ML20065M708

Changes to Gpunc Operational QA Plan for Three Mile Island Unit 1 & Oyster Creek, Involving Relocation of Audit Frequencies from TS to New App E of Plan

ML20065M708
Person / Time
Site:	Oyster Creek, Three Mile Island
Issue date:	04/15/1994
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20065M656	List: ML20065M649 ML20065M668 ML20065M683 ML20065M708
References
1000-PLN-7200.0, NUDOCS 9404260154
Download: ML20065M708 (13)

Text

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GPUNC OPERATIONAL QUALITY Numbar Nuclacr ASSURANCE PtAN roa TuREE site ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.Ol Titlet GPUNC Operational Quality Assurance Plan for Three Revision No.

Mile Island Unit 1 and Oyster Creek See Note Below.

Applicability / Scope This Plan Has GPUNC-Wide Applicability Responsible Office Except TMI-2 6160 This Document is within QA Scope I YES NO Effective Date Safety Reviews Required 1 YES NO See Note Below.

List of Effective Pages on Page 2.0 NOTE: The changes of this revision involve relocation of audit frequencies from Technical Specification to new Appendix E of this Plan. A revision number and effective date are not being provided for this revision pending NRC's approval of the said changes.

um Signature Concurring Organizational Element Date Originator Director, Quality Assurance Concurred By Dir-Services Dir-Independent Safety Review Dir-Nuclear Assurance Dir-OCNGS Dir-TMI Unit 1 Dir-Technical Functions

-s a h Approved By Office of the President 4/// h

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365 % wro 1.0 l 9404260154 940419 PDR ADOCK 05000289 P PDR

GPUNC OPERATIONAL QUALITY ASSURANCE Numbar

- n Nucirr pun rOR TnREE azi.E 151.mm uNzT 1 ANO OYSTER CREEK 1000-PLN-7:00.01

Title:

Organization Revision No, See Note cr. PO.  ;

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GPUNC OPERATIONAL QUALITY ASSURANCE Numbar

• M WINuciccr PtAu rOR TnRtE artE 1.itANO UN1T 1 AND OYSTER CREEK 1000-PLN-7200.01 Titles 10.0 Audits Revision No.

See Note on Pa. I

c. Procedure (s) f or the scheduling, preparation, performance, reporting of the results of audits, and distribution to appropriate 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 areas to be audited are listed in the Nuclear Units' Technical specifications. The frequencies of internal audits are based on performance and are listed in Appendix E of this plan. Annual review of these frequencies shall be conducted. This review shall examine the appropriateness of the prescribed audit frequency by considering performance factors such as deficiency trends, assessment results, etc.

and shall determine if more frequent audit is needed of the topical area (s).

lO.i.E Tne frequency of conducting external audits of selected suppliers of technical support, environmental monitoring, radwaste shipping, computer, radicanalytical, and engineering services shall be scheduled once within the life of the activity or every three years depending on the dura

• ion of the contractual relationship.

10. .t Each audit shall be led by a GPUN certified lead auditor. Audit team memt>e r s shall be utilized as required and will be classified as either auditors or technical specialists, depending on their function on the audit team.

10...' Those GPUN and external organizations providing items and/or conducting activit3es within the scope of this Plan are subject to audit consistent with the requirements of this Plan.

10.'.e Audits shall be performed in accordance with pre-established written procedures or checklists. The personnel utilized to perform on an audit shal; not have any responcibility for the activity audited.

10 . . . - Audits shall consist of reviews of approved documents and records and observation (s) of selected activities in sufficient detail to determine the appropriatenens of the documents for use, effectivenose of implementation and the effectiveness of actions taken to correct pre v iot.s nonconformancen 10 ;.10 Audited orcanizations shall provide sufficient support to assure the accuracy of the audit results, review and reuponse to audit nonconform-ances, and effective resolution / prevent 2on of deficiencies. The corrective actions required to resolve adverse audit findings shall be defined and implemented in a timely manner.

10.2 1. Audit finding nonconformances chall be followed up in a timely manner.

Suen adverse audit findingu shall typically not be closed until the effective implementation of corrective action (s) is verified.

