ML20212E229
| ML20212E229 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Crane |
| Issue date: | 03/04/1998 |
| From: | GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20212E202 | List: |
| References | |
| 1000-PLN-7200.0, NUDOCS 9909240189 | |
| Download: ML20212E229 (25) | |
Text
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GPU NUCLEAR CORPORATE Number spy POLICY AND PROCEDURE MANUAL 1000-PLN-7200 01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
1I Applicability / Scope This Plan Has GPU Nuclear-Wide Applicability Except TMI-2 Responsible Office 6L50 This Document is within QA Scope X YES NO Effective Date Safety Reviews Required X YES NO 3/6/98 List of Effective Pages Page Rev.
Page Rev.
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Page Rev.
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1.0 11 21.0 11 41.0 11 61.0 11 81.0 11 2.0 11 22.0 11 42.0 11 62.0 11 82.0 1l 3.0 11 23.0 11 43.0_
11 63.0 11 83.0 11 4.0 11 24.0 11 44.0 11 64.0 11 84.0 11
-5.0 11 25.0 11 45.0 11 65.0
!l 85 0 ti 6.0 11 26.0 11 46.0 11 66.0 11 86 0 11 7.0 1I 27.0 11 47.0 11 67.0 11 87.0 11 0.0 11 28.0 11 48.0 11 68.0 1I 88 0 11 9.0 l1 29.0 11 49.0 11 69.0 11 89.0 11 10.0 11 30.0 11 50.0 11 70.0 11 90.0 11 11.0 11 31.0 11 51.0 11 71.0 11 12.0 11 32.0 11 52.0 11 72.0 11 13.0 11 33.0 11 53.0 11 73.0 i1 14.0 11 34.0 11 54.0 11 74.0 11 I5.0 11 35.0 11 55.0 11 75.0 11 16.0 11 36.0 11 56.0 11 76.0 11 4
17 0 11 37.0 11 57.0 11 77.0 11 I30 11 38.0 11 58.0 11 78.0 11 19.0 11 39.0 11 59.0 11 79.0 11 20 0 11 40.0 11 60.0 11 80.0 1I
[,
Sfgnature Concurring Organizational Element Date,
Originator
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Director, Nuclear Safety Assessment Jkf/
I Concurred By fyj Dir-TMI 2/23/98
/s/
Dir-OCNGS 2/4/98
/s/
Dir-Engineering 1/30/98
/s/
Dir-Human & Administratise Seruces 2/5/98
[g[ Mfg Corporate Procedure Administrator
.;/j7/pg hjg Responsible Technical Reviewer 3/Jj/gf Approved By M
President 3/4/13 i
v l
9909240189 990916 PDR ADOCK 05000219 p
PM RETQAP ot t 1.0
rr GPU NUCLEAR CORPORATE Numb r
!+
GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR l
Titte: GPU Nuclear Operational Quality Assurance Plan Revision No.
11 TABLE OF CONTENTS Eage TABLE OF CONTENTS 2a DOCUMENT HISTORY
5.0 INTRODUCTION
8.0 1.0 ORGANIZATION & RESPONSIBILITIES 1.1 President 10.0 1.1.1 Director Nuclear Safety Assessment i 1.0 1.2 Directors TMI and Oyster Creek 13.0 1.3 Director-Engineering 14.0 1.4 Director-Human & Administrative Resources 15.0 i
1.5 GPU Nuclear Management 16.0 1.6. External Organizations 16.0 1.7 Minimum Qualifications of Assessment and inspection Personnel 16.0 2.0 QUALITY ASSURANCEPROGRAM 2.1 General 18.0 2.2 Scope 18.0 2.3 Graded Approach 20.0 2.4 Levels ofQuality Assumnce 20.0 2.5 Operational QA Plan Control 22.0 2.6 Quality Assuruice Program Review 23.0 2.7 Indoctrination and Training 24.0 2.8 Classification Process 24.0 2.9 Regulatory Commitments 24.0 2.10 Resolution of Disputes and Escalations 25.0 2.11 Safety Review Program 25.0 1.12 Independent Safety Oversight 26.0 2.13 Self Assessment 26.0 2.14 Ombudsman 26.0 3.0 CONTROL OF DOCUMENTS AND RECORDS 3.1 Policies, Plans, Instructions, Drawings, Specifications 27,0 3.2 Document Control 28.0 3.3 Records 30.0 l
RErQAP.011 2.0
GPU NUCLEAR CORPORATE NumbGr GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR Tide: GPU Nuclear Operational Quality Assurance Plan Revision No.
