ML19351A235
| ML19351A235 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, Three Mile Island, 05000000 |
| Issue date: | 12/29/1988 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML19351A234 | List: |
| References | |
| 1000-PLN-7200.0, NUDOCS 8901170303 | |
| Download: ML19351A235 (204) | |
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i GPUNC OPERATIONAL QUALITY ASSURANCE, Numbe-E t
D, I PLAN FOR THREE MILE ISLAND UNIT 1 1000-PLN-7200.01 '
N AN) OYSTER CREEK GPUNC Operational @ality Assurance Plan for Three i: -~ . . , . Title, Revisi.,n No. .
p Mile Island Unit 1.and Oyster Creek' 2 i
?' 1 Responsible Office i' Applicability / Scope L< ;. This Plan Has GPUNC-Wide Applicability Except TMI-2 6160 :
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.This document is within QA plan-scope X Yes -
No Effective Date :
, Safety Reviews Required ~TYes No
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I Concurrina Organizational Element Date L. oriainator /t/ R.
Signature
- d. Konton Sirector Quali"v Asuurance 0/18/88 L' '
L Concurred /s/ P. l. F'ed or )ir-Ouality & " rain na 0/l!4/88 By /s/ H. ). Muk11 ' )lr-TMI-1 11/4/88
/s/ E. .. FitIDatrick )lr-Oyster Creek 11/4/88
/s/ R. . Wilson )ir-Technical Functions 10/24/88 -
p /s/ J. E. Hildebrand )ir-Rud. 6 Environ. Controls 10/24/88
/s/ R. L. Lona )1r-P' ann .no & Nuclear Safety 10/24/88 L
/s/ F. F. Mancanaro )ir-Administration 10/18/88 l' 10/24/88
!' /s/ R. W. Heward )lr-Maint.. Const. & Facilities
/s/ H. Sayers Corporate Secretary 10/18/88 e
/s/ C ,N. C_omerfotd Services Manager 12/20/88 l u #h- ,/ . Responsible Technical Reviewer ah-/#
i Approved '~r/ M .-t ds Office of the President / /hARC l- .,
By ..~ , , , / '/
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. i GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear PLAN FOR THREE MILE !$ LAND UNIT I 1000-PLN-7200.01 AN) OYSTER CREEK ,
Title GPUNC Operational Quality Assurance Plan for Three Revision No. s Mile Island and Oyster Creek 2 LIST OF EFFECTIVE PAGES
).'
P49e Rev. Content Page Rev. Content Page Rev. Content Page Rev. Content No. No. Chanced No. No. Changed No. No. Chanced _% No. Chanced 1.0 2 *' 29.0 2 *
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Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE
'u" ra a re attf rSu e U.IT i AN) OYSTER CREEK Nu.mbe,r i0 - tN-7200.cl l
i Tttle.
-- s GPuMC Operational Qual:ty Assurance Plan for Three Revtston No. ;
Mile. Island and Oyster Creek.
2 l -
TABLE OF CONTENTS
!. tat :
LIST OF EFFECTIVE PAGES 2.0 TABLE OF CONTENTS.
3.0 .
DOCUMENT HISTORY 6.0 INTRODUCTION \
'7.0 '
l '. 0 ORGANI2ATION 1.1 0Ffice'of the President '
l.2' Directors TNI-1 and Oyster Creek 8.0 1.3 9.0 Director Technical Functions 9.0 1.4 Director Administration ,
1.5 9.0 Director Quality & Training 9.0 1.6 Director Naintenance, Construction & Factittles 1.7 Corporate Secretary. 12.0
- 1.8 12.0 Director Planning and Nuclear Safety 13.0 4
, 1.9 Director Radiological & Environmental Controls 13.0 2.0 QUALITY ASSURANCE PROGRAM 2.1 General
+ 2.2 Scope- 14.0 -
14.0
- i. 2.3 Graded Approach
.2.4 16.0 l Three-Level Assurance Approach 17.0 2.5 Operational QA Plan Control 2.6 19.0 Quality Assurance Program Review 20.0 2.7' Indoctrination and Training 21.0 2 '. 8 Classification Process 21.0 2.9 Records of Regulatory Commitments 22.0 2.10 . Safety Reviews 22.0 9 2.11 Responsibillties 24.0 3.0 CONTROL OF DOCUMENTS AND RECORDS !
3.1 Policies, Plans, Instructions, Drawings, Specifications 27.0 3.2 Document Control 29.0 '
3.3 Quality Assurance Records 32.0 l' 4.0 DESIGN CONTROL l' 4.1 General 36.0 4.2 Recuirements 36.0 4.3 Responsibilities 38.0 l.
l 3.0 3685L (12/88) h E. . _ _ ._ , _ _ . _ . . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _ . _ . _ . _ _ _ . _ _ . . _ . . . _ . . _ _ . _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _
I GPUNC OPERATIONAL QUALITY ASSURANCE Number Nucioar "u" roa taart "I'r ts u ao uart i AN) OYSTER CREEK iooo-Pu-noo.oi Title GPUNC Operational Quality Assurance Plan for Three Revision No.
Nile Island and Oyster Creek 2 l TABLE OF CONTENTS (CONTINUED) 5.0 PROCUREMENT AND MATERIAL CONTROL i 5.1- Control of Procurement 5.2 40.0 Identification and Control of Materials, Parts and Components 46.0 l 6.0 CONTROL OF STATION ACTIVITIES 6.1 General 49.0 6.2 Control of Inspections 49.0 6.3 QA Monitoring 6.4 52.0 i
' Control of Special Processes 53.0 6.5 Test Control 6.6 54.0
!- Control of Measuring and Test Equipment 58.0-l- 6.7 Handling, Storage and Shipping 6.8 59.0 l Inspection, Test and Operating Status 61.0 6.9 Housekeeping and Cleanliness 63.0 6.10 Equipment Control 64.0 6.11 Control of Construction, Maintenance 65.0
- (Preventive / Corrective) and Modifications 6.12 Control of Surveillance Testing and Inspection 69.0 6.13 Radiological Control 70.0 ),
L 7.0 CONTROL OF RADT0 ACTIVE WASTES
- 7.1 Geners ',
7.2 72.0 l Reautrements 72.0 7.3 Responsib111 ties 73.0 8.0 CONTROL OF CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 General 75.0 l 8.2 Requirements 75.0 l 8.3 Responsibilities 77.0 l
9.0 CONTROL OF TRAINING 9.1 General 79.0 9.2 Requirements 79.0 9.3 Responsibili ties 80.0 t
10.0 AUDITS 10.1 General 82.0 10.2 Requirements 82.0 10.3 Responsibilities 84.0 l
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l GPUNC OPERATIONAL QUALITY ASSURANCE Number Nehr PLAN FOR THREE MILE ISLAND UNIT 1 AN) OYSTER CREEK 1000-PLN-7200.01 :
Title GPUNC Operational Quality Assurance Plan for Three Mlle' Island and Oyster Creek Revtston No. '
2 *
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TA8LE OF CONTENTS (CONTINUED) '
.P111 APPENDICES:
86.0 Appendix A - Comparison Chart of Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards 87.0 t Appendix 8 - QAD Review Requirements for Documents ~ Mlthin QA Plan Scope 88.0 Appendix C - NRC Regulatory Guide Comitments and Exceptions 89.0 Appendix 0 - Terms and Defint tions 108.0 5
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GPUNC OPERATIONAL QUALITY ASSURANCE Number .
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Title GPUNC Operational Quality Assurance Plan for Three Revision No.
.Mlle, Island and Oyster Creek. 2' r
PREPARED BY:
REVIEWF.0 8Y: .
EFFECTIVE '
DESCRIPTION OF CHANGE APPROVED BY:
REVISION DATE i
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GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear Pt*N r0R TNREE Nite IS'ANO uhrT i iOOO-PtN-7200.0i AND OYSTER CREEK Title GPUNC Operational Quality Assurance Plan for Three Revision No.
Mlle Island and Oyster Creek 2 k lNTRODUC110N GPU Nuclear (GPUN) 1$ responsible for the operatton 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 ensu,' compilance with 10CFR20; 10CFR50 Appendix B; 10CFR71, Subpart H; and applicauh Regulatory Guides during the operation of TM1 Unit I and Oyster Creek. This plan sei;hees the Operational Quality Assurance Plans for TMI Unit I and Oyster Creek.
This Operational Quality Assuran".c 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 Plan identifies organizations responsible for the implementation of.the Quality Assurance Program (Section 1.0) and an overall description of the Program (Section 2.0). The remaining sections are structured in a functional manner.
The requirements for administrative controls are generte and apply to all sub-sequent sections. 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, ircluding 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; construction and/or modifications associated with corrective maintenance,' plant improvement, and/or I
repatr; and the processing and preparation for the transport and transportation 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 6.0 , 9.0 and 10.0 again apply to all activities within the scope of this plan. Section 8.0 l addresses the identification and disposition of nonconformances associated with all aspects of the Program. In addition, this section contains the management controls provided for evaluating collectively material nonconformances and l conditions adverse to quality and determining what corrective actions should be i taken to preclude their recurrence. Section 9.0 contains the requirements and administrative controls applicable to training; Section 10.0 contains the l requirements and administrative controls applicable to the conduct of audits. I Appendices A, B and C contain additional requirements associated with the functional areas discussed in this Plan. Appendix 0 contains the definitions ,
of terms used throughout this Plan.
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7.0 3685L (12/88)
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' Title 1.0 Organization Revision No. \
2 1.0 gim nization L
The GFUN Org6nization' Plan is the highest tiered document that assigns major functional responsibilities. Implementing documents i assign more specific responsibilities and tasks and define the i i
organizational interface (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 t positions which manage and perform activities within the scope of this plan. This section provides a summary of the organizational -
units and functions which perten activities within the scope of this plan.
The GPUN organtration is structured on the basis that the attainment of the objectives of this plan rolles on those who manage, perform, and support the performance of activities within the scope of this i plan; and, assurance of this attainment reites 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 Exhibit 1. Theseof the nuclear generating stations is tilustrated in and off site. organizations have functions located both on site s ,
1.1 -
Office of the President ,
The of thePresident President. and the Executive Vice President constitute the Office
.to the President-GPUN. The Executive Vice President-GPUN reports directly i The two officers work in close cooperation 1 and share the executive duties of GPUN. As used in this plan, the Office Executive of the VicePresident President.(OP) means either the President or the l'
The President-GPUN has the overall responsibility for the establish-ment, implementation and evaluation of the effectiveness of the
- Quality Assurance Program applicable to TMI Unit 1, and Oyster Creek.
This responsibility is administered through his management staff, including:
Corporate Secretary Director - OCNGS {
Director - TMI Unit I '
l Director - Technical Functions Director - Administration Director - Quality & Training i i
Director - Maintenance, Construction, & Facilities
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' Director - Planning & Nuclear Safety l i
Director - Radiological & Environmental Control t These OP management staff members give their full support to the L reautrements setstaffs.
forth in this plan ensuring full comp 11 axe by )
i their respective 1 I
8.0 3820L (12/88) l
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GPUNC OPERATIONAL QUALITY ASSURANCE ' Number-1 DTimNuclear us"oE"#lJ' 25'^"""" ' ' "d2 o' Title 1.0 Organization Revision No.
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1.2 Director-TMI Unit I and Ovster Creek Each of the Directors of the nuclear generating stations reports to t the Office of the President. They are each responsible to operate, '
g maintain, and refuel their respective generating station in a safe, u
re11able and effletent manner in accordance with corporate policies and all applicable laws, regulations, licenses and. technical require-l4 ments. The Division Director-Oyster Creek is the senior GPUN b 4 representative at Oyster Creek.and as such assures consistent implementation of policies and procedures at the plant and at GPUN E
' off-site facilities in theneyster Creek area. The Division Director- l TMI-I is the senior GPUN representative at the TMI site and as such assures consistent implementation of policies and procedures at the E plant and at GPUN off-site factittles in the TMI area. '
l y l' 1.3 - Director - Technical Functions The Director-Technical Functions reports directly to the Office of the *
. President. The Director's Quality Assurance plan responsib111 ties -
. consist of providing the requisite engineering and/or technical support to: maintain the design basis of the nuclear plant; maintain the configuration control documents; conduct operating expertence assessment (s); provide nuclear fuel management; provide core l performance monitoring; staff and direct shift technical advisors; monitor and analyze 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 tes ti ng.
1.4 Director - Administration The Director-Administration reports directly to the Office of the President. The Director's Quality Assurance Plan re:ponsibilities ,
consist of establishing, maintaining, and taplementing procurement, warehousing, and plant security programs.
1.5 Director - Quality & Trainino The Director-Quality & Training reports directly to the Office of the President. The Director's Quality Assurance Plan responsibilities consist of establishing, verifying and implementing quality assurance plans, practices and procedures; and, estabitshing, maintaining and delivering training and education programs sufficient to assure safe.
reliableandefficientoperationinaccordancewithCorporatePoliciesj and all appitcable laws, regulations and Itcenses. ;
l 9.0 3820L (12/88)
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ASSURANCE g"giya;gy'5 25'^* = ' " '"-T2 w.Di .
Title 1 0 Organization Revision No.
2 1.5.1
' Director - Ouality Assurang i i
independence and responsibility to assure the effectiv!
tation of and compliance to' the Quality Assurance Program.plemen- ;
sistent with this responsibility is the authority to render Con- later- l and the extent to which the plan applies to those activit Quality and Training.The Director-Quality Assurance reports :strectly -
Additionally. The Director-Quality Assurance has direct unencumbered access to the Office of the Presiden the Directors of each of the nuclear stations with regaru to quality activities.
This reporting relationship has been established to ence from the influence of costs and schedules to be ;
tively assure conformance to Quality Assurance Program requirements Exhibit 2 identifies the Quality Assurance Department (QAD) sections.
The Director-Quality Assurance has no duties or responsibilities unrelated to Qualitymatters.
to quality assurance Assurance that would prevent his full attention the authority and responsibility to:The Director-Quality Assurance has 4.
Develop and administer the maintenance of 'the Operational Quality Assurance Plan and the Quality Assurance Department the required high degree of safety and reliability. proced b.
Audit, inspect and monitor the conduct of GPUN activities to reliability and are carried out consistent with all applica laws, regulations, policies regulatory commitments, licenses, corporate and other requirements, c.
Provide welding, inservice inspection and nondestructive examination program development and maintenance. Perform nondestructive examinations.
L d.
l Identify and report nonconformances as they may exist.
l Initiate, recommend or provide solutions through designated channels.
l~ Verify implementation of resolutions.
) e.
Stop work or further processing, delivery or int.tallation or take other comparable actions when warranted to control and/or prevent the use activities.
nonconforming of nonconforming materials or continuance of f.
Initiate unit shutdown recommendations when warranted by 6 safety concern and obtain unit shutcown with appropriate upper-management concurrence.
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- 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,.
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- h. :
Provide for a review for concurrence of Contractor and Vendor Quality Assurance Programs, j ;
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). 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.
j
- k. Direct and manage the Quality Assurance Department. I i -
- 1. Provide a working interface and line of ccismunication with 1 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 I i
the QA organization is provided. '
i
- o. Immediately n'otify the Office of the President and appropriate Unit Director.of any significant quality related problem or deficiency.
i
- p. Perform assessments on a planned and periodic basis to comprehensively determine the effectiveness of the program and l
' Its tmplementation; and, detect adverse trends as may be present.
I q. Issue periodic reports to the Office of the President and i
Division Directors on the effectiveness of implementation of h activities within the scope of this plan.
- r. Provide for and maintain records generated by QA0 until turnover to the record storage facility (s) for storage.
1.5.2 Minimum Oualifications of Quality Assurance Personnel The Director-Quality Assurance shall have, as a minimum a l l
baccalaureate degree in Engineering or Science, with at least j fifteen (15) years of technical experience including ten years of 1 managerial / supervisory experience in operational, technical support I and/or quality assurance activities associated with nuclear power l plants. At least one year of this experience shall be in a Nuclear l
11.0 3820L (12/88) l
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.J Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Revision No.
Title 1.0 Organization 2 Quality Assurance organization or a special training program ! ;
approved by the Otrector, Quality and Training will be completed '
within'six months of assuming the position. Additionally, the Director-Quality Assurance must be knowledgeable in operating license conditions, other' regulatory requirements and commitments. l plans, procedures and quality and technical standards. i r
Quality Assurance Department Section Managers are required to have a degree in Engineering or Science and experience in a position (s) having responsibil1ty for the supervision and performance of. i operational, technical and/or quality assurance activities. The-degree requirement associated with these management positions may be walved for personnel with demonstrated exceptional' capability and a minimum of. ten (10) years of equivalent experience.
l 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 i
associated with the activities performed by the position. i j
1.6 Director - Maintenance. Construction and Facilities The Director-Maintenance Construction and Facilities reports ,
directly to the Office of the
- resident. The Director's Quality '
Assurance Plan responsibilities consist of establishing, maintaining and implementing 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. I
- 1.7 Corporate Secretary l
The Corporate Secretary reports directly to the Office of the President. The Corporate Secretary's Quality Assurance Plan responsibilities consist of establishing, implementing and {
maintaining document distribution and record retention programs and i facilities, i
l 12.0 3820L.(12/88)
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^ ^ "*r ENuclear E 5 'T5!nitME02PF AND OYSTER CREEK 000-PLN-7200 01 j i
Revision No.
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Title 1.0 Organization 2 i '
l.8 Director - Plannino & Nuclear Safety I The Otrector nlanning & Nuclear Safety reports directly to the Office !
of the President. The 01 rector's Quality Assurance Plan respons- . !
tblittles consist of the maintenance of the of the nuclear plants' i operating licenses and the. establishment and conduct of nuclear I safety. assessment activtties, i .j l.9 Otrector - Radiolocical & Environmental Controls -
. l The Otrettor-Radiological & Environment Controls reports directly to , l the Office of the President. The Ottector's Quality Assurance Plan responsibilities consist of establishing, implementing and main-a talning radiological controls, radiological environmental monitoring, l ,
.and emergency. preparedness plans, practices and procedures sufficient , '
to assure safe and reliable protection of personnel and the general ;
public consistent with Corporate Poltetes and all applicable laws, l regulations and licenses. '
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GPUNC OPERATIONAL QUALITY ASSURANCE Number f#imNuclear us"JEd"nl#'"5'^"""" ' "o200.oi l
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' Title 1.0 Organization 2 l- Exhibit i !
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Office of the President Director Director Director Director Directar 0 stor TMI+1 Radiological & Planning & Ouellty i i
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Director Director Director Corporate Technical Administration Maintenance Secretary Functione Construction l & Facilities 1
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Note: Bold lined bexes .,
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GP Number i Nuclear a'UNC OPERATIONAL
^a roa taats AND OYSTER CREEK QUALITY artE is'^ao uati i ASSURANCE iooo-r'a-72oo oi >
Revision No. 3 .
T1 tie 2.0 QUALITY ASSURANCE PROGRAM 2 )
~
7 2.0 Ovality Assurance Program 2,1 General 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" at used herein includes this ,
Plan and the approved documents which are used to implement this Plan. ' '
This Plan is implemented through such approved documents. ,
i The GPUN Quality Assurance Program has been established to control the !
Activities performed by GPU Nuclear within the scope of this Plan. This j control is exerted primarily through the provision of and compliance l
with implementing documents and assurance that such documents are adequate and consistently used.
l 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 scope of this Plan.
The purpose and intent of this' Plan is to establish the principles l 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 15 recognized that the l 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.
1' The Director - Quality Assurance is authorized and responsible for determining if and to what degree this Plan applies to a given activtty and/or task. In those situations where interpretation of the Plan is L required to provide clarity or resolve disagreements, such interpre-trations shall be documented and approved by the Olrector - Quality Assurance.
,. 2.2 issat 1
The 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 telles on the use of the terms " nuclear safety related," " regulatory required," and "QA Plan Scope."
14.0 3687L (12/88)
y j G Number !
Nuclear 'PUNC '^" roa OPERATIONAL AND OYSTER CREEK QUALITY
'" ate "I't 25'^"o u"2' ' ASSURANCE.
iooo-"-72co.oi ;
Revision No. }
Title 2.0 QUALITY ASSURANCE PROGRAM 2 '
- 2. 2.1 : Items within the scope of this plan are~ designated as "nucidar safety
.related" or " regulatory required." The definitions of these. terms are provided in A.9pendix 0 of this Plan. A Quality Classification process j 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.
l 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 within the scope of this plan are deeignated as within "QA Plan Scope." Activites that are within the scope of this Plan are l those directly related to nuclear and radiological safety and l
protection of the public and are delineated below. - -
Support activities within the scope of this Plan are system / component / ,
part classification, operating experience assessment, design, main- ,
tenance of environmental and fire protection qualification, nuclear ,
j: fuel management, procurement, fabrication, handling, shipping, storage, l cleaning, erecting, installing, testing, repairing, training, welding, l- inservice inspection, heat treatment, document control, and records j management.
1 l Operational activities within the scope of this Plan are normal, I abnormal and emergency operation, chemistry control, core performance l- monitoring, shift technical advice, equipment control, surveillance l testing, inservice testing, maintenance, housekeeping, fire protection, l security, radiological controls, radiological environmental monitoring,
. radwaste preparation for shipment, radwaste shipment, fuel handling /
refueling, technical specification compliance, and emergency preparedness.
Assurance activities within the scope of this Plan are audit, document review, nondestructive examination, inspection, monitoring, surveillance, and safety review, 15.0 3687L ('2/85)
4 GPUNC OPERATIONAL' @ALITY ASSURANCE Number .. .
Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 i
Revision No.
. Title '2.0 @ALITY ASSURANCE PROGRAM 2 s
)
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 l the extent listed and committed to in Appendix C of this Plan, the < ;
Final Safety Analysis Report, and other regulatory requirements and l l commitments. Those approved documents which specifically prescribe the t i methods to implement this Plan will be identified as prescribed by l 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 or not depending.upon: ;
- 4. Statements within the text and the regulatory guides identified in Appendix C of this Plan: ,
- b. The relationship of the task (s) to 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 tash(s) to protection of the health and safety of the public; i
- e. The relationship of the task (s) to regulatory requirements and i 3 commitments, and; ! '!--
I
- f. Other factors as may be specified by GPUN management. !
l 2.3 Graded Approach The extent'to which the requirements of this Plan and its implementing l documents are applied to an item will be based upon the following: i 4 4. The effect of a malfunction or failure of the item on esclear safety or safe plant operation.