10.2 12 Sufficient recordG shall be generated and maintained to provide documentation of audit system scope of coverage, individual audit coverage i..e , audit plann, checkliatn, or equivalent), audit reports, lead auditor cert.facations, followup and verification and results of periodic analySin of audit results.

3899L (12/88) 84.0

GPUNC OPERATIONAL QUALITY ASSURANCE i Number

' ENucirr PtAN rOR TaaEE x:tE : STAND uNr7 1 AND OYSTER CREEK 1000-PLN-7:00.0;

Title:

Appendices Revision No.

See Note on P . .

APPENDIX C - PART 2

2. Edditions to existing plant systems will be made to tne same code, standard and technical requirements wnten were originally applied to the system to which the addition is to be made or more recent versions of these codes, standards and technical requirements. The acdttion will not degrade the safety of the system being acced to.

2. For new construction, the latest applicable code wil. ce utilizec unless sucn utilization would result in harcsnip or unusual difficulty witnout providing an equivalent level of safety.

Nar co;;;ator, cutde 1.30. Aucust 1C72 Qga': . Acsurance Paquirements for the !nstallation, Inspection and Testinc cf Instra-vriat: On anc Electr:c Eculpment GPUN sna11 comply with the Regalatory Position established in this Regulators Guice in that QA programmatic / administrative requirements

.ne; ace: :nerein snall apply to maintenance and modification activities even tnougn such requirements were not in effect originally. Tecnnical requirements associated with maintenance and modifications snall be the origtnal technical requirements or better (e.g., code requirements,

.aterial properties, design margins, manufacturing processes, and

nspection requirements).

Sertionc 5.; and 6.2 Of ANSI N45.:.4 list tests wnich are to be conducted nar;ng tne construe lon phase. In ._eu of this, GPUN utilizes its Incineering ano/cr Maintenance organa:ations to establisn :ne need fer specific tests er test procedures curing the operational pnase.

~~

NPc ~omu .a c rt Gu;de tev. Februare Ic'9 Oua. -- issurarra Precra- 4equire+ents s or.e ra t : c r i The CPUN QA Program complies with the regulatory position of this guide

-atn :ne following clarificat1Ons:

. Reculatory Posit 10n C.4 cf tne regulatory guide Tne frequency cf performance an: minimal tcpical coverage of internal aud.ts w... De consistent w;tn Appencax E of this plan.

3900L 61; sii 94.0

GPUNC OPERATIONAL QUALITY ASSURANCE Numbsr ENuclacr PtAN rOR TaREE x:tE 15tANo uN1T 1 AND OYSTER CREEK 1000-PLN-7 CC.01 Title Appendices Revision No.

See Note on Pc. .

APPENDIX C - PART 0

4. Hose may be used in lieu of pipe where the connections are temporary The ant:Cipated BDDlications of hose would n0rmally be (1) Connections te contractor owned skid mounted radioactive waste process 1nc eculpment, (2) connections to a nonmounted, frecuentiv-enanced component surn as a buria; liner / HIC or (31 00nnections te nonmounted pieces of radtoactive waste processino or ecliection ecu:pment wn:ch must be readil'. removeable (e.c. Items placed on eculpment natenes).

The cressure rat;nc of such hoses and connections snal; ecua; er exceed those cf the system!s) er component (si to which thev are connected.

Prior to use, the hoses shall be hydrotested to the appropriate pressure for tne system or component to which they are connected.

After installation, thev are to receive recular nydrotest nc Cr

..ser.tre inspecttons.

A safat. evaluation is recuired tr iustify tne use of suen hose

- n er ;ons.

NPC b re : ; a t r r v Gu;de 14.; , January 1Q79 Aucit;-- c' Oua;;ts Assurance Procrams for Nuclear Power Plants GPUN is in basic agreement with the position set forth in the Regulatory Gu;de auc ect to :ne f ollowing co:nments :

. Se?t;rne C.:.at: and C.3.a(2)

Tne frequency of performance anc minimal topical coverage of internal auc;ts wai. De consistent witn Appendix E of this plan.

. Sect; r C

.rt  !. Source survetilance will be utilized in lieu of or

.n a : t; r. :: receipt inspect cr.. As permitted, external audits of suen pr -curement art;ons w;.1 typicall, not be seneduled.