I1 TABLE OF CONTENTS 4.0 DESIGN CONTROL 4.1 General 33.0 4.2 Requirements 33.0 5.0 PROCUREMENT AND MATERIAL CONTROL 5.1 Control of Procurerdent 35.0 5.2 Identification and Control of Materials, Parts and Components 39.0 6.0 CONTROL OF STATION ACTIVITES 6.1 General 41.0 6.2 Control ofInspections Requirements 41.0 6.3 Control of Special Processes Requirements 43.0 6.4 Test Control Requirements 43.0 6.5 Control of Measuring and Test Equipment (M&TE) Requirements 45.0 6.6 Handling, Storage and Shipping Requirements 46.0 j
6.7 Inspection, Test and Operating Status Requirements 47.0 6.8 Housekeeping and Cleanliness Requirements 48.0 6.9 Equipment Control Requirements 49.0 6.10 Control of Construction, Maintenance Requirements (Preventive / Corrective) and Modifications Requirements 49,0 6.11 Control of Surveillance Testing and Inspection Requirements 51.0 6.12 Radiological Control Requirements 52.0 6.13 ' Control ofTraining Requirements 52.0 7.0 COMROL OF RADIOACTIVE WASTES OR MATERIALS 7.1 General 55.0 7.2 Requirements 55.0 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 General 57.0 8.2 Requirements 57.0
9.0 ASSESSMENT
1 9.1 General 60.0 9.2 Audit Requirements 60.0 9.3 Monitoring Survey, Surveillance, and Document Review 62.0 Requirements i
APPENDICES:
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Title:
GP.U Nuclear Operational Quality Assurance Plan Revision No.
i1 DOCUMEN'T HISTORY PREPARED BY:
EFFECTIVE REVIEWED BY:
REVISION DATE DESCRIPTION OF CIIANGE APPROVED BY:
were assigned to tne newly named Engineering Division.
Their receipt inspection function was assigned to the Financial and Planning Services Division.
- Format of the document was changed. In the previous revision, the responsibilities were included in specific sections.
In this revision, the responsibilitier. have been relocated to Section 1, consolidated to avoid redundant verbiage and streamlined to represent the current organization.
Responsibilities were deleted from the remainder of the document.
- Section 9 - Control ofTraining has been deleted and is addressed in Section 6.13 to improve the description of work processes at GPU Nuclear.
- Section 10 has been renumbered to be Section 9 and has broader use of the term assessment that includes audits, monitoring, survey, document review, and special j
assessments.
- Description of how "self assessment" activities may be included in the QA Program was added. (Section 2).
- Provides for use ofadditional approved corrective action mechanisms for audits (Section 9).
- Some rewording of text throughout the document have been done to remove redundancy and to improve the description of work processes at GPU Nuclear.
10 The purpose of this revision is to reflect changes in the R. E. Tilton l
Nuclear Safety Assurance Process which impact the plan C. Faust organizationally. The changes combine Licensing and Regulatory Affairs with Nuclear Safety Assessment.
T. G. Broughton Signatures for concurrence and approval obtained from those directly affected only.
i
{'
11 12/31/97 The purpose of this revision is to reflect organizational R. E. Tihon I
changes being implemented by GPUN. The Orgamzational D.P. Kelly change results in the Director of NS A reporting to the President versus the Director of Nuclear Safety and Technical T. G. Broughton Services.
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GPU NUCLEAR CORPORATE Number GW POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 1.0 ORGANIZATION & RESPONSIBILITIES The GPU Nuclear Organization Plan is the highest tiered document that assigns major functional responsibilities. Implementing documents assign more specific responsibilities and tasks and define the organizational inter-face (s) involved in conducting activities and tasks within the scope 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 sununary of the organizational units and functions which perform activities within the scope of this Plan.
The GPU Nucle.~.r organization is structured on the basis that the attainment of the objectives of this Plan relies 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, in-service inspection and refueling of the nuclee.r generating stations are illustrated in the following controlled documents: the GPU Nuclear Organization Plan (1000-PLN-1000.01) and the applicable technical specifications. The GPU Nuclear Organization Plan sets forth specific responsibilities with regard to the requirements of this Plan and implementing procedures.
1.1 President He President-GPU Nuclear has the overall responsibility for the establishment, implementation and evaluation of the effectiveness of the Quality Assurance Program applicable to TMI and Oyster Creek. This responsibility is administered through the President's management staff, including:
Director-TMI Director-OCNGS Director-Engineering Director-Human & Administrative Services Director-Nuclear Safety Assessment The above management staff members give their full support to the requirements set forth in this Plan ensuring full compliance by their respective staffs.
He President - GPU Nuclear is responsible to periodically assess the scope, status, adequacy and compliance of the Quality Assurance Progran to the RETQAP.011 9.0
GPU NUCLEAR CORPORATE Number GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR l
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 requirements of 10CFR50, Appendix B,10CFR20, and 10CFR71, Subpart H, and 10CFR72, Subpart G. This assessment shall be the combined result of:
i Review of audit reports, periodic status reports, etc. on the effectiveness a.
and implementation of the Quality Assurance Program.
b.
Performance at least once a year of an independent assessment of the effectiveness of the Quality Assurance Program as specified in Section 2.6.
l i
1.1.1 Director-Nuclear Safety Assessment The Director-Nuclear Safety Assessment has the functional authority, independence and responsibility to assure the effective implementation of cnd compliance to the Quality Assurance Program. Consistent with this responsibility is the authority to render interpretations in writing on j
those activities to which this Plan applies and the extent to which the Plan applies to those activities.