- b. The design and fabrication complexity or uniqueness of the item.
- c. The need for special controls, and surveillance or monitoring of processes, equipment and operational activities.
- d. The degree to which functionality can be demonstrated by inspection l or test. m
- e. The quality history and degree of standardization of the item.
I 16.0 3687L (12/88) v e -
\
I GPONC OPERATIONAL QUALITY ASSURANCE humber . 4
':. Gru Nuolear 4'Aa AND m OYSTCR taRtcCREEC artt tsu e uait i iO*-PtN-nx.0i
~
i Revision No.
Title. 2.0 QUALITY ASSURANCE PROGRAM 2 l i
the quality requirements for items within the scope of this plan shall I
[ be established using approved procedures based on the " General Logic j Considerations" listed in the Appendin to ANSI #45.2.13-1976. Quality !
requirements will be estabitshed by the respo.$1ble department and ,
, reviewed by the Quellty Assurance Department consistent with Appendix 8 l i of this Fl&n. ;
J The entent to which the requirements of this plan apply to activities l will be based as a stnlmum on operating Itcense conditions and other !
plans previously submitted to the N4C for approval. Other regulatory l g
comhitments as may have been made associated with activities, the text ;
of this Plan, the unit's technical specifications, and Appendia C of I this Plan. Such other plans or regulatory comettaents include but are l
not limited to those associated with emergency planning, physical plant j security, safeguard contingency planning, radiological controls, i radiological environmental controls, fire protection, intervice inspection, inservice testing, licensed operator quellfication and i' recualification, process control, offsite dose calculation, shift technical advisor training, environmental qualification of electrical equipment, security guard tr41ning and qualification, etc.
2.4 Three level ADDreach GPUN is committed to a comprehensive assurance process consisting of a three level approach to assure satisfactory, consistent and complete implementation of this Plan. .l L
2.4.1 Level 2 ' Activities at this level include inspections, checks, or i i tests performed for the purpose of establishing acceptance and/or verification of itses, parts, materials and activities within the scope I ?
of this Plan. Leve' i activities are performed by the Quality '
Assurance Operations, Plant Maintenance, Radiological Controls, ;
Maintenance, Construction and Fact 11 ties, Technical Functions, and I contractor personnel. Where the first-level activities involve l independent inspection for purposes of acceptance and/or vertftcation, -
the activity will be performed by the QA Department or by organizations authorized to perform those activities by the OA Department.
t Operations, Plant Maintenance, Maintenance, Construction and !
Facilities, Radiological Controls, and Startup and Test personnel l !
g perform activities such as tests, calibration of instruments, radiation surveys, analyses of samples, valve line-ups, etc. ;
Maintenance, Construction and Facilities; and, Plant Matt.tenance/
Material personnel perform checks, inspections and/or tests of l
modification, replacement, repair and/or overhaul activities.
Outlity Control personnel perform receipt inspection and checa,s and inspections of modifications and maintenance activities.
Contractors perform inspections as applicable to their scope of
~
work.
17.0 3687L (12/88)
]
GPUNC OPttAi!ONAL QUALITY AS$UltANCE Nuolear LA= roa taatt ai Number
- ND OYSita Cattr. 't istrao uari iiooo-P'a-72oo.oi A
o '
iltle Revision No. -
2.0 QUALITY ASSUllANCc PROGilAN 2 Teckitcal Functions personnel periodically perform walkdowns, '
observations, mea $urements, etc. to revalidate the physical or funct.ional ccaflguration or condition of plant systems or compenents. l In al' cases, the inspection, check and testing activities are .
performed by individuals who are knowledgeable of the activity being !
performed and are qualtfled to perform the work (refer to SecttNi 6.2). Checklists, weld history records, travelers, reports, etc., are 1 l
used for documenting the results of the activity and for providing a record of the performance of the activity.
2.4.2 I t.evel II - The activities at this level are primarily those of survey, !
surveillance, monitoring, tad document review and are performed as l
( deemed necessary by the QA Modifications / Operations or QA Design and L
' Procurement Sections. The level of survelliance 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 4 i
activities where GPUN Quality Control is perforetrg first-level inspection, no second-level activity is required. )
At this level, procedures and instructions are estabitshed and I surveillance and/or monitoring records will be completed and l maintained. Such surveillance / monitoring normally includes observation l of tests and inspections, observation of selected operations, review of '
i records, verifications of test reports, and direct inspection on a l Spot-check basis. The organizations performing this activity have the !
levels of authority, the lines of internal and external communication for anagement direction, and properly trained personnel for i implementation of these activities. ,
i 3.4.3 Level !!! - The purpose of this level of activity is to assure, through a comprenensive program of review and audit, that the first and secor.d ;
levels of the program are properly functioning, and that all organiza-tions conducting activities and/or tasks within the scope of this plan ,
are properly satisf Assurance Program. ying all the requirements of the Operattoi.a) Quality '
At this level, procedures and instructions are established, including l l
the use of cowprehensive checklists or detailed repor+s for documenta-tion of the audit or third-level activity. The progrui requirements of L ,
ANSI N45.2.12 shall be satisfied. Lead auditors shall be uttitred who '
are Qualified to the requirarments of ANSI N45.2.23. Additional !
I technical support personnel, from areas with administrative reporting outside the function that is being audited, will be utillzed 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 necessa'ry access to management to con 0Utt the review and audit, resolve any issues which )
may arise from the review and audit and secure additional technical support for tne performance of audits as may be required. l 18.0 3967L (12/88)
_.__.__...___.__.________.i.
GPUNC OP(RATIONAL QUALITY ASSURANCC Number Nuolear P'** Foa taatc ai't is'^ao uatt i AND OYSTER CREEK iooo-P'a-troo ol
[. Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 2 2.5 Operational Quality assurance Plan Control This Plan is av'thorized 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 i 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 Appendir 8: 10CFR71, Subpart H; ANSI N45.2: and .
AN$1 N18.7. t
, , With the exception of Organization. Section 1.0 and QA Program. !
Section 2.0, each se; tion of this Plan contains three major subsections:
General - A summary description of the general approach of GPUN with !
regard to controlling the specific subject (O of the section. It r character 1rgs the intent of the section by stating the overall ;
objectives to be met and/or. the results to be achieved.
Recutrements - A description of the requirements appitcable 'to the f specific subject of the section. ;
Responsibilities - Identification of those organizations and their responsibilities relative to the specific subject of the section.
2.5.1 Approval l
This Plan shall be originated by the Director-QA and be approved by the i I Office of the President af ter being reviewed for concurrence by the .
following Director - OCNGS '
Director - TMI Unit 1 Olrector - Technical Functions Director - Administration '
Director - Quality and Training i i Director - Maintenance, Construction and Factiltles !
Director Planning and Nuclear Safety I -
Director - Radiological and Environmental Controls Corporate Secretary Services Manager ,
2.5.2 Revisions l The Director - Quality Assurance, with the assistance of the Licensing l and Regulatory Affairs Director, shall, for each revision t0 this Quality Assurance Plan, determine if the changes reduce or do not reduce the commitments in this plan previously accepted by the NRC. l 19.0 3687L (12/88)
, - , , - -._,mc -
--...-m---- ,.-.--.,w-.,. ,-m. -.. --, , _ - - - . . _ , - - - _ - - - - , - . ,
i Nuolear GPUNC OPERAir0NAL QUALITY ASSURANCE pun ra taEE Niu isua unit i AND OY$T(R CR([K Number 10*-PtN-n*.m i
l Title Revision No.
2.0 QUALITY ASSURANCE PROGRAM 2 Revisions to this Quality Assurance Plan that do not reduce the commit-ments in this Quality Assurance Plan previously accepted by the NRC l shall be originated by the Director Quality Assurance and approved by the Office of the President with the concurrence of the Director - j Quality and Training and any Olvision Director effected. The Cover i Page containing the approval anc concurrence stonatures of the Office '
of the President and the 01vis10n Directors sha'I be retained. !
Revisions of this type do not require approval by the NRC prior to l
implementation, but must be submitted to the NRC at least annually. r The Document History page will be utilized to identify such changes.
l Revisions of this Quality Assurance Plan that reduce the commitments in this Quality Assurance Plan previously accepted by the NiiC shall be ,
submitted to the NRC and receive NRC approval prior to implementation. (
i 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 i 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, the reason for 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 I provide the basis for changes that correct spelling, punctuation, or !
editorial items. A r.opy of this letter must be maintained as a facility record for three years. Revisions of this type shall be )i ;
originated by the Director - Quality Assurance, approved by the Office l '
of the President with the concurrence of the Olvision Directors as '
indicated by their signatures on a revised Cover Page.
2.5.3 Estribution 1
Copies of the Operational Quality Assurance Plan may be distributed as
- Controlled" or " Uncontrolled" in accordance with the requirements established in Section 3. l 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 interim action plan is defined and approved by the Director - Quality Assurance.
2.6 Quality Assurance Procram Review The effectiveness of the QA Program and its implementation is period-itally reviewed by verlous organtrations at various levels and the t
results of these reviews are documented in reports to the Olvision t
Directors and the Office of the President for evaluation and correctivt action as required. The effectiveness of the QA Program is evaluated and reported by the QA Department through the surveillance, monitoring and auditing functions. Other civisions provide additional information/
evaluations are requested.
{
20.0 I 3687L (12/88)
l GPUNC OPERAT!0NAL QUAL!TY ASSURANCE Number.
U Nuolear PLAN roR tNRct Nitt iStAND unit i AND OYSTER CR((K iooo-PtN-72oo.oi Revision No.
Title 2.o QUALITY ASSURANCE PROGRAM 2 In addition to the reviews and evaluation performed by the QA Depart- ;
ment, the Office of the President shall have, at least once per year, ,i en independent assessment performed of the QA Program implementation to '
ensure that the QA Program is effective in ensuring that regulatory requirements and commitments; and, GPUN pollctes are met. This assessment may be performed utillaing 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 forinally identified and tracked through resolution.
l 2.7 Indoctrination and Trainine Formal indoctrinetton and training programs for personnel performing or i verifying activities within the scope of this Plan are required to be l established and maintained. A Training department is established and '
staffed and is responsible for plannin !
providing training to GPUN personnel. g,The scheduling, developing indoctrination and and training ,
programs are established by on-stte and by off-site organizational units responsible for the' performance or vertftcation of activities within the scope of this Plan. These training programs are developed, !
1mplemented and maintained as dtlineated in Section 9.0 of this Plan. I t
The prof tclency of personnel shall be evaluated; and, measures to (
maintain proficiency shall be implemented through either retraining. ;
reenamining and/or recertifying. i i
When certification is required a certificate (s) shall delineate the ;
specific function (s) the individual is certified 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 Subsection 2.2.2 of this Plan. Subsection 2.3 :
provides further bests for grading the extent of application of the !
requirements of this Plan to activities. Documents that prescribe methods for Inglementing the requirements of this Plan shall be marked ;
as epecified by 3.2.2.2.b of this Plan.
- Items within 1he 3 cope of this Plan shall be classified and identified as " Nuclear Shfety Related" or " Regulatory Required." A procedure (s) ;
shall be preptred to establish, implement and mdtntain a classification t process for items. This procedure (s) and changes thereto shall be reviewed for concur ence by the Director - Quality Assurance prior to issuance. ,
i 21.0 3687L 112/BB) ,
. ___ ___ _ . _ _ . _ _ _ _ _ _ _ _ ___u.__-----------
G Number !
Nuolear *PUNCLaa m m AND OYSTER CREEK OPERATIONAL Et artE iS u e ua QUALITY Ti ASSURANCE iO*-Pta-7:oo.oi i l
Revision No.
Title 2.0 QUALITY AS$URANCE PROGRAM 2 i
Structures, systems and components, but not parts thereof, shall be j identifled on a Qua11ty Classification List (OCL). A QCL shall be '
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 l process.
l 1 Spare or replacement parts and materials are not necessarily classified l the same as the component of which they are a part. Such parts and l materials that perform or contribute to the performance of a nuclear safety-related or regulatory reoutred function are within the scope of l this Plan and classified similarly as the component of which it is a ,
i part. For procurement of spare or replacement parts which are of a i different classification, the classification will be determined by ;
Plant Engineering or Technical Functions. The determinations util be ;
documented, reviewed by Quality Assurance consistent with Appendix 8 of -
this Plan, and retained. Refer to Section 5.0 for specific requirements. I 2.9 Rigylatory Commitments j Records of regulatory requirements and commitments are maintained by l l Licensing and Regulatory Affairs. Appendix C herein Itsts those l .
Regulatory Guides wnich contain specific quality assurance requirements ;
with the stated GPUN position, exceptions and/or clartftcations e 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 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 .
I a cualifted Responsible Technical Reviewer on documents end substantive -
revishms of documents as specified by the GPUN Review and Approval Matria. ;
The independent safety review is an independent review of documents and . ,
i substantive revisions of documents as specified by the GPUN Review and l l Approval Matrix. It includes a review of a safety evaluation. This 6 l
review 15 conducted by a outlif ted Independent Safety Reviewer (ISR) on i safety evaluations associated with documents and substantive revisions I
to documents as specified by the GPUN Review and Approva~1 Matrix. The
! ISR snall not have direct resg>nsibility for the activity reviewed.
3687L (12/88)
' G Number Nuolear 'PUNC
'Aa m OPERATIONAL fact aitt 25'^a att 4ND OYSTER CREEK QUALITY i ASSURANCE-i *o- *'" m
- o '
Revision No.
Title 2.0 QUALITY ASSURANCE PROGRAM 2 2.10.2 The second element of the safety review program is the Independent I on-Site Safety Review Group (10SRG). An 10SRG shall be located at l each ponerating station. The IOSRG has no line responsibilities or i 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 Director. Each 10SRG will consist of a Manager, j 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 expertence in the nuclear power field including technical supporting functions or 8 years of appropriate experience.
Credit toward esperience will be given for advanced degrees on a ,
one-to-one basis up to a maximum of two years.
j Each 10$RG shall have access to the unit and unit records as necessary to perform its evaluettons and assessments. Based on its reviews, the ,
i 10SRG shall provide recommendations to the management positions !
responsible for the areas reviewed. 10$RG reports of evaluations and !
assessments shall be prepared, approved, and transmitted to the Nuclear !
Safety Assessment Director, Director - Planning and Nuclear Safety. l and the management polttions responsible for the areas reviewed. -
1 2.10.3 The third element of the safety review program is the review by'the l Nuclear Safety Assessment Department (NSAD). :
l t
NSAD is an independent organization reporting to the Director - - '
Planning and Nuclear Safety. !
In addition to overseeing the IOSRG, the Nuclear Safety Assessment l Department, through itt, headquarters staff, will assess all aspects of GPUN activities as well as developments elsewhere in the nuclear industry. It shall prcvide the following safety review functions: I
- 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 sefety review progfam and identify areas for i mprovement. . ,
- 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 Ombudsman will reply to the Individual who raised the matter.
- c. Staff support to the General Office Review Board.
W 23.0 3687L (12/88) k
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l
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Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN r0R TNREE attE iStANo unit i AND OYSTER CREEK iOOO-PtN-7200. 0i l
i Title 2.0 QUALITY ,55URANCE PROGRAM Revision No. !
2 l
2.10.4 !
The fourth Review element of the safety review program is the General Office Board, I 'I backgrounds. This is a group of senior level Individuals with diverse !
It reports to and takes general direction free the Office !
of the President but has direct access to the Chief Executive Officer and the Board of Directors. Its charter is broadly defined to encom- :
pass all matters potentially affecting nuclear safety so as to foresee potentially significant nuclear safety and radiation problems. i 2.11 Responsibilities f 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 10CFR50. Appendix 8, 10CFR20, and 10CFR71, Subpart H.
This assessment shall be the combined result of: '
- a. Review of audit reports, periodic status reports, etc. on the effectiveness and implementation of the Quality Assurance Program. i
- b. Performance at least once a year of an independent assessment of i
the effectiveness of the Quality Assurance Program to assure that this program ensures compliance with regulator :
connitments and GPUN policies and directives. y This requirements assessmentand may l be performed utilizing the safety review groups, an independent consultant, representatives from other utilities and/or the i 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 & Traintne i
The Director-Quality & Training has overall responsibility for estab-
' lishment of the GPUN Operational Quality Assurance Plan. The Director through the Director-Quality Assurance shall provide periodic status reports to the Office of the President on the effectiveness and imple-mentation of the Quality Assurance Program. ,
2.11.3 Director - Quality Assurance The Director-Quality Assurance has the authority and direct respons-ibility to verify the effective implementation of this Quality Assurance Program.
This responsibility is principally discharged l through the review of documents which implement this Plan, the
' verification that such documents are effectively and consistently '
implemented and providing the regullite leadership to assure that required corrective action is promptly defined and implemented.
1 3687L (12/88) 1
)
i l
l
1 l
, G Number j Nuolear 'PUNC
'*" roa taart OPERATIONAL QUALITY ar't is'^'~) uart i ASSURANCE iooo-"-'2co.oi AND OYSTER CREEC l' Revisten No.
Title 2.0' QUALITY ASSURANCE PROGRAM 2 The Director-Quality Assurance shall establish and implement a formally .
documented and procedurally controlled process to evaluate and report on the adequacy and continued effectiveness of this Plan and its imple- l mentation, The basis for this evaluetton report (s) includes reports of audits performed by Quality Assurance; QA monitoring of station activ-ities; evaluations of suppliers, source surveillance of equipment suppliers; audits of external service organlaations; and quality trena i analyses based on nonconfermance and deficiency reports and reports of !
Inspections, examinations, surveillance / monitoring and audits. These )
actions may involve specific actions to provide compilance with this l Plan and may include follow-up audits and revision to the Quality I I Assurance Program. 1 Implementation and closeout of corrective actions shall t,e effectively )
followed up by the Director Quality Assurance to assure timely correc. l tion and compliance.
The Director-Quality Assurance is responsible for the contents of this ;
Plan and for ensuring that this Plan 15 modified and updated as stand-l ards, regulations, recutrements, and experience dictate. Proposed ,
revisions to this Plan may be suggested by GPUN personnel by submitting the request, in writing, to the Director-Quality Assurance for review ,
and action. l 2.11.4 Director Technical Functions l The Director-Technical Functions is responsible for development and l maintenance of the Quality Classification List. l ;
2.11.5 Director - Plannine and Nuclear Safety The Director-Planning and Nuclear Safety through Licensing and Regu-latory Affairs is responsible for providing GPUN documented positions ,
and interpretations on all other regulatory guides not contained in ,
Appendix C of this Plan as may be required. ;
i 2.11.6 GPUN - Management
- Management personnel in each division are responsible for the implemen- l tation of the Ouality Assurance Program 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 within their division, department or group. Thisincludestheidentificationandqualtftcationl of personnel as Responsible Technical Reviewers and Independent Tafety Reviewers; the review and approval of documents within their functional area of responsiblitty as assigned by tne GPUN Review and Approval Matrix and other activity as may be required to implement Technical Specifications Appendia A. Section 6.5 reautrements.
25.0 3687L (12/88) 1
, _ , . - - , , _ --mr ..__,, s., , _ _ . . , , , . . . . . - - ,_,,-._,.s._ _
_ , , , - , _ , _ , , , . _ , - . _ . . _ , , , - , . _ . _ _ _ . , , . , ._m . - r__m .
GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear Ptra r0R raaEE ai'E iSt**o uatT i AND OYSTER CREEK 20oo-Pta-72co.oi Revision No.
Title 2.o QUALITY ASSURANCE PROGRA* 2 Management personnel in each division are responsible to take positive i
, action to evaluate and correct nonconformances identified in the ;
conduct of those of their activities within the scope of this Plan. t This responsibility to correct includes adverse trends as may be 1 identified by appropriate analysis.
2.11.7 External Oreanizations Suppliers who provide items, parts, materials, consummables, and/or services which are within the scope of this Plan shall have a QA Plan l and implementing procedures appropriate for the items, parts.
materials, consummables, and/or services. The suppiter's QA program shall be subject to review for concurrence by the Director-Quality Assurance or his designee. The extent to which the supplier's QA i program will be applied will be specified by procurement documents.
l 2.11.8 Resolution of Ottoutes 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 l such disputes occur. If this is not possible, the difference of opinion shall be escalated through supervisory / management levels until resolution is achieved. j The Otractor-Quality Assurance shall make the decision on matters related to if and to what oegree this Plan applies to activities, quality requirements, and vertftcation and acceptance to established requirements, The Director-Technical Functions shall make the decision on matters related to classification of items, parts, materials, and technical l l
l requirements or design changes.
The Director-Quality Assurance shall be responsible for evaluating deftetencies for trends. Significant or repetitive failurts to comply i with administrative, technical, operational or this Plan's ,
requirements wlll be further evaluated to determine the safety 4 significance of the condition. In these cases, management of the i
organization shall be notified of the condition anc shall be afforded r i an opportunity to take appropriate corrective action. If this action is not taken, 4 Stop Work Notification will be l$ sued.
i 1
4 26.0
- - 3637L (12/66)
'GPUNC OPERATIONAL QUALITY ASSURANCE r#imNuolear gaJNasMI't 25'^"o van i Number m 'a-72
- o' '
T1tle Revision No.
3.0 CONTROL OF DOCUMENTS AND RECORDS 2 j 3.0 CONTROL OF MalENTS AND RECC805 3.1 Plans. Procedures. Instructions. Drawinas. Specifications j
3.1.1 General
{
Activities which are within the scope of this Plan shall be pre- I scribed by approved documents of a type appropriate to the circum. }
t ,
stances. These documents shall be complied with in the performance i i of the activity or changed prior to proceeding with the activity.
These documents typical' y include but are not llatted to those termed plans, procedures, instructions, directives, drawings and specifications. ! t All personnel shall be indoctrinated in the use or i j
content of such documents prior to commencement of the activity.
l 3.1.2 Resutrements I
Documents which prescribe the methods for the performance of activ- !
itles and/or tasks within the scope of this Plan shall be consistent with the requirements of this Plan. These Plan requirements include ;
compilance with the text of this Plan and the Regulatory Guides and ANSI stan64rds to the extent delineated in Appendix C. To accomplish i this, these documents shall: !
- a. Define the responstb111ttes and authorttles of personnel I performing the activity.