2. sor :-- ".:.rtr>

External aud: s cf selected suppliers of services wnich are within the s::pe ci :nts Plan w;.. De seneculee and conducted at least once a; thin :ne life of :ne art:vit. cr every three years. Refer also to

.;.5 ;!

n;s p.an.

An annua. evaluation cf suppliers of ;tems, parts, materials and l services s... ce conductec. These evaluations will be conducted l ut..; ;n: ne resu;ts of source surve;11ance, source inspection, l receipt :nspect;cn and/or aud ts; and, other factors. These i eva;uat:Ons wi.. ceterm:ne tne neec to concurt audits of suppliers of l

tems, parts er materials, or, .ncrease the frequency of conducting 1 aucats of suppliers of services. l l

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3900*_ i;;/82) 108.0

GPUNC OPERATIONAL QUALITY ASSURANCE Numb:r Nu2iocr PtAN FOR TnREE MrLE 1 STAND UN1T 1 AND OYSTER CREEK 1000-PLN-7200.01

Title:

Appendices Revision No.

See Note on Pg. 1 Appendix E Maximum Frecuency D11_Ref 1 OC Re[1 , Description (See Note 1) 6.5.3.1 (A) 6.5.3.1 (A) The conformance of unit operations to 24 Months provisions contained within the Technical Specifications and applicable license conditions.

6.5.3.1 (B) 6.5.3.1 (B) The performance, training and 24 Months qualifications of the entire unit staff.

6.5.3.1 (C) 6.5.3.1 (C) The verification of the nonconform- 24 Months ances and corrective actions program (See Note 2) to be properly implemented and documented as related to action taken to correct deficiencies occurring in unit equipment, structures, systems or methods of operation that affect nuclear safety.

6.5.3.1 (D) 6.5.3.1 (G) The performance of activities 36 Months required by the Operational Quality Assurance Plan to meet the criteria of Appendix B " , 10CFR50.

6.5.3.1 (E) 6.5.3.1 (D) The Emergency Plan and implementing 12 Months (Reg.

procedures. Reg'd. Frequency) 6.5.3.1 (F) 6.5.3.1 (E) The Security Plan and implementing 12 Months (Reg.

procedures. Reg'd. Frequency) 6.5.3.1 (G) 6.5.3.1 (F) The Fire Protection Program and 24 Months implementing procedures 6.5.3.1 (H) 6.5.3.1 (I) The Offsite Dose Calculation Manual 36 Months i and implementing procedures.

6.5.3.1 (I) 6.5.3.1 (J) The Process Control Program and 24 Months implementing procedures for solidification of radioactive wastes. ,

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3900L (12/88) 115.0 i

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GPUNC OPERATIONAL QUALITY ASSURANCE Numbar Nuclocr PtAN rOR TnRzz Miss 1 STAND UN1T 1 AND OYSTER CREEK 1000-PLN-7200.01

)

Titiet Appendices Revision No.

See Note on Pg. 1 Appendix E Maximum Frequency TBI Re12 OC Re[1 Description (See Note 1) 6.5.3.1 (J) 6.5.3.1 (H) The performance of activities 24 Months required by the Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December, 1977.

6.5.3.1 (K) 6.5.3.1 (K) Any other area of unit operation As Requested considered appropriate by the 10SRG or the Office of the President-GPUN.

6.5.3.2 (A) 6.5.3.2 (A) An independent fire protection and 12 Months loss prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.

6.5.3.2 (B) 6.5.3.2 (B) An inspection and audit of the fire 36 Months protection and loss prevention program, by an outside qualified fire consultant.

Note 1: All frequencies, except for those that are regulatory required or listed as 36 months, can be extended for an additional 25% to allow for schedule flexibility. If the 25% extension or a portion thereof has been used for an audit, the scheduled interval for the second audit will start at the actual end-date of the let audit. The 25% will not be used on two consecutive audits of the came area.

Note 2: Corrective action will be a standard audit scope item for all individual audits.

