. Maximum allowable levels of water leachable chloride ions, total halogens and sulfur compcunds shall be defined and imposed on the aforementicned materials.

3. Section 2.1 of ANSI N45.2.1-1973 states that required planning is frequently performed on a generic basis for application to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which meet the requirements of the Standard. Indivicual plans for each item or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Secti n? 11 Paragraphs 2 and 3 cf ANSI N45.2-1977 which provides for examination, measuremant or testing to assure quality or indirect control by monitoring of processing methods.

However, final cleaning or flushing activities will be performed in accordance with procedures specific to the systen. 103.0 3900L

g '7] g f GPUNC OPERATICiNAL QUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000 PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

4. GPUN intends to conform to the Cleanness requirements of Section 3.1 of ANSI N45.2.1-1973 with the exception of permissable particle sizes for cleanness Classes 6 and D. In these Cases, GPUN will conform to the requirements of ANSI N45.2.1-1930, Section 3.2.2.1(b) which states, "These shall be no particles larger then 1/32 in. by 1/16 in, icng (0.3 mm by 1.6 mm)" for cleanness Class B and Section 3.2.4.4 which states, "Particles no larger tn3n 1/16 in. by 1/8 in. long (1.6 mm by 3.2 mn) cn a 14-mesh (1.4 mm. ASTM E-11 Specification for Wire Cloth $leves for Testing Purposes) or finer filter, or the equivalent." for cleanness Class D.

5. Section 3.1.2.1 of ANSI N45.2.1-1973 states th3t surfaces shall be examined without magnification under a IIghting level (background plus supolementary lighting) of at least 100 foot candles. GPUN intends to permit the use of neutral 137. gray card with a 1/32" black line for determining acceptability of illumination in lieu of the 100 foot candles. 6. Section 4.0 of ANSI N45.2.1-1973 states that items are not to be delivered to the pcint of installation socner than necessary unless the installation location is considered a better storage area. The strategy for the storage of items is based on many factors, one of which is to not adversely affect the item's acceptability wnile in storage. If other factors make it desirable to store an item at the installation site, and the locaticn is acceptable from a quality standpoint, it is not our intention to eliminate that site as a potential storage area. As an alternate to this requirement. items may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations. E< ample - reduced nandling or easier access, thereby reducing susceptibility to handling danage. In all such cases, equipment stored in place will be protected in accordance with Section 5 of ANSI N45.2.1-1973. 7. Section 6.0 of ANSI N45.2.1-1973 states that where environmental contamination causes degradation of quality, seals are installed and the item is tagged witn identifications and instructicns for seal removal. GPUN utilizes procedural controls which spe-ify the authorization requirements for seal removal. "Tags" are not normally utilized. 104.0 3900L L .

Nuclear wuNc CPEam0NAt cuAun ASSuRace PLAN FOR THREE MILE ISLAND UNIT 1 numeer 1000-PLN- 7200.01 AND 0fSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

8. Secticn 7.2 of ANSI N45.2.1-1973 allows piping systems to be flushed only with water. A wat3r flush of piping systems using other fluids can lead to contamination and/or other problems which would affect the reliaoility of these systems. ANSI N45.2.1-1980 provides requirements and reccmmendations for flushed using fluids other than water. For flushing of hydraulic instrument, control, lubrication and other non-water systems, GPUN intends to conform to Sections 3.4.2, 3.4.3, 3.4.4, and the guicance of Table 3.3 from ANSI N45.2.1-1980. Specifications and procedures for flushes utilizing this exception must specify, as applicable: particulate contaminate levels; water content; water soluble contaminate levels; organic contaminate levels, flush time, flush pressure / flow / amount; type of fluid to ce used; and, the restrictions ident; fled in Sections 3.4.2, 3.4.3, and 3.4.4.

NRC Regulatory Guide 1.38, Rev. 2, May 1977 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of items for Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with the regulatory position of this guide with the following modifications or clarifications to ANSI N45.2.2-1972:

1. Section 2.7, Classification of Items. The four-level classification system for storage of items will be followed, however, tne designated classification level may not be explicitly identified on the item.