4
- b. Des'cribe interfaces between GPUN organtrational units and/or l
external organizations that participate in or are effected by the conduct of the activity. !
i
- c. t Prescribe actions to be taken or the reruits to be achieved '
which are consistent with tie requirements of this Plan.
I
- d. Include quantitative (such as dimensions, tolerances. And operating limits) and/or qualitative (such as workmanship) i acceptance criteria sufficient for deteretning that such activtties have been sattsfactorily accomplished. ,
- e. Identify and spectfy the content of records to be generated la i conducting the activity. ,
f.
Include references as needed to implement the activtty. When such references are ut11tred, the specific requirements of the references which are applicable shall be Identified or incorporated into the document.
27.0 3814L (12/88)
___-_-___-_.__________._._______4.__.-._._._...-.,4 ..-_.__._.-__.,.-.,-_,-___,m___m_,,.mm..,-.. m,....,-_,, ~ . _ , , , _ _ . . .
l t
GP Number Nuclear r'UNC Aa r0ROPERATIONAL AND OYSTER CREEK TaREE at't iS u a uarT QUALITY i ASSURANCE i *o-Ptaa2 *.oi Revision No. l Title 3.0 CONTROL'0F DOCUMENTS AND RECORDS 2 {
t
- g. Se approved and concurred with by responsible personnel prior to '
, the initiation of the activity. !
- h. Se distributed in a controlled manner to preclude the use of f' obsolete documents and with sufficient number of copies to assure availability to responsible personnel.
Reviews of such documents shall be conducted by the Quality Assurance Department (QAD). The timing and scope of QA document reviews shall i be as detailed in Appendia 8. These QAD reviews are conducted to independently verify that the document is appropriate for use. These i QAD reviews assure, as a minimum, that the reviewed document is l
Consistent with the pertinent QA Plan requirements; contain intpection t and verification reavirements where appilcable; contain quantitative l 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 l l consistent with QA Plan requirements * '
Documents which prescribe methods for implementing this Plan shall be i followed as written or changed. The requirements for use of such i documents and how to proceed if such documents cannot be complied with ;
as written shall be prescribed by procedure (s). ;
Plans, procedures, and instructions shall be revised as needed to i ensure that such documents can be implemented as written. Appropriate documents shall be thoroughly reviewed following plant transients, i incidents, and/or events and revised as needed. Such documents shall I i be reviewed by an individual knowledgeable in the area affacted by the document (s) no less frequently than every two years to determine if changes are necessary or desirable. A revislon of the document (s) mayl constitute the above review provided the results of the review are ,
documented.
l 3.1.3 Responsiblittles !
3.1.3.1 Department Mananers i The Director or Manager of each department performing activities within the scope of this Plan is responsible for the preparation, I i
approvai 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 internal and esternal lines of ccwenunications ~
among participating organizations and technical disciplines.
i l
I 28.o l 3814L (12/88) l 1
l
)
GPUNC OPERAt!ONAL QUALITY ASSURANCE Number y '
Nuolear PtAN r0R t m E Mite iStANo unit i AND OYSTER CREEK iO*-PLNa2*.Di Revision No.
11 tie 3.0 CONTROL OF DOCUMENTS AND RECORDS 2 ,
3.1.3.2 Quality Assurance DeDartment (QAD)
QAD shall review those approved documents which prescribe the methods l of complying with the requirements of this Plan. When specified in '
procurement documents supplier Quality Assurance Plans / Manuals, special I process procedures, and inspection and test procedures shall be l reviewed for concurrence by QA0 prior to authorizing the supplier to start work. :
3.1.3.3 Enternal Oreantrations Those activities within the scope of this Plan which are performed by l' an esternal organ 124 tion (s) shall be prescribed by approved docu-ments(s). The extent and type of such approved documents to be utilized by the external organization shall be prescribed within approved procurament documents. Compilance shall be verified through the audit, source surveillance, source inspection, monitoring and !
inspection programs. !
3.2 Document Control j 3.2.1 General Document control procedures shall be established to control and I coordinate the classification, review, approval, issuance, revision, '
and change of approved documents which prescribe methods or provide the technical and/or eval 1<:y requirements for activities 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 Reovirements i
3.2.2.1 Written document control procedures shall be established to provide for the control of the folloring types of approved documents: l :
- a. Operational Quality Assurance Plan, GPUN Organization Plan, GPUN Review and Approvat Matrix, Quality Classification List Environ- ;
mental Qualification Master List (s), and Supp11er Quality '
Classification List (s).
D. Plans, procedures, directives, and/or instructions as required to implement the provisions of this Plan and the Regulatory Guides -
to the extent delineated in Appendix C. ;
- c. Quality Assurance Department Plans, Procedures, and Standards.
29.0 3814L (12/88)
I i
_._.._.-__,,-,-.__...~,..._..____..__,__,,_..,$,
Nuolear GPUNC OPERATIONAL QUAL 8TY ASSURANCE PLAN r0R TNREE NITE ISt*ND uali i AND OYSTER CREEK Number i0oo-PtN-720o.oi l
l Title Revision No. .., j 3.0 CONTROL OF DOCUMENTS AND RECORDS 2 ;
- d. Operating, Surveillance Testing Refueling and Equipment Control Procedures and Instructions. ;
i e.
MaintenanceWorkAuthorizin!forantionDocuments, Vendor Manuals and vendor ! .
Procedurs3, Instructions, t I
f.
' Engineering Configuration Control documents which include safety .
analysis, safety evaluations, calculations, standards, t specifications, system / modification design descriptions, design ;
reviews and/or verifications, drawings and ilsts.
i
- g. Computer codes utilized for calculational tasks associated with activities within the scope of this Plan, i
)
- h. Engineering, Manufacturing, Construction, Modification,
- I Installation, Nelding, Test, Inspection and Nondestructive ! i Examination Procedures, Instructions, Standards, and j '
Specifications. ' '
- 1. Procurement Documents, Specifications, and Contracts.
- j. Final Safety Analysis Report (s), Fire Protection Plan (s). Fire }
I Hazards Analysis Report (s), Emergency Plan (s), Security Plan (s), :
Safeguard Contingency Plan (s), Guard Force Training and Qualification Plan (s) and Offsite Dose Calculation Manual (s). ,
- k. Nonconformance, Deficiency and Deviation Reports or Requests. . -
l
- l. Operating and Special Orders. I i i m.
Procurement and Material Control Procedures and Instructions. !
- n. Radiological Control, Process Control Radiological '
Environmental Monitoring Radweste Shipping and Cheelstry Control Plans, Procedures, Instructions, Standards, and Specifications.
3.2.2.2 Procedures established for document control shall pnescribe the '
following requirements: i
( '
- 4. Drawings, design descriptions and specifications for items, i parts, and materials designated as Nuclear Safety Related shall I be marked as such.
- b. Documents which prescribe how to perform activities within the i scope of this Plan shall be marked as within "QA Plan Scope". I These documents typically will be those termed plans, l procedures, instructions, and directives. Specifications and i drawings will be marked as stated in 3.2.2.2.a above.
3o.o 3814L (12/88) l
1 1
h
%gglgg7 GPUNC OPERATIONAL QUALITY ASSURANCE PLAN FM THREE MILE ISLW WIT I Number I AND OYSTER CREEK 1%0JLN42%.01 Title 3.0 CONTROL Of DOCUMENTS AND RECORDS Revision No. ,
2
)
[
' c.
Review and approval requirements for documents and their '
revisions shall be specified to ensure that adequate technical and quality requirements are incorporated prior to issue, f ,
Issuance requirements shall be 'specified to ensure adequate i dissemination for use. i i
d.
The orgahlzations or positions responsible for reviewing, approving and issuing documents and their revision shall be f specified, i i
e.
Revisions being shall be documented, apprcved, and issued prior to implemented.
Temporary changes shall be reviewed and )
(,
approved consistent with Technical Specification requirements, l i
p
- f. l r Revisions and changes shall be reviewed and approved by the !
same organizations that performed the original revtem and approval or by organizations designated by the originating ,
organizations except for documents originated by organtrations ,
outside GPUN. In this case, GPUN may designate the review and i approval organizations.
Approved changes shall be promptly transmitted for incorporation into documents and obsolete or i Superceded documents shall be eliminated from use. .
9 Document distribution shall be sufficient to assure that the l documents are readily available to responsible personnel prior to commencement of work, i i
h.
The user of approved documents is responsible for assuring that !
the latest issue of the document is being used to perform work, i thus assuring that voided, superseded or obsolete documents are not used. Master lists or indices which identify current i 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 controlled '
documents or master lists are responsible for maintaining their assigned copies in a current status. Documents distributed and stamped as information only will not be considered to be :
current, and, as such, will not be used in performing an activity within the scope of this plan.
g i t.
In the special case of documents containing information pertaining to plant security, provisions shall be made to prohibit unauthorized disclosure of certain safeguards information. These provisions shall include identtftcation of the documents, restrictions on their distribution and storage in locked security storage containers.
31.0 3814L (12/88)
r i
G Number !
Nuolear 'Puhc OPERATIONAL
'^a roR m tc ar't is'*
- uait AND OYSTER CREEK QUALITY 1 ASSURANCE 1*o-x 72eo.o' i
Reviston No. [
Title 3.0 CONTROL Of DOCUMENTS AND RECORDS 2 l
t 3.2.3 Responsibilities t I
3.2.3.1 Cornorate Secretary !
Responsible via the Information Management Center Managers to [
establish and mainteln approved documents to implement the GPUN Document Control Program. , f 3.2.3.2 Director administration ;
Responsible to develop and administer a corporate policies and .
procedures system. ;
1
- 3. 2. 3. 3 Director - Quality & Trainino i Responsible via the Director-Ouality Assurance for the review of GPUN document control procedures and the evaluation of the overall document control system effectiveness through document review and l audit.
3.2.3.4 All Functional Mananers Responsible to provide specific document control procedures, as l !
required, to implement 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. 1 3.3 Records !
3.3.1 General Records related to items, parts, materials and activities within the scope of this plan shal? be identified, reviewed, retained, and retrievable. These requirements are imposed on all organizations performing activities within the scope of this plan. Records shall l be described and controlled by approved written procedures or instructions. As a sinimum, these procedures or instructions shall prescribe the method (s) for the identification, generation, ,
collection, storage, maintenance, retention, and retrieval of such records _ i 32.0 3814L (12/88)
^
e
' }
1 GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuolear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01
{
{
l Revision No. l Title 3.0 CONTROL OF DOCUMENTS.AND REC 0kDS 2 l i
I
- 3.3.2 Reevi rement s Approved documents shall be established for the identification, ! ,
generation, collection, storage, maintenance, retention and retrieval , !
of records and shall provide for the following alnimum requirements: I i
- a. Dtsign specifications, procurement documents, and/or GPUN proce-dures shall specify the records to be generated, supplied and i maintained by or for GPUN, including retention times. Typical i records to be specified include operating logs, maintenance and i modification procedures and related inspection results, !
reportable occurrences, inspection and verification procedures (excludirg 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 documentation such as calculations, computer '
codet , design verifications, drawings, specifications, procure- i ment documents, calibration procedures and reports; nonconform-ance r00erts; corrective action reports; and other records required by Tet,hnical Specifications. l i
- b. Sufficient records hnd documentation shall be maintained to i provide evidence of the acceptability of items, parts, materials l or activities within the scope of this plan. Inspection and test receras shall contain the following where applicable:
- 1. Identification of the type of observation, i
, 2. The date and results of the inspection or test.
- 3. Identification of any conditions adverse to quality. ;
4 !
. Inspector or data recorder identification.
i
- 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 utilized to prevent' destruction of quality records by fire, flooding, theft and deterioration by environmental conditions such 45 temperature or humidtty in compliance wtth the stardards, codes :
and regulatory guides endorsed in Appendir C of this Plan. ,
- d. All records shall be legible in original or reproduted form. l 33 0 3814L (12/88)
GPUNC OPERATIONAL QUALITY ASSURANCE Nuolear 'ND OYSTER CREEKua roR tNut A
Num.be r i*o-P'a-n at's tsua
- oiuart i i
Revision No. !
ittie 3.0 CONTROL OF DOCUMENTS AND RECORDS 2 t
3.3.3 R.tiransibi l.i tie s 3.3.3.1 Director - Quailty S Trainino The Director-Quality & Training is responsible through the Otrector -
Quality Assurance, for:
- a. Reviewing procedures related to the identification, generation, collection, retention, storage, retrieval, and maintenance of i records. '
f
- b. Establishing procedures and/or instructions for the Identification, generation, collection, retention, storage, t
retrieval, and maintenance of records generated by QAD, until '
they are turned over for storage. .
t
- c. Performing planr.ed and periodic audits to verify the adequacy I
! and implementation of records requirements by both GPUN !
internal organizations and suppiters of services, i I
- d. Performing source surveillance source inspection, or receipt l
(, l inspection to verify that requfred records have been generated - ;
i and supplied with items, parts or materials. I l 3.3.3.2 GPUN Division Otrettors Each Division Director is responsible for:
- 4. The identification, generation, collection, maintenance, and l storage of records in accordance with approved written procedures or instructions which conform to the requirements of i
, this section until such time as they are transferred to the 1 applicable Information Management Center for storage. I '
- b. Providing direction in approved documents to ensure the identi-I fication generation and maintenance of records with sufficient i I dotati to furnish objective evidence that activities within the !
L scope of this Plan were conducted in compliance with this Plan and the standards, codes and regulatory guides endorsed by this plan.
1 i- 3.3.3.3 Corporate Secretary 1
The Corporate Secretary is responsible through the Information l
Management Center Managers for:
l a. The cellection, maintenance, and storage of records in accord-l ante with approved written procedures and instruc'tions which conform to the requirements of this section.
34.0 3814L (12/88)
~
GP Number Nuclear a'UNC
- ** r0a OPERATIONAL twatt aitt iS'**D uait QUAllTY i AS$URANCE t ooo-a'N-T2co.oi AND OYSTER CREEK _
Revision No.
4,.
Title 3.0 CONTROL OF DOCUMENTS AND RECORDS 2
- b. Provicing procedures and/or instructions which stisure the l maintenance, storage an$ retrievability of records.
- c. Estabitshing and implementing the GPUN Records Control System.
3.3.3.4 External Oreanizations 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. Purcliased equipment records shall be retained by the supplier until the equipment is released for shipment '
at which time the records required by procurement documents are to be submitted t0 GPUN.
When required by the procurement documents, suppliers shall establish procedures for the identification, generation, collection, storage, maintenance, retrielval and/or transmittel of records. Implementa-tion of these procedures shall be assured by performance of source surveillance, source inspection, monitoring and audits performed by QAD.
Records to be submitted with the shipment or retained by the supplier I 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 in the adequacy of compliance of the suppiter with the reQut,rements of this [
section.
35.0 3814L (12/88)
4 l
Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE etAa roa taaEE artt isLAao uart i AND OYSTER CREEK Nu;ber icoo-eta-72eo.oi f
Title 4.0 Design Control Revision No. l 2 i q
4.0 DESIGN CONTROL 4.1 General
)
l Measures shall te established and documented to assure that the !
applicable speelfted design requirements, such 45 design bases, regulatory requirements, codes and standards are correctly ;
translated into specifications, drawings, procedures or instructions. These measures shall include provisions to assure !
i that appropriate Quality standards are specified and included or i referenced in design documents for design of systems and structures.
4.2 Reovirements Design control measures require that:
4.2.1 l The organizational structure be de144 a, and authority and !
responsibility of. personnel involved in preparing, reviewing, ,
approving and verifying design documents be delineated, i
4.2.2 ;
The design bases, safety analysis, regulations, codes and standards and Plant Technical Spectftcations including all effective amensments '
will be utilized in, reviewed for revision, and revised, es '
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 appitcation, ;
i including comettiblitty of materials, accessibility for inservice inspection, maintenance and repair ALARA considerations, personnel safety, fire hazards analysis, and quality standards. The review l
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 esternal design interface controls, procedures, and i lines of coanunication among participating design organizations and across technical disciplines are established and described for the ;
preparation, review, approval, release, distributton, and revision of documents involving design interfaces.
4.2.5 '
Errors and deficiencies in approved design documents, including design methods (such as computer codes) that could adversely affect items and activities within the scope of this plan shall be documented, and action shall be taken to assure that these errors or j deficiencies are corrected. In addition, any errors or deficiencies resulting from the application or use of the design documents shall be identified and corrected.
36.0 3815L (12/BB)
Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE Number pun r0R tmE nu isue umt i i=>Pa-nx.oi AND OYSTER CREEK i . Title 4.0 Design Control Revision No. I 2
i
/ ,
}
4.2.6 Deviations in specified Quality standards shall be identified and
)
j procedures shall be established to assure their resol.ution and control. l 4.2.7 Review of commercial grade items for suitability of use in structures, systems or components within the scope of this Plan shall be conducted prior to such use. ,
4.2.8 Design verification methods (design review, alternate calculatior.s l or qualification testing) shall be established and completed prior j to turnover for operation. ,
I 4.2.9 Design vertftcation procedures shall be established which assure the j fo11owing:
- 4. The verifier is quellfied and is not directly responsible for '
the design. ,
- b. Verification, including approved field changes, shall be l complete prior to turnover of the component or system to ;
Operations.
- c. The responsibilities of the verifter, the areas and features to !
be verified, shall and the extent of documention of the verification l be specified.
4.2.10 When verifications are to be accomplished solely by test: [
- a. Prototype, component or feature testing shall be performed .
prior to installation of the equipment, or prior t;) the point i when the installation would become irreversible.
- b. Verification by test shall be performed under conditions that .
simulate the most adverse design conditions as determined by l analysis.
4.2.11 Procedures shall be established to assure that computer codes, and changes thereto, are verified, certifled and controlled to prevent ,~
. Unauthorized changes, l' 4.2.12 Changes ter approved engineering documents, including fleid changes, I l will be subject to design control measures. Design changes shall be reviewed and approved by the organl24 tion responsible for the original design or by another organization with coerparable expertise +
designated to review and approve changes.
l
- l l
37.0 3815L (12/88) "
l
Nuclear GPUNC OPEaATIONAL QUALITY AS$URANCE Number P'*a r0= thaEE Nite iSt*ND uarT i AND OYSTER CREEK iODD-Pt=-220o.oi Title 4.0 Design Control Revision No. .
I 2 !
4.2.13 Design documents subject to procedural control include, but are not limited to, spectftcations, calculations, computer progrants, design
]
descriptions, and drawings, including flow diagrams, ptptng and instrume't diagrams, system diagrams, facility drawings showing equipment locations and site arrangements. .
4.2.14 Measures, which include procedure chenps, shall be provided to l !
assure that responsible plant personnel are made aware of design '
changes and/or modifications, which may affect the performance of their duties. ,
t 4.3 Responsibilities
- 4. 3 .1 Director - TMI Unit 1. and Oyster Creek The Directors - TM1 Unit I, 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. '
i 4.3.2 Director - Technical Functions The Director - Technical Functions is responsible for the development and implementation of the design control measures utilized by Technical Functions and Plant Engineering departments.
4.3.2.1 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 fulftli these responsibilities, the Director - Engineering Projects and/or ,
the Director - Engineering and Design will:
- a. Control and coordinate the activities of all contractors with design responsibility.
i
- b. Coordinate the efforts of the System Engineering Department 45 1
may be needed to support design related projects. I
- c. Provide for the review and approval, as appropriate, of I baseline design documents such as selected design criteria, flow diagrams, system descriptions, arrangement drawings, ont-itne diagrams and logic diagrams.
- d. Ensure Quality Assurance review of apolicable design criteria :
documents and specifications, and changes thereto.
l 38.0 3815L (12/88)
_ _ _ _ . _ _ _ _ _ __ . . _ _ _ _ _ _ _ . _ _ _ ______ __ _ . _ _ _ _ __ u
' GPUNC OPERATIONAL QUALITY ASSURANCE Number i TGINuclear us"JDJ"nl#"
'S" """' ' o' ' " 2oo o' Revision No. !
Title 4.0 Design Control 2 l
l 4.3.2.2 The Director - Technical Functions, through the Director - Systems .
Engineering, is responsible for: i
- a. Providing conceptual and analytical engineering service to other engineering groups as required. i
- b. Providing technical aoministration of nuclear fuel-related i engineering activities.
l
- c. Providing direct technical support to the Plant operating staff by providing Shift Technical Advisors. '
4.3.2.3 The Director - Technical Functions is respomible, through the [
Engineering Services Director, for providing Jetailed design and >
drafting services and for the preparation and maintenance of the !
Quality Classification List (QCL).
l 4.3.2.4 The Director - Technical Functions is responsible through the i Director - Engineering and Design for providing centrallred I technical capabilities in conventional engineering disciplines as i recuired to produce engineering documents for plant modifications l and for the technical performance of components and systems within the nuclear plants.
4.3.3 Director - Quality & Training i The Director - Quality & Training is responsible through the Director - Quality Assurance for providing Quality Assurance review i 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 organtrations to verify the effective implementation of ,
design control measures and the technical adequacy of engineering i results produced.
l u
39.0 3815L (12/88)
-- , -,-n.,-- w -
GPUNC OPcRAi!ONAL QUALITY ASSURANCc Number Nuclear PtAN m tNRtc attc istANO uNrT i AND_0YSTER CREEK i =0-PLN-7200.0i l
Revision No. ,
ittie 5.0 PROCURcMENT AND MATcRIAL CONTROL 2 j i
5.0 PROCUREMENT AND MATERIAL CONTROL !
5.1 Control of Procurement .
5.1.1 General !
t 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 ensure that -
procurement sources are evaluated and confirm that the activities of consultants, vendors and contractors, and purchased items conform to '
procurement document requirements. The programs of all participants i shall be in accordance and/or compatible with the applicable requirements of this GPUN Operational Quality Assurance Pl n. ,
5.1.1.2 The general and specific requirements for the Quality Assurance !'
Program of all suppliers including their subsuppliers supp' lying items, materials parts, consumables, equipment or services, or wtthin the scope of this plan shall be prescribed by procurement j documents. These quality program requirements shall be consistent ;
with Section 2.3 of this Plan.