Additional responsibilities include providing recommendations or solutions to quality problems, and performing monitoring, assessments and audits for all areas except for licensing activities and IOSRG. The Manager (s), Assessment has responsibility for these activities when monitoring, assessing, and/or auditing licensing and IOSRG activities.
For on-site independent review issues involving licensing activities and I
IOSRG, the Manager (s) Assessment has the authority to directly report to and communicate with the President.
The Director-Nuclear Safety Assessment reports directly to the President and has direct unencumbered access to the Directors of each of the nuclear stations with regard to activities affecting quality. This reporting relationship has been established to provide sufficient independence from the influence of costs and schedules to be able to effectively assure conformance to Quality Assurance Program requirements.
The Director-Nuclear Safety Assessment has no duties or responsibilities unrelated to the responsibilities contained in this document that would prevent the required attention to quality assurance matters. The Director-Nuclear Safety Assessment has the authority and responsibility to:
a.
Develop and administer the maintenance of the Operational Quality Assurance Plan and Nuclear Safety Assessment r
l RETQAP.011 10.0 l
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Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
I1 procedures required to assure that all GPU Nuclear activities provide the required high degree of safety and reliability.
1 b.
Assess, audit, and monitor the conduct of GPU Nuclear activities to assure that they provide the required high degree of safety and reliability and are carried out consistent with all applicable laws.
)
regulations, regulatory commitments, licenses, corporate policies and other requirements. Assessment schedules are developed and implemented to ensure all required areas are assessed.
Establish and conduct of nuclear safety review and assessment c.
activities which include those of the nuclear stations' Independent On-site Safety Review Group and the General l
Office Review Board.
d.
Identify and report nonconformances as they may exist. Initiate, recommend or provide solutions through designated channels.
Verify implementation of resolutions as required.
e.
Initiate stop work or unit shutdown recommendations when warranted by a safety concern and obtain unit shutdown with appropriate upper-management concurrence, f.
Provide for a review of selected documents which prescribe methods for activities and quality requirements for items within the scope of this Plan. Refer to Appendix B of this Plan.
g.
Provide for a review for concurrence of Contractor and Vendor Quality Assurance Programs as specified in Section 5.
h.
Direct and manage Nuclear Safety Assessment.
i.
Provide a working interface and line of communication with other divisions and other appropriate industry and regulatory groups for all program matters.
j.
Provide indoctrination, certification, and/or training programs for Nuclear Safety Assessment.
k.
Assure QA program indoctrination of appropriate personnel outside of Nuclear Safety Assessment is provided.
1.
Immediately notify the President and appropriate Unit Director of any significant quality related problem or deficiency, f
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4 GPU NUCLEAR CORPORATE Number spy POLICY AND PROCEDURE MANUAL 1000-PLN 7200.01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
1I Perform assessments on a planned and periodic basis to m.
comprehensively determine the effectiveness of the program and its implementation; and, detect adverse trends that may be present.
Issue periodic reports to the President and Division Directors on n.
the effectiveness ofimplementation of activities within the scope of this Plan.
o.
Establish and maintain a Supplier Quality Classification List (SQCL) which documents the results of the examinations of prospective suppliers, p.
Assist in the development of a GPU Nuclear comprehensive self assessment Program. Provide oversight of self assessment activities to determine effectiveness of the program.
q.
Review and concur with all procedures for reporting and controlling of non-conformances for compliance with the requirements of this plan.
r.
Review, verify and concur with closcout of non-conformances, when required.
Provide for maintenance of the operating license for the Nuclear s.
Plants.
t.
Provide interpretations as necessary of this plan and the operating license to ensure proper implementation.
u.
Coordinate the Safety Review Process to ensure consistent application ofcompany and regulatory requirements.
Serve as owner for the " Issues Management" process by v.
establishing and maintaining standards that provide for a graded approach to resolving issues based on complexity and risk.
w.
Provide principle interface and control with all non-financial, non-environmental regulatory agencies for GPUN including NRC, appropriate state agencies, and supporting legal services.
In addition, ensure preparation and coordination of GPUN responses to regulatory agencies, including NRC inspections and enforcement bulletins, circulars, notices and generic letters, and activities associated with INPO and NEl.
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i GPU NUCLEAR CORPORATE Number GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 1,2 Director-TMl and Os ster Creek j
Each of the Directors of the nuclear generating stations reports to the President.
They are each responsible to operate, 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
{
requirements. The Division Director-TMI and Oyster Creek are the senior GPU
)
Nuclear representative at their sites and as such assure consistent j
implementation of policies and procedures atthe plant and off-site facilities in their respective area. The Director's Quality Assurance Plan responsibilities consist of establishing, maintaining and delivering training and education programs sufficient to assure safe, reliable and efficient operation; establishing, implementing and maintaining radiological controls, radiological environmental monitoring, emergency preparedness. Additionally, the Directors through the Maintenance Department functional management have responsibility for implementing modification, maintenance, and inspection activities (excluding Receipt Inspection and NDE). (Section 6.10)
Additional specific responsibilities associated with the above are:
a.