The classification level will, however, be traceable through the procurement documents. Classification diffe-ing from Section 2.7 will be considerec acceptable provided no degradation is assureo; for example, electric motors designed for outside service may be stored in a level C area rather than a level 8.

2. Section 3.2, Levels of Packaging. The four level classification system for packaging of items may not be used explicitly. For commercial grade items standard commercial grade packaging requirements may be specifieo.

3. Section 3.6 concerns prevention of halogenated materials from contacting stainless steel or nickel alloy materials. The clarifications applicable to Regulatory Guide 1.37, identified previously, also apply to this section of ANSI N45.2.2.

4. Section 3.7.1 Cleated, sheathed boxes will be used up to 1000 lbs.

rather than 500 lbs. as specified. This type of box is safe for, and has been tested for, loads up to 1000 lbs. Otner material standards (i.e., FED Spec. PPD-8-601) allow this. Special qualification testing shall be required for loads in excess of 1000 lbs. { 105.0 3900L

J ENuclear @UNC @ERAHONAL QUAUTY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

5. Section 5.5, Correction of Ncnconformances. This section provides fcr "rework" and "use as is" dispositions for nonconforming items.

As an alternate, the "repair" disposition (as defined in ANSI N45.2.10-1973) sill also be used.

6. Section 6.2.1 For storage of level D items access will be controlled and limited by posting. Other positive controls such as fencing or posting of guards will be provided for nigher stcrage levels.

7. Section 7.4 states that a system should be established to indicate acceptability of all equipment and rigging af ter each inspection, specify contro! of nonconforming lifting equipment, and supplement periodic inspections with special visual and nondestructive examinations and dynamic load tests. In lieu of this, GPUN does perform dynamic load tests on new equipment, preventive maintenance on cranes, nondestructive examinaticn of lif ting hooks annually, and a visual inspection of lif ting equipment prior to use.

8. Appendi< A.3.4.1 The las t sentence of A.3.4.1(4) and (5) 'hould be corrected as follows:

(4) "However, preservatives for inaccessible inside surfaces of pumps, valves and pipe systems containing, reactor coolant water shall be the water flushable type." (5) "The name of the preservative used shall be indicated to facilitate touch up."

9. Appendix A 3.4.2, Inert Gas Blankets. There may be ases involving large or complex shapes for which an inert or dry alc purge flow is provided rather than static gas blanket in order to provide adequate protection due to difficulty of providing a leak proof barrier. In these cases a positive pressure purge flow may be utilized as an alternate to leak proof barrier.

10. Appendix A.3.5.2 Tapes will meet a sulohur limit of 0.30% by weignt instead of 0.10% as specified in A.3.5.2(1)(a).

This limit is reasonah e cased upon the chemical content of commercially available tapes. Tapes will be of a contrasting color rather than "Brightly Colored" as required by A.3.5.1(3).

11. Appendix A.3.7.1 be imposed:

In lieu of A.3.7.1(3) and (4), the following will Fiberboard boxes shall be securily closed either with a water resistant adhesive applied to the entire area of contact between the flaps, or all seams and joints shall be sealed with not less than 2-inch wide, water resistant tape. 106.0 3900L

J ENuclear GPuNC ePcRATIcNAt QuAtITv AS$uaANCE PLAN FCR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK Nu,per 1000-PLN-7200.01 Title Appendices Revision 2 APPENDIX C - PART 2 NRC Regulatory Guide 1.39, Rev. 2, September 1977 Housekeeping Requirements for Water Cooled Nuclear Power Plants Endorses ANSI N45.2.3 - 1973 The GPUN Quality Assurance Program complies with this guide with the folicwing clarification to ANSI N45.2.3-1973,

1. Sections 2.1 and 3.2 The Nuclear Stations will not utilize tne five level zone designation system referenced in ANSI N45.2.3, but will utilize standard janitorial and work practices to maintain a level of cleanliness commensurate with company policy in the areas of housekeeping, plant and personnel safety, and fire protection.