-l 5.1.1.3 Quality Assurance Plan measures shall be applied with a graded l :
approach to the procurement of new and spare parts, replacement parts, commercial grade items and consumables. Procurer 3nt of spare '
or replacement parts for structures, systems and components shall be subject to current GA program controls and to codes, standards, technical and quality requirements equal to, or better than, original, as may have been superseded or upgraded by regulatory reovirements or comettments. As a etntmum, 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 t 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 Recuirements 5.1.2.1 Procurement Documents The requirements for the preparation, review, approval and control of procurement documents shall be prescribed in detailed procedures. These procedures shall prescribe requirements to ensure that procurement documents:
40.0 3816L (12/88)
1
- GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear auN r0R TNREE Niu ISuNo uNn i iooo-PtN-noo.oi AND OYSTER CREEK i Revision No. l Title 5,0 PROCURENENT AND MATERIAL CONTROL 2 )
I
- 4. Specify the technical and quality assurance requirements !
commensurate with regulatory requirements and comitments and l
.this Plan. j
- b. Require applicable quality assurance requirements to be imposed !
on subvendors and subcontractors. i L 1
- c. Specify or reference design basis technical requirements, i including applicable regulatory. requirements and comitments, I material and component identification requirements, drawings, specifications, codes and standards, test, calibration, and 1 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, j
- e. Include an identification of those items and activities within the scope of this plan. .
- f. Identify those records which vendors or contractors shall retain, maintain, and control; and those which vendors or . I contractors shall deliver prior to use or installation of the ;
item. j
- g. Include right of access to vendors or contractors and subtier vendor and contractor facilities and recores for source
'l inspection and/or audit. l
- 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 equivalent to those provided in this -
plan,
- k. Identify the programs, procedures, activities or conditions ,
that require GPUN approval and/or release. .
l l
l 41.0 3816L (12/88)
GP Nu ber -
t Nuolear r'UNC aa roaOPERATIONAL QUALITY THREE at'E istrao uart AND OYSTER CREEK i ASSURANCE iooo-Pla-72co oi i Revision No.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL 2 t
Measures shall be established for the review, approval, and release !
of procurement documents and subsequent revisions. The reviews l shall. assure the inclusion of the applicable technical, quality, i regulatory, and administrative requirements in procurement documents l prior to their use. Review of procurement documents shall be occumented to provide objective evidence of their approval prior to :
release. !
5.1.2.2 Qualification and Selection of External Oreantrations ,
Evaluations of prospective suppliers shall be conducted and l documented to demonstrate qualifications based upon one or more of the following criteria:
- a. Review of performance histories which provide records of ;
supplier previous capability to provide similar products or services.
- b. Review of the external organization's capability to comply with the GPUN Quality Assurance Program, as applicable to the items t or services to be supplied. ;
- c. A pre-award survey of the external organization's facilities and '
! Quality Assurance program to determine his capability to meet I the technical and quality requirements of the procurement l document (5). l -
Procedures shall be established to prescribe the evaluation and I selection of external organizations. Contracts or purchase orders for itemt, materials, parts, consumables, equipment or services ,
within the scope of this plan shall be awarded either to:
- d. External organizations whose Quality Assurance Program has been reviewed and accepted by GPUN Quality Assurance Department as being commensurate with the equipment or services to be provided, or
, e The external organization will be required, by procurement documents, to work under the direct control of the GPUN Quality Assurance Program. In these instances, the supplier will not be required to have a separate quality assurance program.
When GPUN's acceptance of &n external organization's quality 4 assurance program is required, it shall be reviewed for concurrence l by GPUN prior to initiation of the activity affected by their program.
In the case of " commercial grade items" the procurement process shall be controlled so that the dedication process described in 5.1.2.1 shall be met. '
42.o 3816L (12/88)
I 1 GPUNC OPERATIONAL QUAL.ITY ASSURANCE Number Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 l Revision No. l Title 5.0 PROCUREMENT AND MATERIAL CONTROL 2 ;
I 5.1.2.3 Manufacturino Assurance Measures shall be estabitshed to provide control of manufacturing I activities of suppliers. These methods shall be described in 1 j
, detailed written procedures. .
b The attributes of the manufa:turing assurance program shall include:
Provisions for the review for concurrence of the suppiter's
- 4. .
drawings, Quality Assurance manual, manufacturing and quality ,
procedures prior to fabrication. When specified in approved procurement documents suppiters may not implement procedures until written notice of CPUN acceptance is received. . ;
- b. Established supplier inspection plans that delineate, as j ~
, required, the hold and/or witness points in the manufacturing process for specified review, inspection, verification and test.
i C. Methods for identifying and reporting nonconformances and i resolving of nonconformances where the supplier's suggested I ,
disposition is "Use-as-is" or " Repair". Such methods shall !'
require the approval of the supplier disposition of nonconformances by the responsible engineer and approval of the responsible Quality Assurance organization. GPUN Quality '
Assurance shall also verify that repairs are accomplished in accordance with the approved disposition. ' !
t
- d. Not'ification of site QC Receipt Inspection of outstanding '
nonconformances and/or incomplete pre-shipment inspection prior ,
to item shipment from the supplier,
- e. Planned and systematic audit, source inspection and/ or source !
surveillance of supplier activities or products. Scope of I ,
coverage and frequency shall be determined by the criticality of l
the furnished items or services and the evaluated results of '
supplier qualifications, including pre-award surveys and QA document reviews. Revisions to source verification plans shall be tade as warranted by supplier performance. Typically, audits will be conducted on suppliers of services; and, source inspection, source surveillances, and/or receipt inspection will be coniucted on suppliers of hardware. ,
- f. Control of suoplier document package including review for ;
completeness and acceptability. Inadeouate records which render the Quality 3tatus of item (s) furnished indeterminate shall be I sufficient cavse for rejection of this item (s).
43.0 3816L (12/58
o .
- t Nuolear GPUNC OPERATIONAL QUALITY ASSURANCE etAa r0R ThREE altE IstAno caIT i AND OYSTER CREEK Number iOOo-eta-7200.oi i
Revision ko. )
Title 5.0 PROCUREMENT AND MATERIAL CCNTROL 2 !
l i
- 9 Assessments of supplier control of quality shall be made at a I ;
frequency and depth commensurate with the importance, complexity i and quantity of the items furnished, These assessments shall !
utilize the gus11tative and quantitative information provided by '
i supplier noncompItance documents; surveillance, inspection and I ;
audit reports; and receiving inspection and test records. l
- h. Material acceptance procedures that assure:
- 1. The material, component, or equipment is clearly identified j and that the identification and quantity correspond to the information on the shipping documents and quality records.
j;
- 2. The item's handling and shipping requirements have been met '
by the supplier and maintained by the carrier. I
- 3. The item's record package or compilance certificate is I complete &nd adequate, i
- 4. The material, component or equipment meets the technical requirsments specified in the procurement documents, ,
inspection plans, checklists or other special engineering :
documents.
- 5. Items delivered which are not in compliance with '
requirements are documented 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.), 1 segregated (if possible), and prevented from being i inadvertently issued for installation or use.
)
l 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, i
!. 5.1.2.4 Comercial Grade Dedication for NSR Applications The process of acceptance of commercial grade items intended for use in nuclear safety related app,lications shall be controlled and '
1mplemented through an approved procedure (s) which includes the following: i'
- 3) An engineering evaluation to determine if the commercial grade item performs a safety function or if its failure could compromise a safety functions.
b) A determination that the definition of commercial grade item as I provided in loCFR21 is met.
i 44.0 3816!. (12/88)
E'
' i
', Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE Number PLAN roa TNREE Mite istAND uari i-
'AND OYSTER CREEK iooo-PtN-72co.oi 5
Revision No. !
Title 5.0 PROCUREMENT AND MATERIAL. CONTROL 2
, .c 7 !
c) A determination of the critical characteristics which are i essential for the performance of its safety function.
d) The definition of functional tests and/or inspections, including J' acceptance limits, to be performed to verify critical characteristics. l e) Verification that critical characteristics have been met by one j of the following: -
1 Performance of functional tests and/or inspections after )
receipt by GPUN; ; .
2.
Withessing of functional test and/or inspections at the '
I supplier's facility.- '
- 3. Assuring through audit or surveillance that the supplier has '
a quality program which adequately controls the critical f charactertstics; performs tests-and/or inspections which 4
verify that critical characteristics have been met; Establishing the commercial grade part performance history concurrent with performing one of e(l), e(2) or e(3) above; or,
- 5. Any combination of e(l) through e(4) above. t Thisdedicationprocessshallresu[tinthedocumentedbasisforthe appropriateness of the use of the commercial grade item (s) in the specific nuclear safety related application (s). ,
5.1 3 Responsibilities ,
5.1.3.1 Olrector - Administration I
The Director-Administration is responsible through the Director i
Materials Management for the: '!
- a. Administration and operation of contracting, procurement and warehousing activities of'GPUN.
- b. Assurance that the technical and quality requirements, as ;
established by requisitioners, are incorporated into contra;t/
procurement documents without revision.
- c. Assurance that bids are evaluated for conformance to technical and quality requirements by the requisitioners.
- d. Assurance that t))e contractual, legal and commercial requirements are incorporated into the procurement documents in a manner which will enforce the technical and quality requirements.
- e. Assurance that documents and records, as required by procurement t.
documents. are submitted in a timely manner and that they are L
complete and legible.
f.
Assurance that ourchase orders and contracts for items and services within the scope of this Plan are issued to external organizations listed en the Suppliers Quality Classification List.
L 45.0 L 3816L f12/88)
3 , 4 m . GPijNC OPERATIONAL QUALITY ASSURANCE Number Nuclear P'^a roa twRet Mitt is'^ao uart i AND OYSTER CREEK iooo-*'a-72oo oi i
Revision No. i Title 5.0' PROCUREMENT AND MATERIAL CONTROL 2 s
{
.l 5.1.3.2. Director - Quality & Trainino l I
The Director-Ouality & Trainteg is responsible through the !
Pirector-Quality Assurance to: J
- a. Assure that QA0 procedures for the control of purchased i equipment, material and services are established, approved, j Implemented and effective. 1
- b. Review for concurrence GPUN precedures necessary for the control ,
1 of purchased equipment, material, and services that are within ,
the scope of this Plan, j
'c. Review supplier Quality Assurance Programs'for concurrence to 1 the extent required by the procurement documents.
- d. Review for concurrence supplier record packages as required by l applicable procedures or procurement documents.
- e. Estabitsh and implement an adequate program of source inspection, source surveillance and receipt inspection to assure that items, ,
parts, materials and consumables within the scope of this Plan -
comply with contract requirements.
- f. Review procurement documents to assure that quality requirements are correctly stated, inspectable and controllable; that there -
l are adequate acceptance / rejection criteria; that source
!. verification er receipt inspection is specified; that minimum L documentatte 5e supolled is specified; and that the procurement -
sents have been processed in accordance with established requirements. This review may include sampling review of previously approved procurement documents or in-1ine reviews of selected purchase requisitions or orders prior to L. placerrent ,
- g. Establish and maintain a Supplier Quhlity Classification List L (SQCL) which documents the results of the evaluations of prospective suppliers.
5.? Identification and Control of Materials. Parts and Components 5.2.1 Generai l i.
Measures shall be established to provide for the identification and L control of items, parts, materials, and consummables within the '
I scope of this plan. These measures shall assure that incorrect or L nonconforming items are identifled and contrciled in order to
) prevent their it.edvertant installation or use. Where, required by I design documents, the system established shall provide traceability of components from the receipt of material through fabrication, l
l l~ 46.0 l 3816L (12/88) l
C GPUNC OPERATIONAL QUALITY ASSURANCE Number
- ' Nuclear et^a r0a iwaEE Mitt istaa0 uait i AND OYSTER CREEK io0o-eta-72oo.oi Revision No.
Title' 5 0 PROCUREMENT AND MATERIAL LONTROL 2 Installation and testing. Verification shall include review of objective evidence of inspections and tests which demonstrate that product identification and control is maintained at various stages of manufacture, installation, or erection. Identification requirements snall be specified in the applicable design and
. procurement documents.
5.2.2 . Reau t rement s 5.2.2.1 Identification and traceability requirements shall be included in specifications and drawings.
5.2.2.2 Material, parts, and components, including partially fabricated subassemblies or subdivided materials shall be identified to preclude the use of incorrect or defective items.
5.2.2.3 Items, materials, parts, consumables, and equipment within the scope ;
of this Plan shell be identified so that they can be traced to L appropriate documentation, which provides objective evidence of the technical and quality requirements met; such documents include but
- are not limited to:
- a. Specifications
- o. Drawings (including as-builts)
- c. Procurment Documents I d. Physical and Chemical Test Reports
- e. Nonconformance Reports
( f. Inspection Reports and Checklists
- g. Storage Maintenance Instructions I h. Nondestructive Examination Reports j* 1. Vendor Certificates of Compliance The identification and/or end use of items, materials, parts, l consumables, and equipment shall be specified in procurement 1.
documents and work authorizing documents to provide this traceability.
l-Traceability to heat and/or lot number shall be provided when reoutred by code (s). Traceability is provided for parts of items l
' within the stoce of this plan. However, if the parts do not provide or contribute to the performance of a nuclear safety functior,, ; ,
traceability will not be provided for those parts unless required by l code (s) or regulation (s). l f
' 47.0 l 3816L (12/88) l l
1
i Number Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE r u a r0a taRu aiu 15uao uait i AND CYSTER CREEK iOOo-Ra-noo.oi :
Revi5 ton No.
Title 5.0 PROCUREMENT AND MATERIAL CONTROL 2
}
5.2.2.4 The location and method of identification shall be specified so as not to affect the form, fit, function or quality of the item being i identified. '
5.2.2.5 Correct identification of materials, parts and components shall be verified prior to release for fabrication, shipping, installation, and testing. !
5.2.2.6 Where physical identification is either impractical or insufficient, p ysical separation, procedural control, or other approved means may be employed.
5.2.2.7 A receipt inspection, when specified by procurement documents, shall I be performed at the site to verify that identification for received items is complete and accompanied by specified documentation. In the case of commercial grade items, receipt inspections shall be conducted consistent with 5.1.2.4 of this plan. ,
5.2.3 Responsibilities 5.2.3.1 Responsible Department Manager
! Ea:h Department Manager is responsible for ensuring that procurement documents contain appropriate requirements for the identification i
and control of materials, parts, or components and that only materials, parts or components which have been accepted by QAD are used. *
- 5. 2. 3. 2 Director - Quality & Trainino i The Director-Quality & Training is responsible through the Director- 1 l Quality Assurance for:
- a. Review of procedures for maintaining identification in i accordance with the requirements of this section.
l b. Verification of identification during receipt inspection,
- c. Monitoring and conducting inspections, surveillances and audits to verify conformance to the requirement of this section.
5.2.3.3 Director - Administration The Director-Administration is responsible through the Director Materials Management for assuring that correct identification of materials, parts, and components are vertfled prior to release for fabrication, shipping, installation and testing.
l' 1
48.0 l 3816L (12/88) l l
i g- W w e ---+&- i.m ae--iq.re---t.w~w. e eyy ew, -i*e.-rum--.r. -,--e--y-.m- - - - - -- -e -,,--- ---:- - - - - -w-
9 t
I Nuclear GPUNC OPERATIONA:. QUALITY ASSURANCE etAN r0R tNREE a:tt 15'ANo uNt1 i AND OYSTER CREEK Nuwber io0o-a'N-72oo.oi r
Title 6 o CONTROL OF STATION ACTIVITIES f"" (
6.o CONTROL OF STATION ACTIV! TIES 6.1 gperal 5
'This section provides general requirements which are applicable to i the operational, support, and assurance activities which are directly nuclear to related the safe operation, maintenance and modification of the station, .
6.2 control of Inspections 6.2.1 Recuirements 6.2.1.1 A program for performance of inspections of activities within the scope of this plan shall be establisned and executed by, or for, th ;
organization performing the activity to verify conformance to the documented instructions, procedures, spectftcations and drawings for accomplishing the activity. Design specifications, drawings, procedures, or instructions sh311 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 I be further translated into procedures, instructions, or checklists which shall contain, as required, the following:
- a. Identification inspected. of characteristics and activities to be j
- b. Methods to be used including necessary measuring and test !
equipment and the accuracy requirements.
- c. Ideotification insptction.
of organization responsible for performing the i
- d. Acceptance and rejection criteria.
- e. Identification of required procedures, drawings and specifications, including the appilcable revisions.
- f. Documentation of inspection results including identification of the individual performing the inspection, i 6.2.1.2 Inspectors (including NDE personnel) shall be quallfled in accordance with applicable codes, standards and GPUN or GPUN accepted Qualification programs and their qualification and certification shall be kept current and documented.
1 49.0 3818L (12/88) l~
l.
4 l Nuclear GPUNC OPERATIONAt QUAtITY ASSURANCE eta
- r0R TNREE altE IStANo UNIT i ANo OYSTER CREEK Number' iooo-ets-7200.oi i
i Title Revision No, s 6.0 CONTR0t OF STATION ACTIVITIES ,
2 ;
1 6.2.1.3 Individuals performing inspections and/or examinations shall be other l !
than those who perform or directly supervise the activity being inspe:ted and shall not report directly to the immediate supervisors who are responsible for the work activity being in),pected. If the individuals performing the inspections and/or examinations are not l R part of the responsible Quality Assurance organization, the proce-dures 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 be con-duc ed by second line supervisory personnel or by other qualifted -
personnel not assigned first line supervisory responsibility for the conduct of work. These activities, l.9., those performed by indivt- ,
duals 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 super-vision. When inspections and/or examinations associated with normal [
operations of the plant (such as routine maintenance, surveillance and tests) are performed by individuals other than those who l performed or directly supervised the work, but are within the same group (reporting to different supervisors), the following controls shall be met:
- a. The quality of the work will be demonstrated through a functional L
test when the activity involves breaching a pressure retaining item. ~
1-
- b. The qualification criteria for the personnel.are reviewed and found acceptable by the Quality Assurance organization prior to initiating the inspection.
Inspections of maintenance activities may be conducted by individuals j who directly report to a supervisor immediately responsible for the maintenance being inspected. However in such cases the following i
shall be met:
1
- a. The qualification of individuals shall be reviewed for concurr-ence by Quality Assurance.
t.
- b. Deficiencies identified shall be handled consistent with the requirements of Section 8.o of this plan.
- c. Independent inspections and/or monitoring of such cases of main-tenance and inspection shall be conducted by Quality Assurance.
! The frequency and scope of such independent verifications shall be based on the observed quality of the inspections.
6.2.1.4 The Quality Assurance Department shall establish documented methods to review work activities prior to implementation to d'etermine the need for inspection and the specification of the requisite hold and/or witness points.
So.o 2818t (12/88)
y e m
GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear PtAN roR THREE at'E ISLANo unit i AND OYSTER CREEK iooo-PtN-72oo.oi i
Revision No. '
Title 6,o CONTRot OF STATION ACTIVITIES 2 6.2.1.5 When QA Hold Points have been established, either contractually, by procurement, or internally by plant procedures, work may not proceed i beyond the Hold Point until either inspection is performed or waived L by the responsible Quality Assurance organization, .
6.2.1.6 Inspections of modifications, repairs, and replacements shall be by l 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 previously accepted lots, sampling inspection shall be representative and only to the extent nr essary to assure adequacy of control. The sampling plan shall bt etermined by Quality Assurance. Inspection personnel shall be provided with suitable equipment and tools, which are ,
. calibrated as necessary, and controlled to assure that accuracy l requirements are satisfied and that inspections are complete.
I l 6.2.1.7 Inspection data and results shall be evaluated by designated I
personnel to assure that the objectives have been met and that items requiring action or follow-up are identifled and documented.
I ;
6.2.1.8 Records shall be kept in sufficient detail to provide adequate confirmation of an inspection program.
6.2.2 Retoonsibilities 6.2.2.1 Director - Technical Functions N The Director - Technical Functions is responsible for ensuring that requirements for inspections are included in design specifications, drawings, procedures and instructions and that these reautrements '
include acceptance criteria and, as applicable, references to codes, 4 standards and regulatory requirements and commitments. I 1
l 6.2.2.2 DirectSr - Quality & Trainina l l <
it o oirector - Quality & Training, through the Director - Quality I i
Assurance, is responsible for:
l'- 4. Assuring that inspectors are qualified in accordance with applicable codes, standards, regulatory requirements and commitments, and GPUN or GPUN accepted qualification programs.
- b. Reviewing maintenance and installation documents for inclusion l of inspection and test requirements and QA hold and/or witness l points,
- c. Reviewing and concurring with the personnel qualification criteria of individuals performing inspections, including tnose who are not part of the QA organization. -
- d. Identification of inspection plans to be used for verification of inspections on previously accepted lots.
51.o 3818L (12/88) l L
a Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE PLAN FOR TaREE MILE IStA e UNIT i AND OYSTER CREEK Number iDoo-ata-72co.oi i Title Revision No.
6.0 CONTROL OF STATION ACTIVITIES 2 i !
6.2.2.3 ResDonsible Department Manaaer i Each responsible Department Manager performing work requiring inspections is responsible for: ,
- 4. Notifying the QA Department of the work being performed. i
, b. Ensuring that maintenance and installation documents within the .
scope of this plan are transmitted to QA to provide for the '
inclusion of hold and/or witness points prior to approving such documents for use.
- d. Assuring that all information, records or copies of records associated with their work are made available to QA personnel.
Each responsible Department Manager performing inspections is responsible for:
- e. Assuring that the personnel performing inspections are qualified in accordance with applicable codes, standards, regulatory requirements and commitoents, and GPUN or GPUN accepted qualification program (s). >
f.
Assuring that the results of all inspections are properly docu-mented and the results are evaluated by designated personnel.
6.3- CA Monitorina !
6.3.1 'Reavirements 6.3.1.1 A program for QA Monitoring of activities affecting items or i 1
processes within the scope of this plan shall be established and I executed by the QA Department.
1
,, 6.3.1.2 Monitoring is used to establish adequate confidence levels that activities within the scope of this plan are being performed in [
accordance with the QA Program requirements 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 safety importance of activities, extent of previous '
expertence, thoroughness of overall coverage, uniqueness of testing t
or operating activities and trending data.
l 6.3.1.3 Monitors shall be qualified in accordance with a documented QA Department procedure that ensures that Monitors are knowledgeable in
- l. the activities they are monitoring to the extent that they can readily verify compliance of the activity being performed.
52.0 3818L (12/88)
/
.i 3
+
GP Number !
<" Nuclear a'UNC OPERATIONAL Aa roa TaREE AND OYSTER CREEK QUALITY altE tStaao uaIT i ASSURANCE iooo-Pta-7200.oi :
Revision No.