Ensuring that testing (e.g. Post Maintenance, Surveillance and IST) and calibration performed at their assigned station is performed in accordance with the requirements of this Plan. (Sections 6.4,6.5 and 6.11) b.
Ensuring that the handling, cleaning, storage and shipping activities, under their direction, associated with the operation and maintenance of their assigned station are performed in accordance with the requirements ~
of this Plan. (Section 6.6)
Ensuring that the appropriate requirements for controlling the inspection, i
c.
test and operating status, including independent verification, are l
incorporated in the procedures used on all fabrication, installation, test and operation activities performed at their respective stations. (Section i
6.7) d.
Ensuring that the programs are established and maintained for housekeeping and cleanliness control of all work activities in accordance with the requirements of this Plan. (Section 6.8) l e.
Ensuring that the programs are established and maintained for identification and control of equipment to avoid unauthorized use and to assure that operational equipment is in a ready status. These RETQAP.011 13.0
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I1 requirements shall include independent verifications to ensure proper implementation. (Section 6.9) f.
Ensuring that the programs are established and maintained for minimizing the generation of radioactive waste and materials, the processing of radioactive waste and movement of radioactive materials.
(Section 7) g.
Ensuring that nonconformances are reported and corrected for all activities within the scope of this Plan. Items such as failures, malfunctions and deficiencies are handled in a manner consistent with their importance to nuclear safety and reviewed in accordance with appropriate procedures and the applicable Technical Specification.
(Section 6.7 & 8) h.
Providing and implementing an inspection program (excluding receipt inspection and NDE) to assure maintenance and modification activities are carried out consistent with all applicable laws, regulations, regulatory commitments, licenses, corporate policies, and other requirements.
1.3 Director-Encineerine The Director-Engineering reports directly to the President. The Director's Quality Assurance Plan responsibilities consist of providing the requisite engineering and technical support to: maintain the design basis of the nuclear plants; maintain the configuration control documents including development and maintenance of the quality classification list; conduct operating experience assessment; provide nuclear fuel management; provide core performance monitoring; staff and direct shift technical advisors; monitor and analyze the technical performance and reliability of systems and components; proside selective review of plant operations and testing procedures, and associated training; provide technical control and coordination of plant modifications as required by Section 6.10 of this Plan; coordinate and implement In-Service Inspection and Non-Destructive Examination services; procurement engineering; and, provide a weld program and a repair program.
Additional specific responsibilities associated with the above are:
Review of procurement documents to assure that quality requirements a.
are correctly stated, inspectable and controllable; that there are adequate acceptance / rejection criteria; that source verification er 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. (Section 5)
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r GPU NUCLEAR CORPORATE Number GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 b.
Performing periodic evaluation of the quality of procurement documents produced. This evaluation may include a sampling review of previously approved documems or in-line reviews of selected purchase requisitions or orders prior to placement by individuals independent from the production of the documents selected. (Section 5)
Ensuring programs are established and maintained for the special c.
processes of welding, heat treating, and nondestructive examination.
(Section 6.3) d.
Performing a startup and test function to assure new or substantially modified plants, facilities and systems are tested in compliance with this Plan. (Section 6.4) i 1.4 Director-Human & Administrative Sersices I
The Director-Human & Administrative Services reports directly to the President. The Director's Quality Assurance Plan responsibilities consist of establishing, implementing and maintaining document distribution and record retention programs and facilities; medical examination and fitness-for-duty i
testing plans and procedures; coordinating administration of the GPU Nuclear i
policy and procedure system; establishment, maintenance, and implementation j
of plans and procedures for nuclear plant security, access authorization, safeguard contingencies and plant security guard force training and qualification consistent with Corporate Policies and all applicable laws; establishing, maintaining, and implementing procurement, receipt inspection, material identification and warehousing plans and/or procedures. Section 5.0 of this Plan contains specific requirements related to procurement and receipt inspection.
Additional specific responsibilities associated with the above are:
a.
Ensuring that the programs are established and maintained to evaluate bids for conformance to technical and quality requirements by the i
requisitioners and that the contractual, legal and commercial requirements are incorporated into the procurement documents in a i
manner which will enforce the technical and quality requirements.
(Section 5) b.
Establish and maintain a program of receipt inspection, to assure that items, within the scope of the Plan comply with contract requirements and supplier record packages are reviewed for concurrence as required.
(Section 5)
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1 GPU NUCLEAR CORPORATE Numbzr spgy POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR
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GPU Nuclear Operational Quality Assurance Plan Revision No.