Cleanliness will be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into systems considered imoortant to safety. This will include as a minimum documented cleanliness inspections wnich will be performed immediately prior to system closure. Control of personnel, tools, equipment, and supplies will be established when major portions of the reactor system are openea for inspection, maintenance or repair. Additional housekeeping requirements will be implemented as required for control of radioactive contamination.

2. Section 3.2.3 discusses fire protection. Except for the quality assurance aspects of fire protection, no specific commitments are made in this Plan. As part of other activities, GPUN has Established positions or commitments relating to fire safety or protection.

NRC Regulatory Guide 1.54, June 1973 Quality Assurance Requirements for Protective Coatings Aoplied to Water Cooled ( Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification:

1. GPUN will comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to maintenance and modification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) shall i be the original requirements or better.

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• Nuclear cPuNC cPERATIcNat cu4tITy ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Nurreer 1000 PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

2. The quality assurance program for protective coatings includes the planned and systematic actions necessary to provide adequate confidence that shop or field coating work for nuclear facilities will perform satisfactorily in service.

All protective coatings, except those noted in 3 below, applied to surfaces within containment are tested to demonstrate that they can withstand LOCA conditions. These tests are performed in accordance with Section 4 of ANSI N101.2, Protective Coatings (Paints) for Lignt Water Nuclear Reactor Containment Facilities, under LOCA conditicns which equal or e<ceed those described in the FSAR. The quality assurance program is applied for Protective Coatings consistent with the nature and scope of work specified in the technical specifications. The following elements are included: (a) Preparation of coatings specificaticn and procedures for generic coating materials / systems. (b) Review and evaluation of coating manufacturers' demonstration test data and quality assurance measures for control of manufacture, identification, and performance verification of applied coating systems. (c) Review and evaluation of supplier quality assurance measures to control storage and handling, surface preparation, application, touch-up, repair, curing and inspection of the coating systems. (d) Training and qualification of inspection personnel in coatings inspecticn requirements. (e) Supplier surveillance inspection. The coatings quellfication program and the associated quality assurance requirements are necessary only for coatings whose failure or failure mechanism would have a significant effect on safety.

3. Regulatory Guide 1.54 is not imposed for:

(a) Surfaces to be insulated. (b) Surfaces "cor.tained" within a cabinet or enclosure (for era +ple, the interior surfaces of ducts). 108.0 3900L

Nuclear GPUNC OPERATIONAL QUAUTY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Number 1000 PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2 (c) Field repair on any Q-class coated item less than 30 square inches of surface area such as: o Cut ends or otherwise damaged galvanizing. o Bolt heads, nuts, and miscellaneous fasteners. o Damage resulting from spot, tack, or stud welding. Field touch-up and repair of larger areas shall be in accordance with item (1). (d) Small "procuction line" items such as small motors, handwheels, electrical cabinets, control panels lounspeakers, etc. where special painting recuirements would be inpracticable. (e) Stainless steel or galvanized surfaces. (f) Coating used for the banding of piping. (g) Strippable coatings used for cleanup.

4. Quality Assurance documentation may not be similar to records and documents listed in Section 7.4 through 7.8 of ANSI N101.4 but will be evaluated to assure that they provide at least the same degree of documentation as required by this standard.

NRC Regulatory Guide 1.58, Rev. 1, September 1980 Qualifications of Nuclear Power Plant Inspection, Examination, and Testing Personnel The GPUN Quality Assurance Program complies with this guide with the following clarification:

1. The guidance of Regulatory Guide 1.58 shall be followed as it pertains to the qualifications of QA inspection personnel who verify conformance of work activities to quality requirements. The qualification of other QA personnel shall be in accordance with GPUN established requirements. The qualifications of plant operation personnel concerned witn day-to-day operation, maintenance, and certain technical services shall conform to Regulatory Guide 1.8.