- Title 6.o CONTROL OF STATION ACTIVITIES 2 I
6,3.1.4 Nnitoring reports shall contain as a minimum the following: l a.. Identification of activity being monitored includ'Ing specific I reference to the program or procedural requirements governing g the activity. t
- b. Indication of compliance, i
- 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 noncon. '
-formances exist and are ident1 fled as a result of the monitoring.
6.3.1.5 Records shall be kept in sufficient detall to provide adequate documentation of a monitoring program. '
6.3.2 Responsibilities 6.3.2.1 Otrector - Quality & Trainino I The Director - Quality & Training through the Director'- Quality '
Assurance, is responsible for: .
- a. Establishing the requirements for 0A monitoring of activttles and practices affecting items or processes within the scope of -
,. this plan. I
- b. Assuring that QA Monitors are adequately trained and are qualified to. perform their duties.
- c. Assuring that adequate' awareness of plant status is maintained by site QA Management through discussions with plant personnel, attendence at status meetings, etc.. to permit the definition of appropriate real-time monitoring activities.
- d. Assuring that reports of the monitoring activities have l sufficient details and provide adequate confirmation of the monitoring program.
L l .- 6.4 Control of Special Processes l
l 6.4.1 Recuirements l 6.4.1.1 Special processes are those processes that require interim in-process controls in addition to final inspection to assure quality. Such j processes include, but are not limited to, welding, heat treating, chemical cleaning, nondestructive examination, plant chemistry control, and the processing and preparation for shipment of radio-active wastes.
i 53.0 l' 3818L (12/88)
u ..
Nuolear GPUNC OPERATIONAL QUALITY ASSURANCE Number '
PLA= r0R TaREE Nite iStANo uarT i iooo-eta-Troo.oi -
AND OYSTER CREEK-Title 6.0 CONTROL OF STATION ACTIVITIES Revision No. '
1 2 !
6.4.I'2.
Measures shall be established and documented to asture 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 qualtfled personnel and procedures.
6.4.1.3 Procedures for special processes shall be established to meet the requirements of applicable codes, standards, and regulatory require-ments and commitments or to meet the requirements of special process specifications which may be produced by or for GPUN. These proce- '
dures 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 quellfled i personnel. Procedures, equipment, and personnel performing special processes shall be qualified in accordance with applicable codes, standards, and specifications. Organizational responsibilities shall anddelineated be personnel. for the qualification of special processes, equipment Qualification records of personnel, equipment, and ,
procedures associated with special processes shall be established, prepared and kept current. For special processes not covered by the existing codes or standards, 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.
6.4.2 Responsibilities
~
6.4.2.1 Responslble Department Manager Each responsible Department Olrector/ Manager performing special processes is responsible for.
- a. Assuring that the established program requirements for control. I ling and accomplishing special processes are implemented.
b.
Assuring that the procedures, including changes, are reviewed, approved and qualifted prior to use. l
- c. Assuring that personnel and equipment used in the performance of l
special processes are quallfled and the records of qualification are maintained.
6.5 Test Control 6.5.1 Reouirements 6.5.1.1 A documented test program shall be established to assure that all testing required to demonstrate that the structures, sy' stems or components within the scope of this plan will perform satisfactorily i
in service. The tests shall be performed in accordance with l written, approved, and controlled test procedures or ins: ructions which incorporate or reference the requirements and acceptance 54.o 3818L (12/88) 1' 1
~ . -
rT1 ,
Nuolcar GPUNC OPERATIONAL QUALITY ASSURANCE PtAN r0R TNRtE NItt 2StANo UNIT i AND OYSTER CREEK' Number icoo.ptN-72co.oi i
i if
' Title- 6.0 CONTROL OF STATION ACTIVITIES Revision No.
2 1
standards contained in the applicable design documents. The extent r'
of testing shallorbe replacement, based on the complexity of the modification, repair. !
Testing, including proof tests prior to installation, hydro testing, Inservice Testing (IST) and preopera- ;
tional tests, necessary to demonstrate that the installed or modified I structures, systems and components will perform satisfactorily in l.
service, shall be accomplished in accorG6nce with written approved procedures or instructions. These procedures shall be consistent '
i ;
with or incorporate the technical and quality requirements and I acceptance limits specified by applicable design and procurement documents. These test procedures or instructions shall provide for ;
the following as required: l Y
- 4. A description of the test objective. ,
b.
Instructions for performing the test, including caution or safety notes in sufficient detail to avoid operator interpretation.
- c. Test preregulsites such as calibrated instrumentation adequate test equipment and instrumentation including accuracy, require-l ments, completeness of item to be tested, suitable and controlled environmental conditions, and personnel to be provided to conduct testing under the direction of a quellfled test supervisor or test engineer. ( !
- d. Provisions for data collection and storage. '
e.
Acceptance and rejection criteria as specified in design and procurement documents.
f.
Methods of documenting or recording test data and results, in sufficient detail to prevent misinterr 'ation. !
9 Handatory hold or witness points for .'etion by G?UN Quality Assurance and/or other designated 6 %).
- h. Provisions for control of jumper!. t' 1 leads and jurisdic-tional or safety tags.
1.
Provisions for returning a system to normal configuration upon completion 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 determined by a responsible individual or group.
P 6.5.1.3 The test program shall cover all required tests including:
- 8. PreoperaticNI tests of coc' ients or systems to demonstrate that performance is in accoraance with tne aesign intent.
- 55.0 3818L (12/88)
f Nuclear GPUNC OPERATIONAL QUALITY ASSURANCE PLAN r0R tNREE altE ISLANo UNIT i AND OYSTER CREEK Number icoo-PtN-72oo.oi
{
i Revision No.
Title 6.0 CONTROL or STATION ACTIVITIES 2
)
b.. Tests'during initial operation to demonstrate system performance l
(that could not be tested prior to operation) to confirm compli-ance.to design criteria,
- c. Tests during the operational phase to provide assurance that l failures or substandard performance do not remain undetected and that the required reliability of systems within the scope of I this plan is maintained. I ,
4
- d. Tests during activities associated with plant maintenance during t the operational phase and to oemonstrate satisfactory performance following plant maintenance or procedural changes.
6.5.1.4 Tests performed following plant repates or replacements shall be conducted in accordance with the original design and testing requirements or approved, documented alternatives. Testing shall be '
sufficient to confirm that the charges ceasonably produce expected results and that the change does not reduce safety of operations, t
6.5.2 Responsibilities 6.5.2.1 Directors TNI Unit 1, and Oyster Creek The Director of the nuclear generating stations are each responsible for assuring that testing performed at their assigned station is 1
performed in accordance with the requirements of this Plan including, as a alnimum, the following:
- a. . Assuring that testing is performed in accordance with written, approved and controlled procedures or instructions. '
- b. Assuring that operations personnel have the required special training and skills,
- c. Assuring that the test results are documented and are evaluated for acceptability by a responsible individual or group.
- d. Assuring that identified discrepancies are addressed, resolved and reported as required by the Operating License and Technical Specifications of the Unit.
6.5.2.2 Director - Technical Func':fons The Director - Technical Functions, through the Director - Startup and Test is responsible to perform a startup and test function to assure new or substantially modified plants, f acilities and systems are tested. These responsibilities shall include:
- a. Preparing test plans and implementing procedures.
56.3 3818L (12/88)
.l GPUNC OPERATIONAL QUALITY ASSURANCE Nuclear etaw rOR THREE Mite istaaD uar2 i AND OYSTER CREEK-Number iooo-P'~-72co.oi 1
Revision No. j Title 6.0 CONTROL'0F STATION ACTIVITIES 2 i )
i i
- b. Directing testing and assuring test engineers have the required j special training and skills. ,)
- c. Ensuring that test documentation is completed, as required, and reviewed prior to turnover to Operations, j
- d. Coordinating technical assistance of testing. I
- 6. 5.2. 3 Director - Maintenance. Construction and Facilities The Director-Maintenance, Construction and Facilities (MCF), through l the applicable station Maintenance, Construction and Facilities 1 I Director, is responsible for: ,
- a. Ensuring supporting personnel have the required special training i and skills. .~
- b. Prescribing and performing the construction or post-maintenance !
test requirements for the work performed by MCF. '
- c. Ensuring that all construction or post-maintenance testing per- I formed by MCF, including hydrotesting, is performed, documented and the results acceptable prior to turnover.
6.6 Control of Measuring and Test Equipment 6.6.1 Requirements 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 functionality or quality of structures, systems and components within the scope of this Plan. Such equipment typically include tools, gauges, meters and other devices. Such measurements L and tests include as a minimum those associated with the activities of operation, maintenance, modification, chemistry, 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 be established to ensure that range, type, accuracy and use of the equipment conforms to specified requirements.
L 6.6.1.2 Requirements for each control program shall include inspection and L verification of accuracy upon receipt of equipment, identification l of all gauges and instruments, calibration and scheduled recall for calibration and traceability to an accepted Standard. These activ-itles shall be subject to OAD monitoring and auditing. Procedures shall be established to implement the following requirements:
)
i 57.0 f 3318L (12/88) l l 1 1
.- . . ~ . . . - -. . -. . .
I t
Nuclear GPUNC OPERATIONAt QUAT!TY ASSURANCE Number PtAN roa TNaEE artE iStANo unit i AND OYSTER CREEK iooo-PtN-T200.oi 1 Title 6.o CONTa0t OF STATION ACTIVITIES Revision No. '
2 a.
Establish the calibration technique and frequency requirements, maintenance requirements , and controls for all measuring and test equipment which ara used in the measurement, inspection, I 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 nondestructive examination equipment). 1 b.
The identification of measuring and test equipment traceable to the calibration test data, c.
Installed plant instrumentation and measurement and test equip-ment requiring calibration shall be identified and controlled in
- accordance with written, approved procedures to assure that i approved calibration intervals are not exceeded. Portable I measuring and test equipment may be similarly controlled; but .
i slid 11, as a minimum, be clearly labelled to tr.dtcate the date on which the current calibration expires. Measuring and test equip-ment that has exceeded the approved calibration interval shall not be used for measurements or tests.
- d.
Establish calibration frequency for measuring and test equipment 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 i 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 performed 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 and Test equipment (M &TE) used to calibrate instru-ments and gages (flowmeters, pressure gauges, level indicators, etc.) shall have been calibrated against working standards with accuracles being calibrated. at least four times greater than that of the equipment 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.
I 58.o 3818L (12/88)
Nuclear GPUNC OPERATIONAL QUAtITY ASSURANCE PtAa r0R twREE artE iSLAa0 unit i AND OYSTER CREEK Number iooo-Ptu-72co.oi.
l l
Title-Revision No. q 6.0 CONTROL Of STATION ACTIVITIES 2 )
J 1
When the above requirements cannot be met, the standards used shall have a precision and repeatability that assures the equip-ment being calibrated will be within the required tolerance. ,
The basis of acceptance will be documented and authorized by the '
supervisor of the calibrating organization.
Some measuring tools because of their construction (such as mechanical dlal indicators) or because they are not adjustable (such as rulers) need not be periodically calibrated. However, their physical condition and where applicable the accuracy shall be routinely checked prior to use,
- g. A status of all measuring and test equipment under the calibra-tion program is to be maintained. i 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.
- i. NDE equipment shall be controlled and calibrated in accordance with the industry code governing its use.
6.6.2 Responsibilities 6.6.2.1 Responsible Department Manaaer Each Department Manager utilizing tools, gauges, instruments and other measuring and testing devices in activities affecting the function or Quality of structures, systems, components and activities within the scope of this plan shall assure that the equipment is ;
controlled in accordance with an approved calibration control program which complies with the requirements of this Plan.
6.7 Handling, Storage and ShiDDing 6.7.1 Recuirements 6.7.1.1 Measures shall be established and documented to control handling, storage, and shipping, including cleaning, packaging, and preserva-tion of items within the scope of this plan in accordance with j 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.o 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 ccnditions such as temperature or huniidity. These procedures shall be implemented by suitably trained individuals. The procedures shall include but not ,
be limited to, the following:
59.0 38'B'- (12 /88)
- ~
[,1 j
GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear PLAN FOR VHREE MILE ISLAND UNIT l-AND OYSTER CREEK-1000-PLN-7200.01 :
Revision No. ;
Title. 6.0 CONTROL OF STATION ACTIVITIES 2 s ;
i
- 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 o atmospheres, moisture contents, and temperature controls shall l be specifttd as required and their existence verifted 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, ane verifica-tion and documentation requirements shall be specified in the procedures, y
- 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 storage and the control of items in storage which will minimize the possibility J of damage or deterioration during storage. Periodic inspections , ;
of storage areas shall be performed and documented to verify ' - !
compilance with storage procedures. Release of items for !
L installation shall also be procedurally controlled.
L
- e. Provisions to assure that proper marking and labeling of items .
and containers is accomplished to provide identification and J necessary instructions during packaging, shipment and storage. l l
- f. Provisions for documentinr, and reporting nonconformance to !
l handling, and shipping requirements. j
- g. Provisions for the storage of chemicals, reagents, lubricants and other consumable materials which will be used in conjunction )I l
with systems which are within the scope of this plan. l l- h. Provisions for " Limited Life" requirements (including " Shelf t
l Life" and " Service Life" for applicable materials).
I 6.7.2 Responsibilities i
6.7.2.1 Responsible Department Managers l l
Each responsible Department Director / Manager is responsible for l Identifyirg in procedures. drawings, specifications or procurement i l documents those handling, storage and shipping requirements +
l necessary to assure compliance with the requirements of this Plan. '
60.0 3818L (12/88) r- y+ .4..ew,.. -s , - ,o,-- - , - . ~ . . , , _.,4, - , , , - - , ~ _ _ , , - . - . _ _ , , - - - - - , . _ . - . _ _ . --.-._-..-,--_..-._-_-._,.--.4..-- e, -_. . ..-~d
Y , . i Nuolear GPUNC OPERATIONAL 00AtITY ASSURANCc etAN r0n TNate Mitc rStANO unit i Number i0oo-Pt.N .72co.oi i
AND OYSTER CREEK Title "O' 6.0 CONTR0t Of STAi!ON ACTIv! TIES
'Y" 6.7.2.2 Director - Administration The Director-Administration, through the Director-Materials Management, is responsible for: -
n.
Providing the procedures for the receiving and storage of ,
materials, parts and components, l b.
Assuring that the personnel responsible for the handling and ;
storage of materials, parts and components are adequately trained in the performance of their duties and that they ,
tmplement the procedures properly.
- c, Providing adequate storage of items, materials, components, and~
parts within the scope of this plan.
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 with the reautrements 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 modification projects performed at the generating stations.
6.8 Inspection. Test, and Operating Status 6.8.1 Reautrements 6.8.1.1 Measures shall be established and documented to ensure that the required inspections 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 sultable
'; means, to assure that reautred inspections and tests are satisfactorily completed to prevent inadvertent bypassing of
!- required inspections and tests and to prevent inadvertent operation.
i 3818L (12/88) i L
,1' .
. t Nuolear GPU pu ,NC OPERATIONAL QUALITY ASSURANCE ro. T m E MILE Isu o U IT i Numbe,r i000. tN. n oo.oi i
AND OYSTER CREEK Title Revision No, s '
6.0 CONTROL Of STATION ACTIVITIES 2 6.8.1.2
'The requirements for an acceptable inspection, test and operating I status program for structures, systems, and components throughout fabrication, instt11ation, test and operation include: i 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 appilcation and removal of inspection and welding stamps, and other status indicators such as tags, jumpers, markings, labels, and stamps.
c.
Procedure! for controlling the bypassing or altering of the sequence of required inspections, tests or other critical operations are procedurally controlled with concurrence by the Quality Assurance organization. The procedures shall provide for the identification of items which have satisfactorily passed I
such inspections and tests, where necessary to preclude inadvertent bypassing of required Inspection and tests, d.
In cases where documentary evidence is not available to confirm that an item has passed required inspections and tests, that
- ltem shall be considered nonconforming until such evidence becomes available. Affected systems shall also be considered to be inoperable and reliance shall not be placed on such systems T'~'
to fulfill their intended safety functions.
e.
I 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.
I Methods which ensure temporary modifications / variations shall be '
n controlled by approved procedures which include a requirement for Independent verification. A log shall be maintained of the 1
current status of such temporary modifications / variations.
g.
L Methods which ensure that nonconforming services and inoperative !
p- or malfunctioning structures, systems, components or materials l l
be identified in accordance with the requirements of this l
l 62.0 3818L'1?/88!
I i
.,..,_._.,.~.--.______,____.._____.,_-__.-_________________________________.i
t i
GPUNC' OPERATIONAL QUAL!TY ASSURANCE Number !
1 Nuclear '^" roa '"att at't IS'^"o u"It i
'ND OYSTER CREEK A
iooo-"-'aoo oi' i j
Revision No. {
Title 6.0 CONTROL OF STATION ACTIVITIES 2 j
' 1 6.8.2 Responsibilities 6.8.2.1 Directors TN! Unit 1. and Oyster Creek The Directors of the nuclear generating stations are each l 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 l performed at their respective stations.
6.9 Housekeepino and Cleanliness 6.9.1 Recutrements r
6.9.1.1 Good housekeeping practices shall be uttilzed 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 parts of the nuclear plant within the scope of this plan. l .
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 -i quality of the' item is not degraded as a result of housekeeping practices or techniques. During maintenance activities, certain portions of safety-related systems or components may be subject to potential contamination with foreign materials. To prevent such L contamination, control measures, including measures for access control, and tool accountability shall be established. Additionally, 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.
l l 6.9.2 Resoonsibilities l 6.9.2.1 Directors TMI Unit 1. and Oyster Creek 1
l- The Directors of the nuclear generating stations are each
- responsible for establishing and maintaining programs and practices i
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.
63.0 i 3818L (12/88) 1
. _ _ . . - - - -_-. - - . - _ . _ - _ - . .- - . _ . - .- +:
4[ 4 " *
]
~ GPUNC OPERATIONAL QUALITY ASSURANCE Number l Nuolear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 l
Revision No. l Title' 6.0 CONT.ROL OF STATION ACTIVITIES 2. N
, 6.9.2.2 Director - Maintenance. Construction and Factittles The Director-Maintenance, Construction and facilities through the- !
site Maintenance, Construction and Facilities Directors is l
responsible to implement housekeeping and cleanliness control plans, ,
procedures, instructions or practices associated with all work 1 activities performed by MCF personnel and contractors, 6.9.2.3 Director - Quality & Traintna t
The Director-Quality & 1 raining, through the Director - Quality Assurance is responsible for monitoring the housekeeping and cleanliness practices at the nuclear generating stations. l )
( 6.10 .Eauioment Control
- 6.10.1 Recutrements 6.10.1.1 Author 1 ration to remove plant installed operational equipment or ,
. systems from service, for maintenance or modification, shall be granted by the on-duty Shift Supervisor.
6.10.1.2 Procedures shall be provided for control of equipment, as necessary, to maintain personnel and reactor safety, to avoid unauthorized ,
operation of equipment, and to assure that operational equipment is g in a ready status. Work on equipment and systems, critical to the !
safe operation of the plant, shall not be performed while the plant l.
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. Control measures such as locking or tagging to secure and I identify equipment in a controlled status.
1 L b. Independent verifications when necessary to ensure that '
l measures, such as tagging equipment, have been implemented L. correctly.
- c. Temporary modifications / variations, such as temporary bypass lines,' blank flanges or stellar mechanical inserts, electrical l o jumpers, lifted 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 person or by functional test which conclusively proves the proper installation and subsequent removal of the temporary modification. A log or equivalent documented evidence shall be maintained of the current status of such temporary modifications I which are installed.
l l
3818L (12/88)
y GPUNC OPERATIONAL QUALITY ASSURANCE Nurber :
MlNuclear %"JjM"s!!LEISLANUUNIT1 1000-PLN-7200.01 i Revision No. )
~ Title- 6.0 CONTROL of STATION ACTIVITIES 2 j 1
- d. . Control of inspection and test status on individual items by the 1 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 i documentation to assure traceability.
6.10.2 Responsibilities i
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 procedures and assuring implementation of the procedures for identification anu control of '
equipment to avoid unauthorized use and to assure that operational equipment is in a ready status. These requirements shall include independent verifications to encure proper implementation.
6.11 Control of Construction. Maintenance (Preventive / Corrective) and Modifications 6.11.1 Requirements '
6.11.1.1 Construction, maintenance or modifications which have the potential to affect the functioning of structures, systems or components within l l the scope of this plan shall be performed in a manner to ensure
, quality at least equivalent to that specified in the original design l basis and requirements, materials specifications and inspection I requirements. A suitable level of confidence in structures, syttems or components on which maintenance or modifications have been c.er-formed shall be attained by appropriate inspsetion and performance testing. Construction, maintenance or modification of equipment l shall be pre-planned and performed in accordance with written pro-i cedures, instructions or drawings appropriate to the circumstances which conform to applicable codes, standards, specifications, and criteria. In this regard, modification tyt,e work in aren and systems of the plant, critical to the safe operation of tne plant, shall not be performed while the plant is operating without specific advance approval by the Plant Division Director or designee (s). , l g 6.11.1.2 Detailed step by step procedures are not required for all i maintenance and modification work. The supervisor planning the job l 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.
'. 65.0 l 3818L (12/88) l l
i
~~ ~ ^'
y . .
j y- ,a, -
i l
GPUNC OPERATIONAL QUALITY ASSURANCE Number-l'
. 4 Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CRE!K 1000-PLN-7200.01 )
i
'itle Revision No.
a 6.0 CONTROL OF STATION ACTIVITIES 2 Mhereas, work involving inter-departmental coordination or risk of nuclear or personnel safety requires a higher level of j administrative control such as approved prccedures and sign offs to I properly' coordinate, direct and document the activity. ;
1 6.11.1.3 Skills normally possessed by quallfled maintenance personnel may not !
require detailed step-by-step delineations in a written procedure j
.'~ but are subject to general administrative procedural controls that govern or define the following areas' 3 l
l
- a. Methods for obtaining permission and clearance from Operation I personnel to work and for logging such work,
- b. Factors to be taken into account, including the necessity of maintaining occupational radiation exposure as low as is reasonably achievable (ALARA),
- c. Method for identification of what procedural coverage is necessary for the maintenance, construction and modification activity,
- d. Considerations for system / equipment cleanliness control,
- e. Method for identification of post maintenance, construction or modification, testing, including system / equipment functional capability to meet operational requirements in all respects.