11 Ensuring that the programs for the handling and storage of materials.
c.
parts and components and appropriate personnel are adequately trained in the performance of their duties and that they implement the procedures properly. (Section 5 and 6.6) 1.5
- All GPU Nuclear-Management Management personnel in each division are responsible for the implementation of the Quality Assurance Program by their division, department or group, including the development and implementation of approved documents performing activities in accordance with expectations and requirements; use of qualified personnel and equipment; 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 within their division, department or group. This includes the identification and qualification of personnel as Responsible Technical Reviewers and Independent Safety Reviewers; the review and approval of documents within their functional area of responsibility as assigned by the GPU Nuclear Review and Approval Matrix (1000-ADM-1291.01); and other activity as may be required to implement Technical Specifications Appendix A, Section 6.5, requirements.
Management personnel in each division are responsible to provide sufficient support to the assessment process and to take positive action to evaluate and correct nonconfonnances identified in the conduct of their activities within the scope of the Plan. This responsibility includes correcting adverse trends as may be identified.
The Director or Manager of each department performing activities within the scope of this Plan is responsible for the preparation, approval and implementation of documents which prescribe activities and/or tasks necessary to effectively implement this Plan. This responsibility includes ensuring that provisions are made for interface controls for intemal and external lines of communications among participating organizations and technical disciplines.
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, parts or components which have been properly accepted are used. Each Department Manager is responsible for maintaining records as required by this Plan until turnover to an approved record storage facility.
1.6 Extemal Oraanizations RETQAP.cli 16.0 j
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l
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 Suppliers who provide Items and/or services which are within the scope of this Plan shall have a QA Plan and implementing procedures appropriate for the items, consumables, and/or services. The suppliers QA Program may be supplemented or replaced by this Plan. The supplier's QA program shall be subject to review for concurrence by the Director-Nuclear Safety Assessment or his designee. The extent to which the supplier's QA program will be applied will be specified by procurement documents.
1.7 51i:+num Oualifications of Assessment and inspection Personnel The Director-Nuclear Safety Assessment shall have, as a minimum a baccalaureate degree in engineering or science, with at least fifteen (15) years of technical experience including ten years of managerial / supervisory experience in operational, technical support and/or quality assurance activities associated with nuclear power plants. At least one year of this experience shall be in a nuclear assessment oversight organization or a special training program approved by the President and will be completed within six months of assuming the position. Additionally, the Director-Nuclear Safety Assessment must be knowledgeable in operating license conditions, other regulatory requirements and commitments, plans, procedures and quality and technical standards.
Managers within Nuclear Safety Assessment who report to the Director-Nuclear Safety Assessment shall have an academic degree in engineering or a physical science and 10 years of professional level experience in nuclear power or related technical fields. Managers must have at least 3 years experience in a position responsible for supervision of operational, technical and/or oversight activities.
The degree requirements may be waived for personnel with demonstrated exceptional capability and a minimum of 15 years of appropriate experience.
Each Independent On-Site Review Group Engineer shall have an academic degree in engineering or a physical science field and 3 years of professional level experience in the nuclear power field including technical supporting functions or 8 years of appropriate experience. Credit toward experience will be given for advanced degrees on a one-to-one basis up to a maximum of two years.
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I1 l
For personnel performing inspection, examination, and special processes. the
(
qualification criteria shall be delineated to the techniques ofinspection or items I
being inspected and the technical abilities of the person being certified will be consistent with the assigned tasks (e.g., electrical inspection, mechanical inspection.)
j r
He qualification requirements and experience levels for other Nuclear Safety Assessment personnel are such as to assure competence commensurate with the responsibilities of and the Regulatory Guides. associated with the activities 1
performed by the position.
I 2.0 OUALITY ASSURANCE PROGRAM 2.1 General
)
This Operational Quality Assurance Plan is the highest tiered GPU Nuclear document which provides the generic (and some specific) requirements and i
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 CPU Nuclear 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 provision 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 GPU Nuclear organizations and for all external organizations providing " Items" or conducting
" Activities" which are within the scope 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 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 will differ from Item to Item and Activity to Activity.
The Director-Nuclear Safety Assessment is authorized and responsible for 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 i
clarity or resolve disagreements, such interpretations shall be documented and approved by the Director-Nuclear Safety Assessment.
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Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 2.2 Scope The scope of the GPU Nuclear 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 and Activities within the scope of this Plan, a i
classification process has been developed and documented. This process relies 1
on the use of the terms " Nuclear Safety Related," " Regulatory Required " and "QA Plan Scope."
2.2.1 Items within the scope of this Plan are designated as Nuclear Safety Related" or " Regulatory Required." The defmitions of these terms are provided in Appendix D of this Plan. A Quality Classification process for items has been
{
developed. This classification process produces a Quality Classificatian List which identifies the permanent plant structures, systems, and compoaents 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 ofItems 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, other than those designated as " Nuclear Safety Related" or " Regulatory Required" as specified by GPU Nuclear management.
2.2.2 Activities within the scope of this Plan are designated as within "QA Plan Scope." Activities 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 quality classificati;n,
. operating experience assessment, design, maintenance of environmental and fire protection qualification, nuclear fuel management, procurement, fabrication, i
handling, shipping, storage, cleaning, erecting, installing, testing, repairing, training, welding, in-service inspection, heat treatment, document control, records management, access authorization and fitness-for-duty.