NDE Level III personnel shall be recertified at an interval of every 5 years as noted by ASME Code Cases N-34) and N-356, rather than the l 3 year interval recommended by ASNT-SNT-TC-1A 1980. 109.0 3900L

e Nuclear cau"C CPERATIcNat ouAtITv assurance PLAN FCR THREE MILE ISLAND UNIT 1 sumner 1000-PLN-7200.01 AND 0(STER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

2. Plant operation personnel may be utilized to perform the visual leakage examinations required by the edition of ASME Section IX and related codes currently committed to for the conducted of inservice inspections. Such personnel snall be qualified consistent with these ASME code requirements. The selection and qualification of such personnel shall be prescribed by a procedure (s) which is reviewed and concurred with by the Quality Assurance Department.

3. Not all personnel wno:

A. Review and approve inspection and testing procedures, S. Evaluate the adequacy of activities to accomplish the inspection and test objectives, C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, D. Certify Level III individuals in specific categories or classes, will be certified as meeting the Level III capability requirements of ANSI N45.2.6 - 1978. Ratner these personnel will be determined by management through evaluation of their education, experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented. NRC Regulatory Guide 1.64, Rev. 2, June 1976 Quality Assurance Requirements for the Design of Nuclear Power Plants GPUN will comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative requirements included therein shall apply to maintenance and modification activities even though such requirements were not in effect originally. Technical reautrements (e.g., code requirements, naterial properties, design margins, manufacturing processes, and inspection requirements) associated with maintenance and modifications shall be the original requirements or better. The Quality Assurance Program complies with this guide with the following clarifications: 110.0 3900L

ENuclear cPuNe OPeRATr0NAt ouAtrTv Assum NcE PLAN FOR THREE MILE ISLAND UNIT I

                                                                                    ' Number 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2 1.

Regulatory Position C.2(1) of the Regulatory Guide: If the designer's immediate Supervisor is the only technically qualified Supervisor, individual available, providing that: (3)this review can be conducted by the the other provisions of the Regulatory Guide are satisfied, and (b) tne justification is indivie; ally documented and approved in advance by the Supervisor's management, and (c) auality assurance audits cover frequency and effectiveness against abuse. of use of Supervisors as design verifters to guard

2. Sections 6.2, 7.2 and 8.0 of ANSI N45.2. ll-1974 Each of the above sections reiterate the need to aoply design control provisions equivalent to original or previously verified designs.

Design control provisions include revision, review, and approval of the design document (s) affected ar.o design verification. The last sentence of Paragraph 6.2 could be read to imply two separate reviews are required for changes to previously approved designs: (1) review of changes for the effects on overall design and (2) design verification. As a point of clarification with regard to "fleid changes," the nature of the field change will be evaluated and the need for design verification of the specific field change will be determined. Field changes that meet the bounds of Paragraph 7.2 will not be design verified. Procedure (s) requirements shall be provided to identify when such field changes are "minor" in the context of Paragraph 7.2. NRC Regulatory Gulce 1.88, Rev. 2, October, 1976 Collection, Storage, and Maintenance of Nuclear Power Plant Availability Assurance Records GPUN will comply with the intent of this regulatory guide by compliance with the requirements of ANSI /ASME NQA-1-1979, Supplement 175-1 and Appendix 17A-1 including Appendix 17-1, NQA-1A-1981. NRC Regulatory Guide 1.94, Rev. 1, April 1976 Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification (s): l 111.0 3900L