)y
- f. Method for ensuring that maintenance, construction or modification activities, performed either on-site or off-site, are properly reviewed.
- g. ContiderMions for other activities already taking place in the general area.
6.11.1.4 Means.(for example, inspections, 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
- l. maintenance, modification, and construction activities.
- 6.11.1.5 A corrective maintenance program shall be developed to maintain structures, systems and components within the scope of this plan at I the quality required for them to perform their intended functions.
Corrective maintenance shall be performed in a timely manner to ensure that items within tne scope of this plan are adequately l maintained in the original, as designed, functional status.
l 66.0 3818L (12/88) l 1
l . _ . . . . _
7: ,
p ,
JU.a
- GPUNC OPERATIG EL QUALITY ASSURANCE Number I Nuolear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 Revision No.
R, Title 6.0 CONTROL OF STATION ACTIVITIES 2 6 11.1.6 A preventive maintenance program including procedurM as appropriate for structures, systems, and components within the scope of this plan l
- , shall be established which prescribes the frequency and type of main-tenance to be performed, In all cases, maintenance shall'be sche-duled and planned so as nM to compromise the safety of the plant.
Planning shall consider the possible safety consequences of con-current or sequential maintenance, testing or operating activities, e Preventive maintenance shall be performed in a timely manner to ensure that items within the scope of this plan are adequately l 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
&nd Technical-Specifications and procedures governing the design, ;
procurement, construction, testing and inspection. Modifications to >
structures, systems and components within QA Plan scope shall be reviewed and accepted in accordance with'the requirements of Section !
2.8 of this Plan, 6.11.l.8 Design, procurement, construction, testing and inspection of all modifications shall be performed in accordance with the applicable portions of this Plan. t 6.11').9 Upon completion of the design phase of a modification Technical Functions turns the project over to Maintenance, Construction and Facilities for installation of the modification with an engineering .
document package. Procurement of the required materials, parts and components is generally initiated by Technical Functions, but may be triitiated by other organizations as necessary.
Maintenance, Construction and Facilities prepares the necessary installation procedures or instructions consistent with the engineering requirements, completes the installation and construction y testing and compiles the records which it generated for record retention. Engineering problems identifled during installation shall be identified to Technical Functions for resolution using the appro.
priate 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. Witriess and hold points may be walved only with prior written authorization from the QA Department.
6.11.2 Responsibilities 6.11.2.1 Directors TMI Unit 1. and Oyster Creek The Directors of the nuclear generating stations are each responsible for:
- a. Estabilshing administrative control procedures for preventative i anc corrective mt >tenance consistent with the GPUN organlZation anc maintenance plans.
67.0 3BIBL (12/8E)
i t
.c .
r GPUNC OPERATIONAL QUALITY ASSURANCE Number Nuclear i M fM THREE MLE ISLAND UNM 1 AND OYSTER CREEK IM0-PLN-7200.01 Revision No, d Title 6.0 CONTROL OF STATION ACTIVITIES 2
)
- b. Ensuring that maintenance and modification activities are ,
performed in accordance with the requirements of this Plan and the applicable Operating License and Technical Speelfications, c .- Planning, scheduling, performing, directing and documenting )
maintenance consistent with the GPUN organization and maintenance plans. l l
Neb 11shing aduitnistrative control procedures for modification d.
,sork consistent with the GPUN organization plan. l l
i 6.11.2.2 Director Technical Functions 1 The Director-Technical Functions is responsible for:
- 4. Reviewing and approving the procedures which define the scope i and limits of responsibilities of plant engineering with regards j to modifications. l
- b. Ensuring that design and procurement activities associated with plant modifications are implemented in accordance with approved l procedures. .
- c. Controlling the drawings and specifications used for plant l modifications'. ),
- d. Preparing and issuing as-built drawings of plant modifications, as appropriate. -
j
- e. Ensuring that modifications are designed, procured and installed j in accordance with requirements which are either equal to or 1 better than the original requirements.
- f. Preparing and filing design, engineering and Technical Functions 1 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 i maintaining the associated drawings current.
l l
68.0 3818L (12/88) l
r - - -
.c 4) f '
b GPUNC-OPERATIONAL QUALITY ASSURANCE ' humber y+ Nuclear. 0^"oW"gfLEISLANDUNU1 MJLN4200M Revision No. '
Title 6.0 CONTROL OF STATION ACTIVITIES 2
. - - - , ~
L t f 11.2.3 Director - Maintenance. Construction and Facilities l The Director-Maintenance, Construction and Facilities, through the
-" applicable station Maintenance, Construction and Facilities Director.
is responsible for:
t
- a. Planning scheduling, performing, directing and dot.usenting [
. construction, modification and maintenance consistent with the GPUN Organization and maintenance plans. ,
l.
- b. Provicing the supervision and labor necessary to complete the assigned work.
- c. Ensuring that installation of a modification is implemented in conformance with engineering requirements. Deviations from engineering requirements are not authorized except as specifically approved by engineering in advance. QA review for concurrence is also required in advance if the deviation affects the inspect-ability or planned inspections of the installation (s) affected.
- d. Providing Technical Functions with the information necessary to prepare and issue as-built drawings.
- e. Preparing and filing installation records in accordance with the i QA Records requirements of this Plan.
,6.11.2.4 Director - Ouality & Trainino l '1 The Director-Quality & Training, through the Director - Quality !
Assurance, is responsible for:
- a. Reviewing installation and maintenance procedures or equivalent work authorizing documents to provide for the assignment of QA 5old and/or witness points to selected documents.
- b. Performing inspections and/or examinations required for the (
completion and acceptance of the installation.
i- c. Verify the appropriateness of 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 program 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 the scope of this plan j ,
will continue to operate, keeping parameters within normal bounds or will act to put the plant in a safe condition if they exceed normal l
, Dounds.
I- 69.0 3818L (12/88) l.
~ ~
GPUNC OPERATIONAL QUALITY ASSURANCE Number I L
Nahr ^" 'oa '""55 "I'5 2 5'^"o uMI T i AND OYSTER CRE(K iOOo-ptN-72oo.oi Revision No.
> Title 6.0 CONTROL OF STATION ACTIVITIFS 1 6.12.1.2 Provisions shall be made for performing required surveillance testing
- and inspections', including inservice tr$pections. Such provisions !
shall include the establishment of a Technical Specifications i l surveillance test *ng schedule reflecting the status of all planned '
L inplant surveillance tests and inspections. Frequency of surveillance tests and inspections may be related to the results of reliability analyns, the frequency and type of service, .or age of L the item or system, as appropriate.
6.12,1.3 a.dditional control procedures shall be instituted, as necessary, to '
, assure timely conduct of surveillance tests and inspections and L appropriate documentation, reporting, and evaluation of the risults.
- l. Procedures shall be. established to assure proper review of L surveillance test data and the return of systems to an operable L
status.following the completion of testing. These procedures shall include provisions for the documentation of authority, conduct, 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 THI Unit 1. and Oyster Creek T.
The Directors of the nuclear generating stations are each responsible for : -
- a. Providing the procedures, schedules and manpower necessary to l 1mplement the Surveillance Testing and Inspection requirements of the Operating License and Technical Specifications as applicable to the assigned unit,
- b. Ensuring that the requirements for Surveillance Testing and l Inspection are completed as required. I
- l. 6.13 Radiolooical Control 6.13.1 Recuirements 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.
70.0 3818L (12/88)
'--e m -r --
8 ,
5
. GPVNC OPERAi!ONAL QUALITY ASSURANCE- Number N I O ER C
~ ~
7 eifIfoT No, Title 6.0 CONTROL OF STATION ACTIVITIES 1
- d. Provide gyldance and specify appropriate methods or tecnniques to ensure that the performance of activities are in accordance with ,
sound radiological control principles and in compliance with applicable regulatory requirements.
- 6.13.1.2 The radiological controls program 15 to be fully integrated into the appilcable activities of each and every phase of operettons at the .
nuclear generating stations.
6.13.1.3 Procedures shall ta provided for the implementation of'the radiological controls program. These procedures shall contain the requirements fot implementation of the program by the Radiological Controls Department and the requirements for inclusion of.
radiological controls in the plant operation, 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 and evaluations for assessment and control of radiation conditions.
6.13.2 ' Responsibilities 6.13.2.1 Olvision 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 properly.
6.13.2.2 Director - Radiological & Environmental Controls The Director-Radiological & Environmental 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 dostmetry control, t
l 71.0 l 3818L (12/88)
1 GPUNC OPERATIONAL QUALITY ASSURANCE Number
. M 3 PLAP FOR THREE Nil,E ISLAND UNIT 1 IQO-PLN-7200.01 RNsN[ AND gYSTER CREEK Revision No, J
l Title 7.0 CONTROL OF RADIOACTIVE WASTE 2 !
- \
- 7.0 CONTROL OF RADI0 ACTIVE WASTE l 7.1 General 7.1.1 Measures shall be established and documented to assure that the ;
requirements of the Code of Federal Regulatione,, Title 10, Part 71 l Title 10. Part 20. and T!tle 6,' Parts 100 through 199 applicatJ 4 % j the packaging and transporting of radioactivs ustes are satisfied. j 7.1.2 -Subpart H to 10 CFR 71 identifies the quality assurance criteria appilcable to the centrol of radioactive waste. The portions of this Plan that relate to the criteria in Subpart H to 10 CFR 71 1 describe to a large extent the administrative controls and quality l requirements to be applied in the control, packaging and I transportation of radioactive material. A comparison of the l requirements of 10 CFR 71, Subpart H and the applicable sections of l this Plan are listed in Appendix A. These sections of this Plan 1 will be implemented to satisfy the requirements of Subpart H to 10 l CFR 71. ,
1 7.1.3 It is the policy of GPUN to minimize the generation of radwaste l materials consistent with the ALARA concept to minimize personnel exposures and environmental contamination. .
1 7.1.4 Title 10 Part 20, requires that'a quality centrol program be implemented to verify compliance with Title 10, Part 61.55 (Naste
'. ) i Classification) and Title 10, Part 61.56 (Naste. Characteristics).
This Plan will be implemented to the extent necessary to assure compliance with those Parts of Title 10 (using a graded approach.)
7.2 Reautrements 7.2.1 Procedures and administrative controls shall be developed and I implemented to cover the following: I
- a. Processing of radioactive wastes including the collection, handling and preparation for shipment of radioactive liquids and l solids. These procedures shall be consistent with the ALARA l program and shall clearly identify the administrative controls-l and organizational responsibilities.
i
- b. Training and qualtftcation of personnel operating radioactive !
waste processing equipment, health physics monitoring, packaging and shipping (which includes Waste Classification and I establishment of Haste Characteristics) and other operations l deemed appropriate by management.
i 72.0 i 3688L (12/88) I
__.__..__,,__.___J
u j ,
-]
i
. GPUhc opt 4ATIONAL QUAL 11Y A550RANCE '
Number f#imNuolear 5'*"'"" '
us"0%"ElltF' ,
Revision No. '
Title 7.0. CONTROL OF RADI0 ACTIVE #5TE i
1 )
. c. The' activities assottated with the packaging of radioactive wastes to include the proper selection of the receptacles to be f Used for containing the waste materials, the selection of the !
shipping containers (structures used to contain and support the receptacle and its contents) establishment of Waste !
Characteristics, Radiological control inspections of the packaging prior to release, proper markings on the outside of the package and the preparation of shipping papers and l certificates. The activities shall be in accordance with !
I' a 10CFR20,10CFR71, and 49CFR.
O. Movement of redloactive materials within and outside the i protected area to assure personnel protection at all times.
l,
- e. The shipment of radioactive material from the Station to be in i accordance with the regulations of the U.S. Department of !
Transportation for the transportation of hazardous materials l (49CFR) and of the NRC (10CFR71 and 10CFR20).
- f. The packaging used for transporting of radioactive wastes, whether purchased from an outtide supplier or designed by GPUN, [
shall meet the applicable requirements of 10CFR20,10CFR71 and
, . 49CFR.
- g. Minimization of the gen 6 ration of radweste materials through j training programs, prudent scheduling and use of equipment and -
personnel and good housekeeping practices. t 7.2.2 The carriers to be used for transporting of radioactive wastes shall be selected on the basis of their expertence, knowledge of DOT regulations, control and maintenance of their equipment and the selection and control of their drivers. The carrier is required to i 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 operations shall be controlled to minimize personnel exposures or environmental contamination consistent with ALARA.
7.2.4 Operations procedures relatiht to radweste shipping and packaging l 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 TMt Unit 1. and Oyster Creek f.
Thi 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 waite and me.ement of radioactive materials. These procedures $nall include the following:
73.0 36 BBL (12/68) 4
- . , . . . . . . . , , . . , . . . . _ . c,,_,,w-e,, , ,_ - . . . . . - _ . , . _ _ . . . _ , _ . . . _ _ . _
e >> .. ,
I GPONC OPERATIONAL QUALITY ASSURANCE Wumber f fGINuolear %"J "J"E!l#" """""" ' " "
Revision No.
l l
Title 7.0 CORTROL of RADIDACTIVE WASTE 2 ' .
- a. Training of personnel in the mthods to alniette the generation f of radweste materials. }
- b. Processing and packaging of 11guld and solid wartes,
- c. Collection and identification of radioactive solids such as :
rags, papers, boots, gloves, etc. and have them moved to the l Radweste facility for packaging. .j
- d. Selection of the proper packaging for the specific contents to f be shipped, taking into consideration the radiation levels, i' contamination Ilmits 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, completes the shipping papers / manifests and certificates, attaches the security seal :
- nd advises the carrier that the shipment is ready. !
- e. Review and acceptMce of carrier procedures specified by the l procurement documents covering the acceptance of radioactive ,
waste materials for shipment. l
- f. Review and acceptance of the designs of packaging purchased from an outside suppiter. ;
7.3.2 Director - Radioloatcal & Environmental Controls ;
The Director - Radiological & Environmental Contr'ols 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. ;
7.3.3 Director - Ous11ty & Trainino
, The Director - Quality & Training is responsible through the Director Quality Assurance to monitor, inspect and audit radioactive i waste processing operations and redloactive material packaging and '
shipping to the extent necessary to verify they are performed in i accordance with e:tablished procedures, app 11 Cable administrative i controls and regulatory requirements.
7.3.4 Responsible Department Manaaers Each manager shall establish the requirements for personnel qualification and institute training and indoctrination to satisfy these recuirements. Training requirements shall be connensurate with the importance and complexity of the activity performed.
74.0 3688L (12/88)
GPUNC OPER4t!0NAL QUALITY ASSURANCE l Number
"'"" 2 o '
DI"81 Nuclear h^"JN*nl#'t 5 '* """ " '
Revision No.
Title 8.0 Control of Corrective actions and Nonconformances 2 8.0 CONTROL OF CORRCCTIVE ACTIONS AND NONCONFORMANCFS 8.1 General
,, 8.1.1 Nonceaforming materials, parts, components, services or activities within the scope of the GPUN Quality Assurance Program shall be identified and contro11e1 to prevent their inadvertent utilization.
Measures shall be established which ensure that conditions adverse to quality, such as failures, malfunctions, defletencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. The cause of significant cond'tions 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 eefined deficiency and/or nonconformance reports. Such defletencies are typically those which are isolated to singular occurrences, not repetitive in nature, and/or are such that appropriate action to prevent recurren:e can be initiated at the time the deficiency is identified and do not require any action other than reporting the
, occurrence. Such deficiencies, when discovered during verification j activities, shall be documented in the report of the verification activity. Such deficiencies shall be analyzed as specifled by Subsection 8.2.8.
[ 8.2 Recuirements l 8.2.1 Nonconformances include both hardware problems involving materials, parts, components or systems which do not comply with estabitshec 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 tee responsibility of all organizations and individuals involveo with the TMI-1 and Oyster Creek Nuclear Stations to identify and report all nonconformances that affect structures, I systems, equipment, materials, parts and components within the scope of this plan. 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.
75.0 3898L (12/88)
I
- l GPUNC OPERATIONAL QUALITY ASSURANCE Number ;
fMINuclear %"JfM"!!!!" '5'*" """' " "" 2 * '
l Revision No. l Title 4.0 Control of Corrective Actions and Nonconformances 2 !
8.2.3 Activities such as examinations or checks performed to assess the l condition of equipment or its operation are not considered to be i nonconformances until it has been determined that it does not comply !
with established acceptance criteria. These activities shall, i however, be documented on an appropriate form to control the !
activity. Once it has been determined that a nonconformance outsts !
the condition shall be reported as a nonconformance and the item ;
controlled to prevent inadvertent use prior to correction.
l 8.2.4 Procedures shall be established which detail and implement the '
following corrective action system measures: !
i
- 4. Conditions adverse to Quality shall be evaluated to determine the need for corrective action. i V
- b. Corrective action documentation of significant deficiencies shall ,
l Include identification, cause, and actions taken to correct and !
i to preclude the stellar recurrence. QAD concurrence is required !
for corrective action disposition for all QA0 identified f nonconformances, i
- c. Follow-up activities shall be conducted to verify implementation i of corrective actions and to close out corrective actions in a timely manner.
l
- d. Significant deficiencies, nonconformances and defects which are i i t potentially reportable to the NRC shall be identified to !
l appropriate management levels for evaluation.and reporting to
- the NRC. as appropriate. ;
8.2.5 Procedures shall be established which detall and implement the recutrements for identification and control of nonconforming items and activities and for the identification of the cause of the i conditions and the actions to be taken to correct the conditions to ;
prevent recurrence. These procedures shall include requirements for :
i the following: l l t
- a. Identification of the form to be used for reporting the i i nonconformance,
- b. Description of the nonconforming item or activity and date of identification.
- c. Identification of the initiator of the nonconformance report. !
- d. Description of the nonconformance, including identification of '
the requirement violated.
t
- e. Identification of nonconforming items by appropriate means (tags, labels, etc.) and segregation, if practical, until disposition of the nonconforming item has been determined.
76.0 3898L (12/88)
.._..-,...-.,._-'_-._n-.. - . , ~ . - . , . . - . , , . . , . .
l 1
GPUNC OPERATIONAL QUALITY A$$URANCE Number l NINuclear %"JfM"nl#" """"" ' ' "-
Revision No.
i Title 4.0 Control of Corrective Actions and Nonconformances 2 l
1 j
- f. Disposition of nonconformance. The disposition shall be determined I by the organization responsible for the nonconformance. Rework !
and scrao dispositicas are made by the material user without ;
engineering review; use-as-is and repair dispositions require j concurrence and justification of cognizant engineering !
organizations. QA concurrence is required for all dispositions. l
- g. Notification to the affected organizations of the nonconformance,
- h. Verification method, verification and close out.
- 1. Record retention. )
- j. Required approval signatures of the disposition and the I
verification. ;
i
- k. Evidence of review for reportability to the NRC. j t
8.2.6 Reworked, repaired, and replacement items shall be inspected and l tested in accordance with the original inspection and test j 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 i on further testing or operetton and shall be dispositioned as appropriate. The evaluation / disposition shall be documer,ted. ;
8.2.8 Nonconformance reports and those deftetencies addressed in 8.1.3 thall !
be periodically analyzed to detect adverse trends as may be present. l Such analysis will be based upon severity, number, frequency of :
nonconforma4ces, the causes of the nonconformances and the timeliness !
of the reperting and resolution of nonconformances. The results of analyses 5%411 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, sur.h as a generic L
, problem identified by the trend analysts or repetitive failure to disposition nonconformances, these problems shall be elevated to upper ,
levels of management for resolution. !
8.3 ResDonsibilities l 8.3.1 Director - Quality & Trainino l l
l The Director - Quality & Training through the Director - Quality l Assurance is responsible for the following:
- 4. Review and concurrence of all procedures for reporting and controlling of nonconformances for compilance with the ;
requirements of this Plan.
77.0 3B98L (12188)
,y_,-- - - - - . -, ----,,-,r
, -,,-.-y...,-r--,.,--,-n,.,-,_,,-wa,-,,,,,,-,__,,,r
--m , , , , , -
GPUCC OPERATIONAL QUALITY ASSURANCE MNuclear Number us"JntPslJ'" '5"""" ' '" ""2
- o' Revision No. '
Title 8.0 Control of Corrective ~ Actions and Nonconformances 2 ) l l
8.3.2 Director TN! Unit I and Oyster Creek
}
The Directors TMI Unit I and OCNGS are each responsible for ensuring that nonconformances are reported and corrected for all activities within the scope of this plan. Plant items such as fattures. (
l t malfunctions, deficiencies, deviations and defective materials, ;
parts or components are handled in a manner consistent with their importance to nuclear safety and reviewed in accordance with , I appre,ariate procecures and the applicable Technical Specification. l 8.3.3 Responsible Denartment Manaaer i 8.3.3.1 fach Director / Manager is responsible for the disposition 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 i 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 identified and controlled in ace.ordance with approved procedures.
)-l I
?
t 78.0 3898L (12/88) l
i l
i GPUNC OPERATIONAL QUALITY ASSURANCE Nuolear Pu N r0R TNR u m u iS u Mo unit i AND OYSTER CREEK Number imosa-nx.oi i
1 Revision No.
Title:
9.0 CONTROL OF TRAINING 2 i s
l 9.0 CONTROL OF TRAINING 9.1 General i
)
GPU Nuclear is committed to the safe operatic <n of its nuclear !
generatinq stations and the protection of the public health and i safety. "his commitment is accomplished, in part, by developing er l maintaining the knowledge and skills necessary to manage, supervise, 1 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 j avoiding performance problems. Therefore, training shall be i provided as determined to be necessary which develops, maintains and '
supplements the skt11s and knowledge necessary to perform activities i within the scope of this Plan, ,
r Training shall be based on training need assessment. The edtent to -
which prior education, training and experience is sufficient to I provide for the requisite job proficiency will be considered in i 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 Recutrements
)
9.2.1 Programs accredtted by INPO shall be developed and maintained in ,
accordance with a Training System Development (TSD) 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 .
l performance requirements. '
{ 9.2.2 The training programs associatad with Radiation Worker, Respiratory ,
Protection, Emergency Preparedness, Fire Protection, and Security ;
Force Training shall be inlemented and conducted by training plans and procedures comparable with the GPUN TSD process. The depth to which the process is applied may vary from program to program, but the implementation and conduct of training will be based upon behavioral learning objectives which are 11nked to job performance I requirements, i
, 9.2.3 The documents 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 commitments are incorporated.