)
Operational activities within the scope of this Plan are normal, abnormal and emergency operation, chemistry control, core performance monitoring, shift technical advice, equipment control, surveillance testing, in-service testing, maintenance, housekeeping, fire protection, security, radiological controls, radiological environmental monitoring, radwaste preparation for shipment, radwaste shipment, fuel handling / refueling, technical specification' compliance, and emergency preparedness.
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GPU NUCLEAR CORPORATE Number GPU POLICY AND PROCEDURE MANUAL 1000-PLN-7200.01 NUCLEAR
Title:
GPU Nuclear Operational Quality Assurance Plan Revision No.
11 Assurance activities within the scope of this Plan are assessment (audit.
document review, monitoring, survey, and surveillance), inspection, non-destructive examination, and safety review. Assurance activities are performed by individuals who are not directly responsible for managing or performing the work or activity. Nuclear Safety Assessment personnel, perform periodic assessments of the " assurance" activities performed by other departments (e.g.
QV, NDE/ISI) to assure effectiveness and adequacy.
The term document review as used in this document pertains to reviews conducted by Nuclear Safety Assessment as detailed in Appendix B of this Plan.
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. nose approved documents which specifically prescribe the methods to implement this Plan will be identified as prescribed by 3.2.2.2 of this Plan.
A specific task (s) associated with the above activities will be classified as within scope of this Plan depending upon:
Statements within the text and the regulatory guides identified in a.
Appendix C of this Plan; b.
The relationship of the task (s) to the safe operation of the nuclear plant; The relationship of the task (s) to the protection of personnel from the i
c.
effects of radiation; I
d.
The relationship of the task (s) to protection of the health and safety of the public; The relationship of the task (s) to regulatory requirements and e.
commitments, and; f.
Other factors as may be specified by GPU Nuclear management.
2.3 Graded Acoroach The extent to which the requirements of this Plan and its implementing documents are applied to an item will be based upon the effect of a malfunction I
or failure of the item on nuclear safety or safe plant operations.
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11 The need for special controls, and surveillance or maintaining of processes, equipment, and of cperaticnal activities will be applied consistent with:
The design and fabrication complexity or uniqueness of the item.
a.
b.
The degree to which ametionality can be demonstrated by inspection or test.
c.
The quality history and degree of standardization of the item.
The quality requirements for items within the scope of this Plan 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 established by the responsible department and subject to assessment by Nuclear Safety Assessment.
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 Appendix 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 environmental controls, fire protection, in-service inspection, in-service testing, licensed operator qualification and requalification, process control, off-site dose calculation, shift technical advisor training, environmental qualification of electrical equipment, security guard training and qualification, etc.
2.4 Levels of Ouality Assurance GPU Nuclear is committed to a comprehensive quality assurance process consisting of a three level approach to assure satisfactory, consistent and complete implementation of this Plan. Additionally, a self assessment program is implemented by GPU Nuclear to further evaluate and enhance performance.
2.4.1 Level I - Activities at this level include inspections, checks, or tests perfonned for the purpose of establishing acceptance and/or verification ofitems and Activities within the scope of this Plan. Level I Activities are performed by the Operations, Maintenance, Materials and Services, Radiological Controls, Engineering, and contractor personnel. Examples of Level I activities include:
Operations, Maintenance, and Radiological Controls, personnel performing tests, calibration ofinstnunents, radiation surveys, analyses of samples, and valve line-ups.
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Maintenance personnel perform checks, inspections and/or tests of I
' modification, replacement, repair and/or overhaul activities.
Quality Verification personnel performing inspections of modifications and mamtenance activities.
. - Materials and Services personnel conducting receipt inspections ofincoming materials / items.
Contractors performing inspections as applicable to their scope of work.
+
Engineering personnel periodically performing walkdowns, observations, measurements, etc. to revalidate the physical or functional configuration or condition of plant systems or components.
Performance of NDE on components after repairs or modifications.
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 and Appendix C).
Checklists, weld history records, travelers, reports, etc., are typically 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 Nuclear Safety Assessment. The level of surveillance or monitoring applied is consistent with the importance of the item to safety and the extent of j
administrative controls utilized for the Level I activity.
At this level, procedures and instructions are established and surveillance and/or monitoring records will be completed and maintained. Such surveillancdmonitoring normally includes observation of tests and inspections, j
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 ofinternal and i
external communication for management direction, and properly trained personnel for implementation of these activities.
2.4.3 Level III - The purpose of this level of activity is to assure, through a comprehensive program of review, assessment and audit, that all organizations conducting activities and/or tasks within the scope of this Plan are properly satisfying all the requirements of the Operational Quality Assurance Program.
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11 At this level, procedures and instructions are established, including the use of comprehensive checklists or detailed reports for documentation of the third-level activity.
For audits, the program requirements of ANSI N45.2.12 shall be satisfied. Lead auditors shall be utilized who are qualified to the requirements of ANSI N45.2.23. Additional technical support personnel, from areas with administrative reporting outside the function that is being audited, will be utilized as Audit Program Management deems necessary. The organization performiag this audit activity has sufficient authority. independence and lines of intemal and external communications to obtain the necessary access to management to conduct the review and audit, resolve any issues which may arise from the review and audit and secure additional technical support for the performance of audits as may be required.