a , gggy GPUNC OPERATfCNAL QUALITY ASSURANCE Number PLAN FOR THREE VILE ISLAND UNIT 1 1000-PLN-7200.01 AND OrSTER CREE < Title Appendices Revision 2 APPENDIX C - PART 2 (1) QA programmatic / administrative requirements included in the Regulatory Guide shall acply to maintenance and modification activities even tnough such requirements were not in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or tetter (e.g. , code requirements, material prccerties, design margins, manufacturing processes, and inspection requirements). (2) Section 5.4 of ANSI N45.2.5-1974 s:ecifies that torque wrenches be calibrated at least weekly and more often if deemed necessary. It has been determined tnat this frequency was chosen based en high usage during construction pnase activities. GPUN usage records indicate trat calibration frequencies based on manufacturer's instruct;cn and usage during ocerational phase activities is sufficient. Therefore, the calibr3 tion frequency of torque wrenches will be controlled consistent with our current program instead of weekly. NRC Regulatory Guide 1.116, Rev. 0-R, May 1977 Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems The GPUN Quality Assurance Program ccmplies with this guide with the following clarification: QA programmatic / administrative requirerents included in the Regulatory Guide shall apply to maintenance and mcdification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications, shall be the original requirements or better (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements). Much of N45.2.8 applies to construction and pre-coerational testing. As a result, many of the listed tests are not appropriate in an cperational plant. In 11eu of this, GPUN utilizes its Engineering and/or Maintenance organizations to establish tne need for specific tests or test procedures during the operational phase. NRC Regulatory Guide 1.123, Rev. 1, July 1977 Qualltv Assurance Requirements for Centrol of Procurement of Items and Services for Nuclear Pcwer Plants The GPUN Quality Assurance Program conDlles with this guide with the following clarification: 112.0 39 COL

Nydgf GPUNC CPERAMONAL QUALITf ASSURANCE Number PLAN FCR THREE MILE ISLAND UNIT I 1000 PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

1. Section C.3. A corrective action system may, depending upon compleitty and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action 15 imposed on a supplier, the apolicable elements of Section 9.0 of the standard will be included and its implementation will be verified.

2. Section C.4 Applicaole inforTation concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.

3. Section 4.2.a of ANSI N45.2.13-1976. When evaluation of a supplier is cased solely on historical supplier data, these data will primarily consist of records of evaluations conducted by accredited agencies such as NBS, UL, ASME or similar agencies of foreign countries; and/or, records of prior procurements, data that includes procureTent experiences of users of identical or similar products of the prospective supplier and product operating experience will be used if available.

4. Section 4.2 of ANSI N45.2.13-1976. In the special case of "commercial grade items" the supplier does not have to be evaluated by one of the methods identifled; however, the procurement documents shall contain requirements specific to the item being procured.

5. Section 7.5. As a point of clarification, personnel who perform the audit (s) as described in Section 12.0 will not be qualified in accordance with ANSI N45.2.6. Such personnel are qualified in accordance with Regulatory Guide 1.146, dated 8/80.

6. Section 10.2.d of ANSI N45.2.13-1976. Tne requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.

7. Section 10.3.1, Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows:

The verification of the validity of supplier certificates and the effectiveness of the certification system are accomplished as an integral part of the total supoiler control and product acceptance program, and no separate GPUN system exists that addresses itself solely to such verification. The degree of verification required will depend upon the type of item or service and their safety importance. The means of verification may include source witness / hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as concrete components; and tests after installation on selected ccmponents and systems. All of these means verify whether or not a supplier has fulfilled procurement document requireTents and wnether or not a certification system is effective, 113.0 3900L

4 MNuclear GPuNC OPEaArronAL cu4tITv ASSuR4NCE PLAN FOR THREE MILE ISLAND UNIT I

                                                                                 ' Numeer 1000-PLN-7200.01 AND OYSTER CREE <

Title Appendices Revision 2 APPENDIX C - PART 2 - NRC Regulatory Guide 1.142, October 1981 Safety-Related Concrete Structures for Nuclear Power Plants (Other Than Reactor Vessels and Containments) GPUN shall comply with the Regulatory Position established in this Regulatory Guide as augmented by ANSI N45.2.5, ANSI /ANS 6.4-1977 and ANSI /ACI 318-77 for the design and construction of new Nuclear Safety Related or Regulatory Required structures and additions to ettsting Nuclear Safety Related or Regulatory Required structures. Inspectors will be qualified according to either ANSI N45.2.6 or Appendix VII of Section III, Division 2, of the ASME Boller and Pressure Vessel Code. NRC Regulatory Guide 1.143, October 1979 Design Gutdance for Radioactive Waste Management Systems, Structures and Components Installed in Light-Water-Cooled Nuclear Power Plants Since tne original design and construction of TMI-l and Oyster Creek was to different classification criteria than contained in this guide; GPUN will comply with the regulatory posit ion of this guide with the following clarifications: 1. For modifications to existing plant systems and for new construction items will be classified consistent with the original design basis utilizing the classification process described in Subsections 2.2.1 and 2.8 of this Plan. 2. Tie-ins to existing plant systems will be made to the same or more recent code, standard and technical requirements which were originally applied to the system to which the tie-in is to be made. NRC Regulatory Guide 1.144, January 1979 Auditing of Quality Assurance Programs for Nuclear Pcwer Plants GPUN is in basic agreement with the position set fcrth in the Regulatory Guide subject to the following ccments:

1. Sections C.3.a(1) and C.3.a(2)

Minimum scheduling frequency and toolcal coverage of the GPUN internal audit program will be as defined in Section 6 of the nuclear units' Tecnnical Specificaticns.

2. Section C.3.b(1).

in addition to receiptSource surveillance will be utill:ed in lieu of or inspection. As permitted, external audits of such procurement actions will typically not be scheduled. 114.0 39')0L

, gggy GPUNC OPERATIONAL CUALITY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-P LN- 72CO . 01 AND OYSTER CREEK Title Appendices Revision 2 APPENDIX C - PART 2

3. Section C.3.b(2)

The extent of QA verification of the performance of external suppliers of items, parts, and materials will be determined by an evaluation process which is ccnsistent with Regulatory Guide 1.123 as ccmmitted to in this Plan. E<ternal audits of selected suppliers of services nhich are within the scope of tnis Plan will be scheduled and conducted at least cnce within the life of the activity or every three years. details. Refer to Subsection 10.2.5 of this Plan for furtner 115.0 3900L

f gdgr GPUNC OPERATICNAL CUAL?TY ASSURANCE Number PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revision 2 APPEN0lx 0 Terms and Definitions This Appendix contains cert 3in terms and their definitions that are important to a uniform understanding of the requirements of the GPUN Oceracional Quality Assurance Program. ANSI N45.2.10-1973, as endorsed by Regulatory Guide 1.74, and NQA-la-1981 contain terms and definitions applicable to the nuclear industry. The terms and definitions found in these cocutents are applicable to the CPUN Operational Quality Assurance Program and, for convenience, are included, in part, herein. Those terms and defir.itions which are the same as listed in ANSI N45.2.10-1973 or NOA-la-1981 are identified by footnote (1). Certain exceptions to the terms and defini tions found in ANSI N45.2.10-1973 and NQA-la-1981 have also been taken. These exceptions are icentifled by footnote (2). ACCEPTANCE (as used in relation to acceptance of a document): Generally approved, believed or recognized. Does not require signature of person accepting. ACCEPTANCE CRITERIA: Specified limits placea on characteristics of an item, process, or service defined in codes, standards, or other documents. (1) ADMINISTRATIVE CONTROLS: Rules, orders, instructions, procedures, policies, practices and designations of authority and responsibility. ALARA: (Acronym for As low As Reasonably Achievable) - a method of analysis of the performance of activities in radiological areas to determine specific methods for reducing man-rem exposure. APPROVAL: An act of endorsing and adding positive authorization (signature) to a document by the person (s) responsible for the document. (2) ARCHITECT / ENGINEERING (A/E); A firm under contract to provide engineering or cesign services. AS-BUILT DATA: Documented data that describes the condition actually achieved in a product. (1) Af'3IT: A formal, independent activity conducted with the intent to verify conformance with established requirements. This activity is performed in accordance with written procedures or checklists to verify, by evamination and evaluation of objective evidence, that documents and activities within the scope of this Plan are consistent with requirements, are being effectively implemented and provide results which are consistent with technical requirements. The terms "source surveillance", "source inspection",

     "inspection" and "monitoring" are not synonymous or eculvalent to the term "audit." (2) 116.0 3900L

• gglg8F' GPUNC OPERA TIONAL (JJALITY ASSURANCE Numt:r PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-P t.N- 7200. 01 Title Appendices Revision 2 APPENDIX D BASELINE ENGINEERING DC'CUMENTS:

Includes but is not limited to safety evaluation, design criteria documents, flow charts, System Design Cescriptions, general arrangement drawings, single-line diagrams, and logic diagrams which show or define basic plant parameters. For instance, Control Panel, Layout and Control Room arrangement drawings are baseline documents. BASIC COMPONENT: A term defined in 10CFR21, a "basic component" means a plant structure, assure (1) system, component or part (including cesign analyses), necessary to the integrity of the reactor coolant pressure boundary, (2) the capability to shutdown the reactor and maintain it in a safe shutdown, or (3) the capability to prevent or mitigate the consequences of accidents that could result in potential off-site e<posures comparable to those referred to in 10CFR100.ll. CALIBRATION: Comparison of two instruments or measuring devices, one of which is a standard of known accuracy traceable to national standards, to detect, correlate, report, or eliminate by adjustment any discrepancy in accuracy of the instrument or measuring device being compared with the standard. CCMMERCIAL GRADE ITEM: An item that meets all of the following conditions: Is used in applications other than nuclear power plant facilities or activities; Is not subject to design or specification requirements unique to NRC requirements for nuclear power plants;

     - May be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description (e.g., a catalog).

NOTE: The technical requirements set forth in the published product description must match the requirements needed to satisfy the design function of the item. Commercial grade items, when used as a basic component, must be dedicated prior to operation. CCNCURRENCE: Written agreement that the provisions in a document for which review has been requested are acceptable for implementation within, or from the standpoint of, the reviewer's area of responsibility. CCNDITION ADVERSE TO (.CALITY: An all inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and conconformances. A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or operability. 117.0 3900L

Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE PLAN FOR ~3REE MILE ISLAND UNIT 1 Numcer 1000-PLN-7200.01 AND OYSTER CREEK Title Appendices Revisicn APPENDIX 0 CONTRACTOR: Any organi:ation under contrar.t for furnishing items or services. It includes the term Vendor, Supplier, Subcontractor, Fabricator and subcontractor levels, where appropriate. (1) CONTROLLED DOCUMENT: A document wnich is assigned and distributed to an individual organization or location and requires that individual or organization to be accountable for the document. The distributing agent is responsible for providing the recipients witn current revisions to tne document. CORRECTIVE ACTICN: Measures taken to rectify conditions adverse to quality and, where necessary, to preclude repetition. (1) DEDICATION: Tne process by which 3 commercial grade item !s designated for use in a nuclear safety-related appilcation(s). It includes a point in time, typically after receipt, when the party designating the item assumes deficiency reporting responsibility associated with such use. DESIGN BASES: That documented information which identifies the specific functions to be performed by a structure, system, or component of a facility and the specific values or ranges of values chosen for controlling parameters as reference bounds for design. DETAILEO DESIGN DOCUMENTS: Engineering design documents derived from the Baseline Engineering Documents that provide the detail of design sufficient to f abricate, install and test a modification or system. This includes but is not limited to Procurement, Material, and/or Test Specifications, Installation Specifications, Fire Hazard Analyses, construction drawings, fabrication drawings, Bill of Materials, etc. DOCUMENT: Any written, pictorial, graphical or other reproducible media information describing, defining, prescribing, specifying, reporting, or certifying activities, requirements, procedures or results. A document is not considered to be a record until it is completed and contains the required signatures. (2) ENGINEERING (Engineer): This term refers to the technical responsibilities of Technical Functions, Plant Engineering or A/E's. EXTERNAL ORGANIZATICNS: Any organization participating in the project which is not a part of GPUN. This tern includes vendors, A/E's and contractors. 118.0 3900L