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3900L (12/88) 116.0

N U] Nuclear Memorandum sen 10CFR50.54 Review of Audit om: March 4,1994 Related Changes tr = S. N. Tiwari - Engineer Sr. I u m on; Morris Corp. Center 6161-94-034 w M. W. latggart - Mgr., Corporate Licensing A Technical Specification Change Request (TSCR) is being initiated to transfer the frequencies of audits from Plants' Technical Specifications to the GPU Nuclear's Operational Quality Assurance Plan (OOA Plan). The following verbiage changes in the '

OA Plan have been proposed to facilitate this transfer:

l. 10.2.4 The areas to be audited are listed in the Nuclear Units' Technical Specification. The frequency of internal audits is based on performance. These frequencies are listed in Appendix E to this Plan.

2. APPENDIX 'C' The frequency of performance and minimal Reg, Guide 1.33. Section 1 topical coverage of internal audits will be consistent with Appendix E of this plan.

3. APPENDIX 'C' The frequency of performance and minimal Reg. Guide 1.144 Section topical coverage of internal audits will be C.3.a(1)and C.3.a(2) consistent with Appendix E of this plan.

As apparent, the changes revolve around the proposed Appendix E. This appendix is attached as Attachment I to this letter. Attachment 2 provides the comparison between proposed and existing audit frequencies.

Analysis of Changes and 50.54 Determination The key elements of this proposed change in OOA Pian constitute of the 2 distinct aspects of proposed Appendix E; one, the Audit Schedule Performance Review, and two, the changed audit frequencies.

A numerical comparison of the existing frequencies prescribed in the Units' Technical Specifications with the proposed frequencies indicates that the frequencies for audits associated with Fire Protection program are not changed. Also not changed are the frequencies mandated by regulations, such as, those for Security Plan and Emergency Plan.

Frequencies of other audits have been proposed to be reduced.

10CFR50.54 Review of Audit Related Changes Ifage 2-If the premise of commitment is the numerical frequency of the audit (s), the proposed numerical reduction in audit frequencies constitute an apparent reduction in GPU Nuclear commitment. It should, however, be noted that this quantitative reduction does not compromise the quality of GPU Nuclear's oversight of its operations. In fact the proposed controls, such as the Audit Schedule Performance Review and the inclusion of Corrective Actions as an item in all audits, enhance the quality of the oversight.

The proposed Audit Schedule Performance Review is the annual review of the performance of the topical area (s) by a group of managers including appropriate plant or corporate management to decide if more frequent audits will be needed. To make this decision, this yearly review will consider such salient performance data as deficiency trends, industry events, notice of violations and licensee event reports. This important database and the conduct and frequency of this review focuses critically on the performance of the area audited and not rnerely on the prescriptive duration between two audits. This position is consistent with NRC's Regulatory Review Group's (RRG) Recommendations, which among other things, recommends a performance based and graded quality assurance.

(Refer to the topical area titled ' Quality Assurance' of the implementation Plan of SECW 44-003 of January 7.1994, and associated RRG's recommendation 4.1.1 ). This yearly performance review combined with the inclusion of Corrective Action as an item for all audits is a significant step towards enhancing the efficiency and quality oEoversight.

Based on the above analysis, it has been determined that the proposed change constitutes a reduction in commitment, although it improves the quality of oversight.

i S. N. Tiwa[

Extension 7433

References:

l. 10CFR50.54

2. NRC SECY 94-003, January 7.1994, Quality Assurance and associated RRG recommendation 4.1.1

Attachment 1 Operational QA Plan Appendix E Maximum Freauency Hil Ref. OC Ref, Description (See Note 1) 6.5.3.1 ( A) 6.5.3.1 (A) The conformance of unit operations to 24 Months provisions contained within the Technical Specifications and applicable license conditions.

6.5.3.1 (B) 6.5.3.1 (B) The performance, training and qualifications 24 Months of the entire unit staff.

6.5.3.1 (C) 6.5.3.1 (C) The verification of the nonconformances and 24 Months corrective actions program to be properly (See Note 2) -

implemented and documented as related to action taken to correct deficiencies occurring in unit equipment, structures, systems or methods of operation that affect nuclear safety.

i 6.5.3.1 (D) 6.5.3.1 (G) The performance of activities required by the 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.

6.5.3.1 (E) 6.5.3.1 (D) The Emergency Plan and implementing 12 Months (Reg.

procedures. Reg'd. Frequency) 6.5.3.1 (F) 6.5.3.1 (E) The Security Plan and implementing 12 Months (Reg. l procedures. Reg'd. Frequency) )

6.5.3.1 (G) 6.5.3.1 (F) The Fire Protection Program and 24 Months implementing procedures 6.5.3.1 (11) 6.5.3.1(1) The Offsite Dose Calculation Manual and 36 Months implementing procedures.