2.5 Operational Ouality Assurance Plan Control This Plan is authorized by 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 B; 10CFR71, Subpart H; 10CFR72 Subpart G; ANSI N45.2; and ANSI N18.7.
2.5Property "ANSI code" (as page type) with input value "ANSI N18.7.</br></br>2.5" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..1 Accroval This Plan shall be originated by the Director-Nuclear Safety Assessment and be approved by the President with concurrence by the following:
Director-TMI Director-0CNGS Director Engineering Director-Human & Administrative Services Corporate Procedure Administrator Responsible Technical Reviewer 2.5.2 Revisions The Director-Nuclear Safety Assessment is responsible for ensuring this Plan is modified and updated as needed. Proposed revisions to this Plan may be suggested by GPU Nuclear personnel by submitting a written request to the Director-Nuclear Safety Assessment.
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11 I
l The Director Nuclear Safety Assessment, shall for each revision to this Plan, f
I determine if the changes reduce or do not reduce the commitments in this Plan previously accepted by the NRC.
1 Revisions to this Plan that do not reduce commitments to the NRC shall be originated by the Director-Nuclear Safety Assessment and approved by President with the concurrence of any Division Director affected. The Cover Page containing the approval and concurrence signatures of the President and the Division Directors shall be retained. Revisions of this type do not require approval by the NRC p-br to implementation, but must be submitted to the NRC at least annually. The Document History page will be utilized to identify such changes.
Revisions of this Plan that reduce the commitments previously accepted by the NRC shall be submitted to the NRC. 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 this Plan must include all pages affected by that change and must be accompanied by a transmittal letter identifying the change, the reason for the change, and the basis for concluding that the revision continues to satisfy 10CFR50, Appendix B and provides a suitable level of control. The letter need not provide the basis for changes that correct spelling, punctuation, or editorial iterrs. 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-Nuclear Safety Assessment, approved by the President with the concurrence of the Division Directors as indicated by their signatures on a revised Cover Page.
2.5.3 Distribution Copies of the Operational Quality Assurancu Plan may be distributed as
" Controlled" or " Uncontrolled" in accordance with the requirements astablished in Section 3.
2.5A Effective Date ofImolementation Changes to this Plan shall be incorporated in the implementing documents.
within 60 days of the issuance date of the Plan unless an interim action plan is defined and approved by the Director-Nuclear Safety Assessment.
Implementing documents which do not require a substantive revision may be combined with a revision at a future date or at the next periodic review of the document. Exarnples of a nonsubstantive revision as used in this context include organizational titles, requirements which exceed the revised OQA Plan requirements, or changes in reporting relationships not specified by Technical Specifications.
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l 11 1
2.6
, Quality Assurance Procram Feview The effectiveness of the QA Program and its implementation is periodically reviewed by various organizations at various levels and the results of these reviews are documented in reports to the Division Directors and the President for evaluation and corrective action as required. The cirectiveness of the QA Program is evaluated and reported by Nuclear Safety Assessment through the
{
su Teillance, monitoring and auditing functions. Other divisions provide additional information/ evaluations as requested.
In addition to the reviews and evaluation performed by the Nuclear Safety Assessment, the President shall have, at least once per year, an independent assessment performed of the QA Program implementation to ensure that the QA Program is effective in ensuring that regulatory requirements and commitments; and, GPU Nuclear policies are met. Th.is assessment may be performed utilizing a safety review group, 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 fornially identified and tracked through resolution.
2.7 Lndoctrination and Trainins Formal indoctrination and training programs for personnel performing or verifying activities within the scope of this Plan are required to be established and naaintained. A Training Department is established and staffed and is responsible for planning, scheduling, developing and providing training to GPU Nuclear personnel. The indoctrination and training programs are established by on-site and by off-site organizational units responsible for the performance or verification of activities within the scope of this Plan.
The proficiency of personnel shall be evaluated; and, measurea to maintain proficiency shall be implemented through either retraining, reexamining and/or
)
recertifying.
When certification is required, a certificate (s) shall delineate the specific function (s) the individual is cer.ified to be able to perform and the criteria used to certify the individual for that function (s).
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 I
Subsection 2.2.2 of this Plan. Subsection 2.3 provides further basis foi grading the extent of application of the requirements of this Plan to activities.
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I1 Documents that prescribe methods for implementing the requirements of this i
Plan shall be marked as specified by 3.2.2.2.b of this Plan.
j i
Items within the scope of this Plan shall be classified and identified as " Nuclear j
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-Nuclear Safety Assessment or designee prior to issuance.
Structures, systems and components shall be identified on a Quality Classification List (QCL). A QCL shall be established and maintained, by Engmeering, for each plant. The classification of structures, systems and components will be subject to independent design review as part of the classification process.