Nuclear GPUNC OPERATIONR QUAUTY ASSURANCE PLAN FOR THREE MILE ISLAND UNIT 1 Nueer 1000-PLN '/200.0) AND OYSTER CREEK Title Appendices Revision 2 APPENDIX 0 ITEM: Any structure, system, or component of a nuclear power plant including a nuclear fuel and raawaste systems. This item also includes licensed radwaste shipping containers. Quality classification shall be performed for mechanical, electrical, and instrumentation items at the component level. Mechanical items shell include valves, eautoment and specialty items. Electrical and instruTen-tation items shall include electrical, distribution, instrument and control panels, cabinets, switchgear, motor control centers, non-panel mounted instruments, transformers and motors. Inis term does not necessarily incluce part of components. LEAD AUDITOR: An individual quallfled to organize and direct an audit, report audit results, and evaluate corrective actions. This term is not equivalent to the term "auditor. MONITORING / SURVEILLANCE: An act of assuring compliance of activities to program requirements by direct observation or record review. Generally, monitoring is performed on site and surveillance is performed at a vendors's facility. NUCLEAR SAFETY RELATED: Structures, systems and components designed to remain functional for all design basis conditions necessary to assure thJ following safety functions:

1) The integrity of the Reactor Coolant Pressure Boundary.

2) The capability to shutdown the reactor and maintain it in a safe (hot) shutdown condition; or

3) The capability to prevent or mitigate the consecuences of accidents which could result in potential offsite exposures comparable to the guideline evposures of 10CFR100.

PPCCUREMENT DOCUMENT: Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to define the quality and technical requirements for purchase. (1) QA PLAN SCOPE: This term is a designator used on the coversheet of approved documents which prescribe the method of performance of activities or tasks identified in Section 2.2.2 of this Plan. QUALIFICATION (Personnel): The characteristics or abilities gained through education, training or esperience, as measured against established requirements, such as standards, or tests, that qualify an individual to perform a recuired function.1 ii 119.0 3900L

c (UClear GPUNC CPF.RATIOt(AL CUALITY ASSURANCE PLAN FOR THREE NILE ISLAND UNIT I Number 1000-PLN-7200.01 AND OfSTER CREEK t Title Appendices Revision 2 APPENDIX 0

      @ALIFICATION (Procedures): An approved precedure that has been demnstrated to meet the specified requirements for its intended purpose. (1)

QUALITV CLASSIFICATION: A process for identifying tne technical and quality requirements of structures. systems, and cocponents based upon regulatory requirements and ccmmitments, safety functicn and'or reliability consideration. f QUALITY CLASSIFICATION LIST (QCL): The controlled 'locument usea to record tne identification of structures, systems and ccmpenents that are within the scope of this Plan. REGULATORY REQUIRED: Those items which are not nuclear safety related but which must meet NRC reculatory requirements or commitments. Sources of regulatory requirements and commitments, as a minimum, consist cf those associated with expressed conditions of the unit operating license, FSAR, fire protection (Appendix R and BTP Apoendix A), security, environmental qualifi-cattor, of electricai equipment, seismic response capabilities, licensed shipping containers to the extent cce.mitted by GPUN, generic letters, IE Bulletins, 10CFR50.54(f) correspone.ence, certain NUREG documents, etc. RECORD: An authentic document which furnishes evidence of the acceptability of an item, p0rt, material, or activity, etc. within the sccpe of this Plan. SPECIAL PROCESS: A process, the results of which are highly dependent on the  ; control of the process or thy skill of the cperators, or both, and in , which the specified quality cannot be readily determined by inspection or test of the product. (1) SUPPLIER: A firm which prevides items, parts, materials or services from an offsite facility and operate: under the requirements of their orn QA program. SUPPLIER QUALITY CLASSIFICATION LIST (SOCL): A list of Suppliers wno have been evaluated by tne GPUN Quality Assurance Department for their capabilities to produce or provide items or services or both within the scope of this Plan. TRACEABILITY: The ability to trace the history, applicatlCn or location of an item and llKe items or activities by means of recorded inforration. (1) TREND ANALYSIS: A quantitative methCd of collecting and 3nalysis nonconformance/ deviation events with the goal cf systematically deternining programmatic / procedural weaknesses. VERIFICATION: An act of confirming. substantiating and 3:,uring that an activity or condition his been implemented in conformance with the specified requirements. (1) 120.0 3900L}}