, 79.0 l 4162L (12/88)
_i _
L GPUNC OPERAff0NAL QUAL 2TY ASSURANCE Number Nuolear PtAN r0R TNREE aitE 15tANo unit i AND OYSTER CREEK iooo-PtN-Troo.0i i
(
Revision No. i
Title:
9.0 CONTRC6 0F TRAINING 2 j i
9.2.4 Technical content review and interface process shall be estabi' 'ed i between the user department and the Training and Education Dep tment i to assure programs accredited by INPO and the Rattiation Worker, !
Respiratory Protection. Emergency Preparedness Fire Brigade, and i Security Force Training Programs are updated to reflect job l performance, plant modifications, procedure changes, regulation i changes, and job scope changes.
l 9.2.5 The review and approval of the specific training program documents l 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 l
procedure (s) or plan (s).
9.2.6 Procedures shall be established for the qualification and f certification of instructors for programs accredited by INPO and the '
Radiation Worker, Respiratory Protection, Emergency Preparedness, !
Fire Brigade, and Security Force Training Programs.
9.2.7 To assure the integrity of qualification proce;ses which utilize ;
examinations, procedures for the control of examinations shall be used to address examination security. i
\
9.2,8 A program and course evaluation process (s) shall be used to evaluate ) ';
the effectiveness of training programs and courses in meeting i 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).
9.2.9 Procedures shall be established to assure that all required records '
l associated with training provided within the scope of this Plan l shall be identified, generated, maintained, and retrievable. These i training records shall be suffletent to provide evidence of the !
content and objective of the training provided, attendees, and date ,
of attendance.
9.3 Responsibilities 9.3.1 The Director, Quality and Training is responsible 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 assigned duties and to meet corporate policies, applicable laws, regulations, licenses, and technical requirements. Specifically, the Director, Training and Education, shall be responsible for the establishment and maintenance of a training organization to:
80.0 2162L (12/88)
1 GPUNC OPERATIONAL QUALITY AS$'JAANCE Number IENuolear %"al"nl#" '5"'"" ' ' *o-"-'2
- o' Revision No. j ftt1e: 9.0 CONTROL OF TRAINING 2 j i
- 4. Manage the training function consistent with regulatory l requirements and commitments corporate priorities, and the !
Training and (ducation Department TSD Process. j l
- b. Provide personnel with training which supports the development and '
maintenance of knowledge and SAllis required to perform activities .
within the scope of this Plan in a manner that will ensure the i safe and effective execution of their duties,
- c. Assure that the content of training provided by ths Training I Department is consistent with and incorporates appropriate GPUN.
local state and federal regulatory requirements and commitments, including timely requalification, i
9.3.2 Department Directors and Managers are responsible for assuring that i their staff members are qualified to carry out assigned activities i within the scope of this Plan. Training activities performed under their direction shall be performed consistent with the requirements of l i this Section of this Plan.
i f
l F
l 1
l t
I l
i l 81.0 l 4162L (12/88)
)
i GPUNC OPERATIONAL QUALITY ASSURANCE Number -
fTd71 Nuclear %"0SJ"slEf" '5"""" ' ' ""'"' !
~
Revision No. !
Title:
10.0 AUDITS 2 .
j 10.0 A@Hj i 10.1 General l
l A comprehensive and documented audt t system shall be estab11thed, l tuplemented and maintained to ensure that:
li
- 4. Plans, procedures and instructions define suffletent organtra- l tional responsttt11ttes, prescribe methods and provide results :
consistent with Operating License requirements, other regulatory i requirements and commitments, technical requirements, contractual (
requirements and this Plan.
- b. Plans, procedures and instructions are effectively implemented. ;
- c. Corrective action systems and management reviews provide for timely completion of requisite action for identified deficiencies /nonconformances/ occurrences / events. j
- d. Corrective action systems and management reviews provide )
effective identification and prevention of recurrent and/or >
significant program nonconformances. I !
- e. Data is provided for GPUN management to optimize the efficiency of methods utillred to ensure regulatory compitance. *
- f. Data is provided for the continuing assessment of the effective- !
ness of all elements of the GPUN Quality Assurance Plan and >
1mplementing documents.
3 10.2 Recutrements ,
10.2.1 A comprehensive system of audits shall be estabitshed 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 j
. following: '
- a. eperating License conditions. Technical Specification '
requirements, other regulatory requirements and commitments and
! the requirements of this Plan,
- b. Regulatory Guides, ANSI Standards, and other codes and standards !
as endorsed by Appendtx C of this Plan or other regulatory '
requirements or commttments. y l
82.0 3899L (12/55) ,
.--,,,,mm-n.,--,n-r,n,,m,------, ,,,.,,,,,-,--n-.
w,-. g-,-
i I GPUNC OPERATIONAL QUALITY ASSURANCE Number I N es PLAN FOR THREE MILE !$LAl0 UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01 !
Revision ho.
Title:
10.0 AUDITS 2 s
s
- c. Documents which prescribe methods and provide the technical requirements for activities or items within the scope of this Plan,
- d. Contractural requirements associated with enternal organizations l providing nuclear fuel, in-core components and selected technical i support and engineering services within the scope of this Plan. !
10.2.3 The audit system shall include- 1
(
- a. Dellneation of the authority responsibility, and organizational j incependence of those responsible for the management and conduct !
of audtt program. I
- b. Procedure (s) for the Qualtftcation and certification of lead auditors.
I i
- c. Procedure (s) for the scheduling, preparation, performance. l reporting of the results of audits, and distributton to appropriate levels of management. ,
- d. Periodic analysts of audit results and the reporting of such .
results to appropriate levels of management. >
i
- e. Follow-up action to be taken based upon Individuai and !
collective audit results.
10.2.4 The frequency of concucting scheduled internal audits shall be as :
specified in the nuclear units' Technical Specifications. :
Unschedulto 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 concucting external audits of selected suppliers of [
technical support, environmental monitoring, radweste shipping, computer, 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.
l 10.2.6 Each audit shall be led by & GPUN certified lead auditor. Audit '
team members shall be uttitzed as required and will be classified as either auditors or technical specialists, depending on their function on the audit team. ;
t 10.2.7 Those GPUN and esternal organizations providing items and/or conducting activities within the scope of this Plan are subject to audit consistent with the requirements of this Plan. ,
83.0
?B991. (12/BS)
GpVNC OPERATIONAL OuALITY ASSURANCE Number rGINuolear us"0SJ"(HJ'" 25'^"
u"" ' ' * '"-'200.0i Revision No.
Title:
10.0 AUO!Ts 2 -
10.2.8 Audits shall be performed in accordance with pre-estab11thed written procedures or checkItsts. The personnel uttilzed 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 sufficient detail to i determinetheappropriatenessofthedocumentsforuse,effectivenessj of implementation and the effectiveness of actions taken to correct i previous nonconformances.
10.2.10 Audited organtrations shall provide sufficient support to assure the l accuracy of the audit results, review and response to audit -
nonconformances, and effective resolution / prevention of deficiencies. .
The corrective actions required to resolve adverse audit findings shall be defined and impiegiented in a timely manner.
10.2.11 Audit finding nonconformances shall be followed up in a timely manner. Such aeverse audit findings shall typically not be closed until the effective implementation of corrective action (s) is vertfled.
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, checkIlsts, or equivalent). Audit reports, lead auditor certifications, followup and verification and s .
results of periodic analysis of audit results. l l 10.3 Aescons'ibili ties 10.3.1 Director - Quality & Trainine i
The Director - Quality & Training is responsible through the l 1 Director - Quality Assurance to:
l o a. Establish anc implement the audit program and assure all required areas are audiced.
I
- 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 audtt schedule.
- e. Analyze the results of audits for quality trends and inform the Office of the President and the affected Divtston Director of the results.
84.0 3899L (12/5S)
GPllNC OPERATIONAL 00ALITY ASSURANCE Number DTINuolear u^"JaiqlJ2'r 25'^* ua2i i iac-Pt"-n*. oi Tttie: 10.0 AUDITS "'['"** !
10.3.2 Director (s) - Audtted Orsantration(s) j The Director (s) of the audited organization (s) are responsible '
through Directors / Managers to ensure:
- a. Sufficient support is given to the audit process to optimize the accuracy of the audtt results, ;
- b. Sufficient review of audit results is provided to assure that i effective preventive measures for audt t nonconformances are 1 defined and implemented.
I l
- c. Responses to audit findings are reviewed and approved by their !
organizations prior to submittal to the auditing organization.
]
- d. Responses to audit finding are submitted to the auditing 1
organtration in a timely manner as defined in implementing ]
plans, procedures and/or instructions.
4
- e. Corrective action to resolve audit findings are taken in a timely manner. l 8
1 h
i I
85.0 l 3899L (12/65) 1
f
' GPUNC OPERATIONAL QUAL!TY ASSURANCE Number Nahr *" 'o" '"att "2't 25'^"
AND OYSTER CREEK u"2' ' ' oo-"-72oo o' i
Revision No. (
litle Appendices 2 l APPENDICES f
l APPEN0!X A Comparison Chart of Operational Quality Assurance Plan l Requirements with those of various parts of the Code of '
Federal Regulations and Nuclear Industry Standards i APPEN0!X B OAD Documents Review Requirements !
t APPENDIX C NRC Regulatory Guide Commitments and Exceptions ;
APPEN0!X 0 Terms and Definitions i
i i
s f
f i 4 S
3 4
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l 86.0 3900L (12/88)
(
GPUNC OPERATIONAL QUALITY A$$URANCE Number Nuolear u" "mtt a2't 25u"o va!' '
'4 OYSTER CREEK A
i o*- a- n * . o' Revision No.
Title Appendices 2 A
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GPUNC OPtRAT104AL QUAL 1TY AS$U4ANCE Number ff51Nuolear ured"n!#" """""" ' ' * '*"* " j t
Revision ho.
Title Appendices - 2 I
i 1
APP (NDIX 5 CAD Documents Review Renuirements
)
QAD shall selectively review documents which prescribe methods to l 1mplement activities within the scope of this Plan or provide the {
quality and/or technical requirements for items, parts, materials ;
and activities that are within the scope of this Plan. The purpose of such reviews is to verify that such documents are consistent with the requirements of this plan. The minimum content of 4 OA document review, as appropriate to the document reviewed, is provided in Subsections 3.1.2. 4.3.3. 5.1.2.3.(e) and 6.2.2.2.(b) of this Plan.
The types of documents typically reviewed include plans, procedures and instructions. procurement documents; work authorizing documents. ,
and changes; etc. Refer to Section 3.2.2.1 for specific types of I l documents which will periodically be verified by QA document review. )
i 1
QA review of documents within the scope of this plan may be conducted l before or after the documents have been approved for use. Further-more. QA may review all or a sample of specific types of documents within the scope of this plan.
The timing and scope of the QA l reviews siiall be based on the technical and administrative adequacy t of'the documents produced without QA review for concurrence, j A QA Department procedure approved by the Director, Quality '
Assurance, shall prescribe the process for measuring the adequacy of ,
documents. produced without QA review for concurrence. This measure shall be based on the comment types and rates resulting from QA reviews of such documents. The procedure shall include requirements -
for maintaining a database sufficient to provide for the measurement +
of adequacy. The procedure shall also prescribe periodic adjustments in the timing and scope of QA reviews of specific types of documents .
based on their measured technical and administrative adequacy. ;
This procedure (s) will also ensure that QA reviews of documents be consistent with the following- t i
, o Some plans, procedures and/or instructions are required by this 00A plan to.be " reviewed for concurrence" by the Director of QA. ;
Such documents and changes shall be reviewed by QA prior to teolementing approval. Other plans, procedures, and/or instruc- r tions and changes thereto may be reviewed for concurrence by Quality Assurance. These documents shall be identified on the 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 by the Director-QA prior to implementation of the change.
- o Procurement, maintenance and installation documents and changes shall be reviewed as appropriate by QA prior to authorization for use to provide for the inclusion of inspection hold and witness points.
88.0 ,
4 3900L (12/88) a.-.-.-- __ - -. _ - _ - . - _ _ - - . -
t
[
GPUNC OP(RATIONAL QUALITY ASSORANCE i Number i ITimNuolear %"JfM"slJ'" 25'** u"" ' ' o*-"d 2
- o '
l Revision No. t Title Appendices 1 APPENDIX C [
00ALTTY A5 FURA 66:t PROGRAN^
RR: REGU .ATORY GUIDL !
CCpt ITME 4T5 Al i JXCET ONS !
i This Appendix identifies those Regulatory Guides which contain j Quality Assurance Program requirements and identifies the GPUN j positions relative to compliance. Part I of the Appendix is a tabulation of the Regulatory Guides the corresponding ANSI Standard :
and Remarks. Alternatives or clarifications are detailed in Part 2 of the Appendta.
1 Compliance wtth these Regulatory Guides will apply to i modifications, additions and activities performed af ter issue of :
this QA Plan and does not imply backfittimg and/or retroactive !
compliance. It is also to be recognized that existing plant :
conditions, may prevent or preclude the satisfaction of all 5 requirements of a specific Regulatory Guide. These conditions will ,
be documented and, along with the justification, will be approved '
by the Director - Quality Assurance. l
> r l
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89.0 3900L (12/88) e
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a 3 See attacted comments. K ;
1.26 2/76, s ee. ) 94 Classificettens and Standeres e seedtfted See attached commients. **
For esoter Strees and modtoecttee teoste Centeentne Components of r ewCleer Pouer Plants t.2e 2/79. eev. 2 Ouellty assurance Preersmi meestrements (Sesten and mes.2 1977 f=11 Cemeir =tth seculetery positten. N Constructten) i 1.29 9/78. see. 3 Selsartc Sesign Classificetten tendifled Same comment as for nee. Gulde 1.26
' 1.30 8/98/72 04 seestrements for t0ee Install. e45.2.4 O-< m Xb 8972 seed 6fted See attached comuments.
i i
actlen. Inspectlen and Testtae of Instressentatten and ElectrScal QQ m m j
e EowIsment myg o zu, e O .
3.3t 4/78. eev. 3 Centrol of Ferrite Centent in so m w o 5tainiess Steen imid netal f 11 Comply =6th secesistory Positiest. '
s I.33 n 3 ,_ .
2/78. eev. 2 Gueltty Asseprence Programe ets.7 e i
noeutrements (Sporetten) 8976 sendtf6ed See attached comments.
1
.E
! i.37 3/16/73 ver-04 seewirements for Cleenine of #45.2.1 1973 seedified l
' Field Syste'"s and Asseclated Ceepenents of taster Cooled See attached comessets. C2c i
i i
nuclear Pouer Plants >
{ t.38 s/77 ee 2 ga seguirements for Paceraetne, 5$
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5 . spine. meceivino. St.r.ec and e45.2.2 3972 sendifled See ettsched comments.
- *{
j tlanellas of Itdes for nGeter Cooled aucteer romer Plants g
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i t.39 9/77. eev. 2 seemseeroepsne seemtrements for e95.2.3 1973 studtfied See attacteed comuments.
taster Cooled.mucieer Pomer -
Plants
. se
- a l.54 6/73 04 nogetrements for Protective
- 898.4 1972 sendt fled Coettnes Asplled to taster See attactied : w s. "**
~
' Cooled nuclear power Plants o' 7'
- P *
- 4.58 9/99. Rev. 1 - Guellf tcet tens of teucteer Pe=er feel. 2. 6 1978 feedified y n Plant Inspectiere. Ewantr.atten See attactied comments. O M and Testing Personr21
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g Power Plants W t.74 2/79 Guellty Asserance Terms and #95.2.89 1973 Full Camely =4th segulatory positten. "
j Sefinttlens
' v.se se/76. eev. 2 Collectlen Storpse and sesen.
Q we nes.2.9 1979 Seedifted See attached commsents.
tenance of muc1eer Pomer Plant Gueltty Assurance Socords I
1.94 4/76. Rev. I SA Seestrecents for Instal- #45.2.5 1979 7eedified I
' latten. Inssettlen and Testino of See attached comuments. N Structural Centrete 4 Steel
- durtne eucleer Pouer Plant ,
Construct 4en g ,,
i I
t i n 5/77. eev. 0-# 04 Seemtrements for Instette- ees.2.s 4975 seedified O n tien. Insaection and Testine of See attached comments. y' seechenical Egwisment and Systems -* N
- . i. m nFF. o...i en me. wire ents F.r Coatr. .f =95.2.i3 I m seediried see attached co e ts.
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Procurement of Items and Sere-Ices for sauc1eer Power Plants Q==
mm l 8.142 te/St. Sev. I Safety-Welated Concrete struc- #45.2.5 Q2- r-4 1974 9eedified See attached ces-ents.
l tures for leuclear Pomer Plants Ae56.4 1977 C (Other then aractor inessels aCI3te t977 and Contas.=entsi 5 ,_
1.143 19/79. Sev. I testen Gestdance for endteettive - 7- e i l seedsfled see attached comments. = -c
- ndeste Ieenagement Syst @_. l o Struct res. and C - s C Installed in Lleht-ndeter- s.p Coeled nucleer Pomer Plants y t
- t. net s/79
. Weoutrements for Austtias of 495.2.32 8977 seedifled Suellty Assurance Freerans for See attached comments. m i
Nucleer Pomee Plants I
- 3 . 3. .,
- 1,f c.tten ~ ,..y ,.2.2, ,,,. ..,,
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1 GPUNC OPERATIONAL QUALITY A$$URANCE Number fEf1Nuolear u^"JfMan!J'"
'5'^*"" ' "'"d2 o '
Revision No, l T1 tie Appendices 2 i
l l
APPENDIX C - PART 2 l NAC Reculatory Guide 1.8. Rev. 1-R. May 1977 i
Personnel Selection and Traintne i
Guidelines have long been estabitshed in the company with respect I to awarding jobs to plant attntenance, operations, and other bargaining unit personnel who may be involved in testing, examination and inspection activities. Personnel are qualtfled in i accordance with the Job Description Manual. GPUN believes that the requirements specified in the 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 qualified by GPUN because it feels the Individual is capable of performing a job even though the individual does not meet the detailed guidance contained in ANSI 1 N18.1 with respect to length of experience and formal training. ]
The unit staffs and the corporate organizations have been upgraded to meet ANS!/ANS 3.1-1978 except as otherwise noted in the i Technical Specifications.
NRC Regulatory Guide 1.26. Rev. 3. February 1976 Quality Grove Classification and Standard for Water. Steam and Radioactive :
Waste Containino Components of Nuclear Power Plants !
Since the original design and construction of TNI-I and Oyster Creek was to different classification criteria than contained in this gulde; GPUN will comply with the regulatory position of this -
guide with the following clarifications:
- 1. For modification to existing plant systems, items will be classified by Technical Functions according to the original design basis or this guide. This classification will r,ot degrade the safety of the system being modified.
- 2. Addttions to existing plant systems will be made to the same !
cose, standard and technical requirements which 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 addition will not degrade the !
safety of the system being added to.
1 3. For new construction, the latest applicable code will be :
utt112ed unless such uttitration would result in hardship or !
unusual difficulty without providing an equivalent level of safety.
92.0 3900L (12/88) '
GPUNC OPERATIONAL QUALITY ASSURANCE Number f331 Nuclear %"JfM"N#" 25"'"" ' " "-'2 '
Revision No.
Title Appendices 2 APPENDIX C - PART 2
)
NRC Regulatory Guide 1.30. August 1972 Outlity Assurance Recutrements for the Installation. Inspection and Testino of !
Instrumentation and Electric Ecutoment !
GPUN shall comply with the Regulatory Position established in this l 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 .
recuirements associated with maintenance and modifications shall be the !
original technical requirements or better (e.g., code requirements. l material properties, design margins, manufacturing professes, and Inspection rtoutrements).
i Sections 5.2 and 6.2 of ANSI N45.2.4 list tests which are to be conducted i during the construction phase. In lieu of this, GPUN utillfen its !
Engineering and/or Maintenance organizations to establish the need for ;
specific tet.ts or test procedures during the operational phase. ;
NRC Regulatory Guide 1.33. Rev. 2l February 1978 Ouality Assurance Program Recutrements (Operation)
The GPUN QA Program complies with the regulatory position of this guice with the following clarifications: !
- 1. Regulatory Position C 4 of the regulatory guide i
The frequency of performance and the minimum topical coverage of l Internal audits will be consistent with Section 6 of the nuclear units' Technical Specifications. Parag aph C.4.a is interpreted to mean audits will be conducted once each 6 months to verify that the nonconformance and corrective action program is propetly 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 paragraph refers to the compilation of a "sumary 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
" Operational Quality Assurance Plan for Three Mlle Island Unit 1 and Oyster Creek" is the " summary" document required, Appendix A l correlates the sections of this Plan to ANSI 18.7 1976. Section 2.0 provides the " consolidated" base and description for the program.
Implementing documents are identified in Section 3.0, are reautred to be consistent wtth this Plan and Appendir C of this Plan, and are ,
marked as stated in Section 3.0.
93.0 3900L (12/88)
l r
GPUNC OPERATIONAL QUALITY ASSURANCE Number I
%a h
ENuolear .
us"JN"s!!" '5"* """ ' " '"-72
- o' Revision ko.
l t titie ,,,en. i c. s 2 .
i 1 l
[ -
APPENDIX C - PART 2 .
l 1
- 3. Paragraph 5.2.2 of ANSI N18.7-1976 titled " Procedure Adherence" y In accordance with Section 6.8.3 of both the Oyster Creek and TMI-1 )
7 Technical Specifications, temporary changes shall be approved by two j members of GPUNC Management Staff quellfled as Responsible Technical '
Reviewers and knowledgeable in the area affected by the procedure. l For changes which may affect the operational status of facility l r systems or equipment at least one of these individuals shall be a J member of factitty management er supervision holding a Senior Reactor i Operator's License on the facility. !
l 4, Paragraph 5.2.8 of ANSI N18.7 - 1976 titled " Surveillance Testing and !