6.5.3.1(1) I 6.5.3.1 (J) The Process Control Program and 24 Months implementing procedures for solidification of l' radioactive wastes.

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Attachment 1 Operational QA Plan Appendix E Maximum Frequency TMI IteL OC iter. Description (See Note 1) 6.5.3.1 (J) 6.5.3.1 (H) The performance of activities required by the 24 Months j Ouality Assurance Program to meet criteria of l Regulatory Guide 4.15, December,1977.

6.5.3.1 (K) 6.5.3.1 (K) Any other area of unit operation considered As Requested appropriate by the IOSRG or the Office of the President-GPUN.

6.5.3.2 ( A) 6.5.3.2 ( A) An independent fire protection and loss 12 Months prevention program inspection and audit shall l I

be performed uth .ing either qualified licensee I personnel or an outside fire protection firm.

6.5.3.2 (II) 6.5.3.2(il) An inspection and audit of the fire protection 36 Months and loss prevention program, by an outside qualified fire consultant.

Note 1: All frequencies except for those at 36 months can be extended for an additional 25%

to allow for schedule flexibility. The 25% will not be used on two consecutive audits of the same area.

Note 2: Corrective action will be a standard audit scope item for individual audits throughout the annual audit schedule.

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Attachment 2 _

Comparision of Existinn and Proposed Audit Frequencies TN11 _QC Existing Proposed Freauency Tech. Spec. Tech. Spec Frequency (See Note 1)

Ref. Ref. Description 6.53.1 ( A) 6.53.1 ( A) The conformance of unit operations to 12 months 24 N1onths provisions contained within the Technical Specifications and applicable license conditions.

633.1 (B) 6.53.1 (B) The performance, training and qualifications of 12 Months 24 Months the entire unit staff.

6.53.1 (C) 6.53.1 (C) The verification of the nonconformances and 6 Months 24 Months corrective action 3 program to be properly (See Note 2) implemented and documented as related to action taken to correct deficiencies occurring in unit equipment structures, systems or methods of operation that affect nuclear safety.

6.53.1 (D) 6.53.1 (G) The performance of activities required by the 24 Months 36 Months Operational Quality Assurance Plan to meet the criteria of Appendix "B",10CFR50.

6.53.1 (E) 6.53.1 (D) The Emergency Plan and implementing 12 months 12 Months (Reg. Reg'd.)

procedures.

6.53.1 (F) 6.53.1 (E) The Security Plan and implementing 12 Months 12 Months (Reg. Req'd.)

procedures.

6.53.1 (G) 6.53.1 (F) The Fire Protection Program and implementing 24 Months 24 Months procedures 6.53.1 (H) 6.53.1(I) The Offsite Dose Calculation Manual and 24 Months 36 Months implementing procedures.

freQ TD3

O Attachment 2 i

Comparision of Existine and Proposed Audit Frecuencies T511 OC Existing Proposed Frecuency Tech. Spec. Tech. Spec Frequency (See Note 1)

Ref. Ref. Description 6.53.1(1) 6.53.1 (J) The Process Control Program and 24 Months 24 hionths implementing procedures for solidification of radioactive wastes.

6.53.1 (J) 6.53.1 (II) The performance of activities required by the 12 Months 24 hionths Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December,1977.

6.53.1 (K) 6.53.1 (K) Any other area of unit operation considered As As Requested appropriate by the IOSRG or the Office of the requested President-GPUN.

6.53.2 (A) 6.53.2 (lA) An independent fire protection and loss 12 hionths 12 hionths prevention program inspection and audit shall be performed utilizing either qualified licensee personnel or an outside fire protection firm.

6.53.2 (B) 6.53.2 (B) An inspection and audit of the fire protection 36 Months 36 Months and loss prevention program. by an outside qualified fire consultant.

Note 1: All frequencies except for those at 36 months can be extended for an additional 25% to allow for schedule flexibility. The 25Fc will not be used on two consecutive audits of the same area.

Note 2: Corrective action will be a standard audit scope item for individual audits throughout the annual audit schedule.

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