Spare or replacement parts and materials are not necessarily classified the same as the component of which they are a part. Such parts and materials that perform or contribute to the performance of a Nuclear Safety-Related or Regulatory Required 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 Engineering. The determinations will be documented, retained and subject to review and assessment by Nuclear Safety Assessment.
Refer to Section 5.0 for additional requirements.
2.9 Reputatorv Commitments Records of regulatory requirements and commitments are maintained by Nuclear Safety Assessment. Appendix C herein lists those Regulatory Guides which contain specific quality assurance requirements with the stated GPU Nuclear position, exceptions and/or clarifications provided. These must be complied with in conjunction with this QA Plan. Appendix C will be revised, as necessary, to reflect any change in the GPU Nuclear commitment to the Regulatory Guides. Nuclear Safety Assessment provides GPU Nuclear documented positions and interpretations on all other regulatory guides not contained in Appendix C of this Plan as may be required.
2.10 Resolution of Disputes and Escalations 1
All personnel, including those performing assurance activities who are not part of Nuclear Safety Assessment, have access to the Director-Nuclear Safety l
Assessment to raise quality or safety concerns. Disputes involving quality or safety arising from a difference of opinion shall, if possible, be resolved at the level at which such disputes occur. If this is not possible, the difference of opinion shall be escalated through supervisory / management levels until resolution is achieved.
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The Director-Nuclear Safety Assessment shall make the decision on matters related to if and to what degree this Plan applies to activities, quality requirements, and verification and acceptance to established requirements.
The Director-Engineering shall make the decision on matters related to classification of items, and technical requirements or design changes.
The responsibility of the Director-Nuclear Safety Assessment for QA Plan implementation takes precedence over his other duties. In the event of a conflict between the Manager (s) Assessment and any non-QA activity reporting to the Director, Nuclear Safety Assessment, the director will delegate his authority to resolve the conflict to the Manager (s) Assessment. The Manager (s) Assessment has authority to report directly to the President.
l The Director-Nuclear Safety Assessment shall be responsible for evaluating deficiencies generated by Nuclear Safety Assessment, as specified in 8.2.8 of this Plan. Escalation of significant deficiencies to higher management levels shall be evaluated in accordance with written procedures when inadequate er untimely responses occur.
i l
2.11 Safety Review Procram 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 qualified Responsible Technical Reviewer on documents and substantive revisions of documents as specified by the GPU Nuclear Review and Approval Matrix.
(1000-ADM-1291.01)
The independent safety review is an independent review of documents and substantive revisions of documents as specified by the GPU Nuclear Review and Approval Matrix. It includes a review of a safety evaluation. This review is conducted by a qualified Independent Safety Reviewer (ISR) on safety evaluations associated with documents and substantive revisions to documents l
as specified by the GPU Nuclear Review and Approval Matrix. The ISR shall not have direct responsibility for the activity reviewed.
2.12 Indeoendent Safety Oversieht The first element of oversight of safety is the Independent On-Site Safety Review Group (10SRG). An 10SRG shall be located at each generating station.
The 10SRG has no line responsibilities or line functions and is devo:cd solely to RErQAP.On 27.0
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I1 safety matters. It is independent of the plant staff and reports off-site to the Director-Nuclear Safety Assessment. Each IOSRG will consist of a manager, who reports to the Director-Nuclear Safety Assessment and a minimum of three full time engineers / technical staff.
~
Each IOSRG shall have access to the unit and unit records as necessary to perform its evaluations and assessments. Based on its reviews, the IOSRG shall provide recommendations to the management positions responsible for the areas i
reviewed. IOSRG reports of evaluations and r ssessments shall be transmitted to the Director-Nuclear Safety Assessment and the management positions responsible for the areas reviewed.
i The second element of oversight of safety is the Nuclear Safety Assessment staff, who audit, monitor and assess aspects of GPU Nuclear activities within the scope of this Plan or relating to safety. This provides for an overview of activities affecting or potentially affecting safety.
The third element of oversight of safety is the General Office Review Board.
This is a group of senior level individuals with diverse backgrounds and extensive nuclear experience. The Board reports to and takes general direction from the President but has direct access to the Chairman of the Board and the Board of Directors. Its charter is broadly defined to encompass all matters potentially affecting nuclear safety (including management related aspects) so as to foresce potentially significant nuclear safety and radiation problems.
Nuclear Safety Assessment provides staff support to the General Office Review Board.
2.13 SelfAssessment Organizations responsible for performance of activities within the scope of this Plan may perform evaluations to assess their performance, seek opportunities for improvement or address known problems. Nuclear Safety Assessment will typically review self assessment activities conducted by other departments as part ofits independent assessments. Nuclear Safety Assessment will not eliminate assessments required by this Plan as a result of departmental self-assessment activities but may alter scope when self assessment activities sufficiently address subject areas.
i 4
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11 2.14 Ombudsman An Ombudsman is provided by Nuclear Safety Assessment as part of the company's employee concern program at each site. This individual is accessible on a confidential basis, if desired, 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 Ombudsman will reply to the individual who raised the matter.
(
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