Inspection" J In lieu of a " master surveillance" schedule, a technical ,
specification surveillance 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 AN5! N18.7 - 1976 titled " Review. Approval and Control of Procedures" .
l The third sentence of the third paragraph is interpreted to mean appitcable procedures shall be reviewed following a reportable ,,
incident such as an accident, an unexpected transient, significant 1 operator error, or equipment malfunction. ,
- 6. Paragraph 5.2.17 of ANSI N18.7 - 1976 titled " Inspections" Not all inspectfons 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 l record; however, records of inspections will be identified and l retrievable. l 4
e I
! I i
1
!i 4
I l
i 94.0 i 3900L (12/88) l
!i GPUNC CfcRATIONAL QUALITY ASSURANCc Number j MNuclear %"o@c!" sic" 25* """ ' 'o*-"-720o oi i l Revision No. I Title Appendices 1 l
APPENDIX C - PART 2 NRC teaulatory Guide 1.37. March 16. 1973 l
Quality Assurance Recuirements for Cleanina Fluids Systems and Associated 52mponents of Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with the regulatory position of this guide with the following clartftcations:
- 1. The second sentence of paragraph C.3 should be amended to read:
l "The water quality for final flushes of fluid systems and associated components shall be at least equivalent to the quality required for normal operation. This requirement does not apply to disolved osygen or nitrogen limits nor does it infer that chromates or other )
i additives normally in the system water will be added to the flush water." !
d l 2. Paragraph C.4 should t,e amended to add: I l
Material such as inks, temperature indicating crayons, labels, ;
wrapping materials (other than polyethylene), water soluble J materials, lubricants. NOT penetrant materials and couplants, which J contact stainless steel or nickle alloy material surfaces shall ,
contain no more than trace elements of lead, zinc, copper, mercury or i i other low melting alloys or compounds. Maximum allowable levels of water leachable chloride tons, total halogens and sulfur compounds ,
L shall be defined and imposed on the aforementioned materials. j
- 3. Section 2.1 of ANSI N45.2.1-1973 states that required clanning is i t
frequently performed on a generic basis for appilcation to many installations on one or more projects. This results in standard procedures or plans for installation and inspection and testing which .
i meet the requirements of the Standard. Individual plans for each l ttom or system are not normally prepared unless the work operations are unique. However, standard procedures or plans will be reviewed for eppilcability 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 1s !
l consistent with Section 11 Paragraphs 2 and 3 of ANSI N45.2-1977 .
l which provides for examination, measurement or testing to assure i
q.,ality or indirect control by monitoring of processing methods.
However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.
95.0 3900L (12/88)
GPUNC OPERATIONAL QUALITY A$$URANCE ' Namter
{
fMN1 Nuclear n^"0W"W'" 25""""" ' "*'"o200. 0 i i
Title Appendices "
APPENDIX C - PART 2 4
GPUN Intends to conform to the Cleanness requirements of Section 3.1 of AW51 M45.2.1-1973 with the exception of permissable particle stres for cleanness Classes 8 and D. In these cases GPUN will conform to the requirements of AN51 N45.2.1-1980, Section 3.2.2.1(b) which states, long (0.8"These inn b shall be no particles lar9er then 1/32 in, by 1/16 in.
t
)
which states, y" 1.6 mm)" for cleanness C' ass 8 and Section 3.2.4.4 i Particles no larger than 1/16 in by 1/4 in. long (1.6 1 mm by 3.2 mm) on a 14-mesh (1.4 mm. ASTM E-11, Specification for Wire Cloth Steves for Testing Purposes) or finer filter, or the '
equivalent." for cleanness Class D. '
j 5.
Section 3.1.2.1 of ANSI N45.2.1-1973 states that surfaces shall be I examined without magnification under a liqhting level (back plus supplementary lighting) of at least '00 foot candles. ground GPUN !
intends to permit the use of neutral 18% gray card with a 1/32" black ;
line for determining acceptability of 111umination in lieu of the 100 foot c6nd!es. !
- 6. i Section 4.0 of ANS! N45.2.1-1973 states that items are not to be ,
delivered to the point of installation sooner than necessary unless .
4 the installation location is considered a better storage area. The i strategy for the storage of items is based on many factors, one of which storage.
is to not adversely affect the item's acceptability while in i If other factors make it desirable to store an item at the .,
installation site, and the location is acceptable from a quality !
standpoint, it is not our intention to eliminate that site as a potential storage area. #$ an alternate to this requiroment, items {
may be delivered to the installation site sooner than absolutely necessary when determined to be advantageous for other considerations. Example - reduced handling or easier access, thereby reducing susceptibility to handling damage. In all such cases, t equipment stored in place will be protected in accordance with i Section 5 of ANSI N45.2.1-1973.
l
- 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 with identifications and lastructions for seal ,
removal. GPUN utilltes procedural controls which specify the l
authortration requirements for seal removal. " Tags" are act normally 't utilized. !
v l
k 96.0 3900L (12/88)
.--._,-y. . _ _ . . -
GPUNC OPERAi!0NAL QUALITY ASSURANCE Number fGINuolear %"0%"Wr" 25'^'* u"It i io*-P'a-72*.0i l
Title Appendices Revision ho.
2 APPEICIX C - PART 2 !
- 8. Section 7.2 of AN5! #45.2.1 1973 allows piping systems to be flashed only with unter. A water flush of piping systems using ather flutes can lead to contestnation and/or otner problems which would affect the ,
reliability of these systems. ANSI #45.2.1-1980 provides requirements i and recommendations for flushed using fluids other than water. For flushing of hydraullt instrument, control, lubrication and other non- !
water systems, GPUN Intends to confors to Sections 3.4.2, 3.4.3, 3.4.4, :
and the guidance of Table 3.3 from AN5! 1845.2.1-1g00. Speelfications ;
and procedures for flushes utlitzing this esception must specify, as applicable: j E particulate _contaminatoleue.ls; water content; water i i soluble contaatnate levels; organic contaelnate levels, flush time. '
flush pressure / flow / amount; type of fluid to be used; and, the restric-tions identified in Sections 3.4.2, 3.4.3, and 3.4.4. '
l IIRC Reaulatory Guide 1.38. Rev. 2. May 1977 I i
N alliy Assurance Recutrements for Packasine. Shtsctna. Receivina. Storace and land 1'ne of Items for mater Cooled Nuclear Power Plants ;
\'
The GPUN Quality Assurance Progres compiles with the regulatory position of this guide with the following modifications or clarifications to ANSI
- 45.2.2-1972: '
- 1. Section 2.4, Personnel Qualifications. As a point of clarification, '
i personnel who perform the audit (s) described in Section 2.4. will not be evallflod in accordance with AN5! #45.2.6. Such personnel are i
( quellflod in accordance with Regulatory Guide 1.146, dated 8/40. '
l- 2. Section 2.7, Classification of Items. The four-level classification I I system for storage of items will be followed, however, the designated t classification level may not be espItcitly identified on the ites.
The classification level will, however, be traceable through the pro- t curement documents. Classification differing fres Section 2.7 will be- t considered acceptable provided no degradation is assured; for example, electric motors designed for outside service may be stored in a level >
C area rather than a level'B. ,
, 3. Section 3.2. Levels of Packaging. The four level classification system I for packaging of items any not be used espilettiy. For commercial grade items standard commercial grade packaging requirements may be -
specified.
- 4. Section 3.6 concerns prevention of halogenated materials from con- I tacting stainless steel or nickel alloy asterials. The clarifications appitcable to Regulatory Guide 1.37, identified previously, also apply to this section of ANSI N45.2.2.
- 5. Section 3.7.1 Cleated, sheathed boxes will be used up to 1000 lbs. I rather than 500 lbs. as specified. This type of box is safe for, and has been tested for Ioads up to 1000 lbs. Other material standards (i.e. , FED Spec. PPP-8-601) allow this. Special qualification testing
) shall be required for loads in excess of 1000 lbs.
97.0 l 3900L (12/88)
i GPUNC OPERATIONAL QUALITY ASSURANCE '
fGINuolear %"0%i"s!c?"
'S* """ ' Number
' * '"-
- o' t
Title Appendices Revtston ho, l 2 A l APPENDIX C - PART 2
- 6. Section 5.5, Correction of Nonconformances. This section provides for l !
" rework" and "use as is" dispositions for nonconforming items. As an !
alternate, the "repatr" disposition (as defined in AW5M N45.2.10-lg73) wtiI also'be used. ;
- 7. Section 6.2.1 For storage of level 0 items access will be controlled i I and limited by postiny. Other positive controls such as fencing or -
posting of guards wil' be provided for higher storage levels.
S. Section 7.4 states I acceptablitty of al@ equipment and rigging after each inspection,at a syste; ;
specify control of nonconforming 11ftung egulpment, and supplement periodic inspections with special visua' and nondestructive examina. :
tiens and dynamic load tests. In lieu of this, GPUN does perform '
dynamic load tests on new egulpment, preventive maintenance on cranes, ,
' nondestruetive examtnat1on of 11fting hooks annually, and a visual inspection of itfting equipment prior to use. . i
- 9. Appendix A.3.4.1 The last sentence of A 3.4.1(4) and (5) should be corrected as follows:
! i I (4) "Nowever, 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 fact 11-tate touch up." j
- 10. Appendtx A 3.4.2, Inert Gas 81ankets. There may be cases ins ving I I large or complex shapes for which an inert or dry air purge w 1s provided rather than static gas blanket in order to provide ..<quate protection due to difficulty of providing a leak proof barrier. In l these cases a positive pressure purge flow may be utilized as an j alternate to leak proof barrier, ,
i
- 11. Appendix A.3.5.2 Tapes will meet a sulphur limit of 0.301 by weight I :
instead of 0.101 as specified in A.3.5.2(1)(a).
This limit is reasonable based upon the chemical content of commer-cially avallat'h tapes. Tapes will be of a contrasting color rather than Brightl?/ Colored" as required by A.3.5.1(3).
- 12. Appendix A.3.7.1 In lieu of A.3.7.1(3) and (4), the following will be I imposed: Fiberboard boxes shall be securely closed either with a water resistant adhesive applied to the entire area of contact between 1e flaps, or all seams and joints shall be sealed with not less the 2-inch wide, water resistant tape. , !
98.0 >
3900L (12/88)
L. _ _ _ . __ _ __ _ ._ __ .. _ _ _ _. - _ - - - - -- - - - - - - - - - - - - - - -
~
urv.s vrtee wm vvm ii anumu 'cu:5er l Nuclear "'ca 'aatt "1" 25 m van i
'ND OYSTER CREEK A
i*o-aia-72oo.o1 i Revision No. i Title Appendices 2 !
APPENDIX C - PART 2 l NRC Regulatory Guide 1.39. Rev. 2. Sectemoer 1977 Housekeecino Recuirements for Water Cooled Nuclear Power Plants Endorses AN$1 f g N45.2.3 - 1973 l
The GPUN Quality Assurance Program complies with this guide with the !
following clarification to ANSI N45.2.3-1973. l
- 1. Sections 2.1 and 3.2 The Nuclear Stations will not utillZe the five i level zone designation system referenced in ANSI N45.2.3. but wl11 ut1112e standard janitorial and work practices to maintain a level of ,
cleanliness commensurata with company policy le the areas of ;
housekeeping, plant and personnel safety, and fire protection. '
Cleanliness wl11 be maintained, consistent with the work being ;
performed, so as to prevent the entry of foreign .^4terial into r systems within the scope of this plan. This will include as a l >
minimum documented cleanliness inspections which will be performed l immediately prior tci system closure. Control of personnel, tools, P equipraent, and supplies will be established when major portions.of ;
the reactor system are opened for inspection, maintenance or repair. :
Additional housekeeping requirements will be implemented as required !
for control of radioactive contamination, t i
- 2. Section 3.2.3 discusses fire protection. Except for the Quality '
assurance aspects of fire protection, no spectfle 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 Reauirements for Protective Coatinos ADD 11ed 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 modificaitons (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) shall j be the original requirements or better, t
l 99.0 390CL (12/88) ,
l l
1 1_ _ _ - _ - _ _ _ _ _ _ _ _ . _ _ _ _ .- - - . . . . . . - _ - . - _ . _ . - . _ - - - . . - - . - - - . - - . - - .
GPUNC OPERATIONAL QUALITY ASSURANCE NVhber I Nuolear " 'a aatt "2't 25'ma" '
AND OYSTER CREEK
" '"-72
- o' i l
, Revision No. l f Title Appendices 1 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 fleid coating work for nuclear facilities- I will perform satisfactorily in service. j All protective coatings, except those noted in 3 below, applied to l 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 Light Water Nuclear Reactor Containment Facilities, under LOCA conditions l which equal or exceed those described in the FSAR. l The Quality assurance program is applied for Protective Contings !
consistent with the nature and scope of work specified in the ,
technical specifications. The following elements are included.
, (4) Preparation of coatings specification and procedures for generic l coating materials / systems.
(b) Review and evaluation cf coating manufacturers' demonstration i' test data and quellty assurance meksures for control of manufactvre, identification, and perforn.nnce verification of applied coating systems. ,
( (c) Review and evaluation of supplier quality assurance measures to control storage and handling, surface preparation, appilcation, touch-up, repair, curing and inspection of the coating systems. },;
l (d) Training and Qualification of inspection personnel in coatings I inspection requirements. ,
(e) Supplier surveillance inspection.
The coatings qualification program and the associated quality
, assurance requirements are necessary only for coatings whose failure l or failure mechanism would have a significant effect on safety, l
l 3. Regulatory Guide 1.5415 mot imposed for:
!. (a) Surfaces to be insulated. *
(b) Surfaces ' contained" within a cabinet or enclosure (for example, the interior surfaces of ducts).
l 100.0 3900L (12/88)
F .
l GPbNC OPERATIONAL QUALITY ASSURANCE Number l
!' O Y 00 t E Revision No. l T1t1e Appendices 1
)
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 l ttem (1).
(d) Small " production line" items such as small motors, handwheels, electrical cabinets, control panels, lounspeakers, etc. where !
special painting requirements 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 listeo 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 Reculaterv Guide 1.58. Rev. 1. September 1960 Qualifications of Nuclear Power Plant InsDection. Examination, and Testina Personnel, *
'ihe GPUN' Quality Assurance Program complies with this guide with the 3 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 with day-to-day operation, maintenance, and certain technical services shall conform to Regulatory Guide 1.8.
NDE Level !!! personnel shall be recertified at an interval of every 5 years as noted by ASME Code Cases N-341 and N-356, rather than the .
3 year interval recommended by ASNT-SNT-TC-1A 1980.
101.0 '
3900L (12/88)
l GPUNC OPERATIONAL QUALITY ASSURANCE Number .
Nuclear %"JfM"sjf25'^" uNn i io x-etN-22co.oi .
Pevision No. .
Title Appendices 2 !
t , APPENDIX C - PART 2 l l-
- 2. Plant operation personnel may be utilized to perform the visual -
L leakage examinations required by the edition of ASME Section IX and related codes currently committed to for the conducted of inserviev ;
inspections. Such personnel shall be qualtfled 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 who:
A. Review and approve inspection and testing procedures.
L I
B. 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, t D. Certify Level III individuals in specific categories or classes, will be certified as meeting the Level !!! capability requirements of '
ANSI N45.2.6 - 1978. Rather these personnel will be determined by management through evaluation of their education, experience, and i
training to be ful'ly qualified and competent to perform these ') .
functions. The basis for the determination will be documented.
NRC Reculatory Guide 1.64. Rev. 2. June 1976 Quality Assurance Reautrements 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 requirements (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements) associated with maintenance and modifications shall be the original requiremencs or better. -
The Ouality Assurance Program complies with this guide with the following clarifications: l
}'
102.0 3900L (l?/88)
1 E
GPUNC OPERATIONAL QUALITY ASSURANCE Number i Nuclear PLAN FOR THRH MILE ISLA@ UNU 1 AND OYSTER CREEK 10M-PLN-7200.01 l Revision No.
Title Appendices 2 APPENDIX C - PART 2
- 1. Regulatory Position C.2(1) of the Regulatory Guide: I ;
If the designer's lienedtate Supervisor is the only technically [
qualified individual available, this review can be conducted by the Supervisor, providing that: (a) the other provisions of the -
Regulatory Guide are satisfied, and (b) the justification is I individually documented and approved in advance by the Supervisor's ,
management, and (c) Quality assurance audits cover frequency and effectiveness cf use of Supervisors as design verifters to guard against abuse. I
- 2. Sections 6.2, 7.2 and 8.0 of AWS! N45.2.ll-1974 Each of the above sections reiterate the need to apply design control i
provisions equivalent to original or previously vertfled designs.
Destga control provisions include revision, review, and approval of the design document (s) affected and design verification. '
1 The last sentence of Paragraph 6.2 could be read to imply that two i separate reviews are required for "fleid changes" to previously I approveo designs: (1) the review of field changes for the effect on I overall design and (2) design verification. As a point of clarifi- i cation with regard to "fleid changes," the effect of the field change ;
will be independently evaluated and *he need for design verification of the specific field change will'be determined. If the review determines that the fleid change has no effect on the previously approved design then that review constitutes a design verification of .
that field change. If the review determines that the field change ,
does have an effect on the previously approved design then a design verification of the resolution of that specific field change will be j '
conducted. !
Also, field cnanges that are " minor" as described in paragraph 7.2 of the standard will not be design vertfled. Pr6cedural requirements shall be provided to identify when such field changes are " minor" in the context of paragraph 7.2 of the standart.
}
~'
NRC Regulatory Guide 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 reautrements of ANSI /ASME NQA-1-1979, Supplement 175-1 and Appendix 17A-1 in:lucing Appendix 17-1, NQA-IA-1981.
103.0 3900L (12/88)
I GPUNC OPERATIONAL QUALITY ASSURANCE Number L
ENuclear us"#J"Tf" "'^"""" ' "'"-72
- o '
Revision No.
l Title Appendices 2 APPENDIX C - PART 2 l NRC Regulatory Guide 1.94. Rev.1 ' Acril 1976
\
l Quality Assurance Reauirements for Installation. Inspection and Testing of )
jfructural Concrete and 5tructural Steel durine the Construction Phase of Nuclear Power Plants )
The GPUN Quality Assurance Program compItes with this guide with the following clarification (s):
(1) QA programmatic / administrative requirements included in the Regulatory -
Guide shall apply to maintenance and modification activities even 5 though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications shall be the ort!)inal requirements or better (e.g., code requirements, L materia properties, design margins, manufacturing processes, and inspection requirements).
(2) Section 5.4 of ANSI N45.2.5-1974 specifies the calibrat1on frequency and method of automatic cut-off impact wrenches used to mako us and inspect high strength bolted connections; and, the calibrat' on frequency of hand held torque wrenches used to insnec', high strength bolted connections. Section 5.2.6 of ANSI 18.7 as we' I as 6.6 of this plan also spectfy controls for measuring and test equipment.
Sections 5.2.6 of ANSI 18.7-1976 in conjunction with 6.6 of this Plan - -
shall be used in lieu of 5.4 of ANSI #45.2.5 to control the frequency )
of calibration of automatic cut-off impact wrenches and hand held torque wrenches used to make up and/or inspect high strength bolted connections. The method of calibration will be consistent with the manufacturer's recommendation (s).
NRC Regulatory Guide 1.116. Rev. O-R. May 1977 Ouality Assurance Recuirements for Installation. Inspection and Testino of Mechanical Equinment and Syst, gel The GPUN Quality Assurance Program complies with this guide with the following clarification:
QA programmatic / administrative requirements included in the Regulatory Guide shall apply to maintenance and modification activities even though such requirements were not in effect ortgtnally. 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-operational testing. As a result, many of the listed tests are not appropriate in an operational plant. 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.
104.0 3900L (12/88)
c .
GPUNC OPERATIONAL QUALITY ASSURANCE Number N I A D OY E E Revision No.
Title Appendices 2 -
APPENDIX C - PART 2 NRC Reculatory Guide 1.123. Rev. 1. July 1977 Ouality Assurance Recuirements for Control of Procurement of Items a_n.g !
5ervices for Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide Ulth the following clarification:
- 1. Section C.3. A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier. When a corrective action is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.
- 2. Section C.4. Applicable information concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.
- 3. Section 4.2.4 of ANSI Na5.2.13-1976. When evaluation of a supplier is based solely on historical supplier data, these data will primarily include records that have been accumulated in connection with previops procurement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experiencG.wlll 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 l- by one of the methods identifled; however, the procurement documents shall contain requirements specific to the item being procured.
l 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 M45.2;6. Such personnel ~are quallfled.h accordance with Regulatory Guide 1.146, dated 8/80.
- 6. Section 10.2.d of ANSI Na5.2.13-1976. The 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 10.2.1, Verification of the Validity of Suppiter Certificates l' 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 supp1Ier 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 1
105.0 3900L (12/88) i l
- - ,,- ,,,-..-,, , -, ,e. . - - - , . , - . . , .-. . ,. .
1 GPUNC OPERATIONAL QUALITY ASSURANCE Number l Nuclear PLAN FOR THREE MILE ISLAND UNIT 1 AND OYSTER CREEK 1000-PLN-7200.01
_ Revision No.
Title Appendices 2
~
APPENDIX C - PART 2 importance. The means of verification may include source witness / hold I 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 components and systems. All of these means verify whether or not a suppiter has ,
fulfilled procurement document requirements and whether or not a ,
certification system is effective.
- 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 tdditions to existing 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 Deslan Guidance for Radioactive Waste Management Systems. Structures and Components Installed in Licht-Water-Cooled Nuclear Power Plants
)-
l' l , Since the original design and construction of TMI-1 and Oyster Creek was [
to different classification criteria than contained in this guide; GPUN will comply with the regulatory position of this guide with the following clarifications:
- 1. For modification to existing plant systems, itees will be classifiec by Technical Functions according to the original design basis or this guide. This classification will not degrade the safety of the system being modified.
- 2. Additions to existing plant systems will be made to the same code, standard and technical requirements which were originally applied to the system to which the addition is to be made or more recent j versions of these codes, standards and technical requirements. The addition will not degrade the safety of the system being added to.
I l' 3. For new construction, the latest applicable code will be utilized unless such utilization would result in hardship or unusual difft-l culty without providing an equivalent level of safety.
106.0 3900L (12/88) l
- . .---....-.~--. . . . . - . . . _. , , . .__ . _m_ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _____
{. ,o
- i f' $
GPUNC OPERATIONAL QJALITY ASSURANCE I Number ]
.6 N I A OY E E Revision No. l Title' Appendices 2 i APPENDIX C - PART 2 NRC Regulatory Guide 1.144. January 1979 '
Audittna of Quality Assurance Programs for Nuclear Power Plants GPUN 1s in basic agreement with the position set forth in the Regulatory
, Guide subject to the following comments:
- 1. Sections C.3.4(1) and C.3.a(2_), l Minimum scheduling frequency and topical coverage of the GPUN Internal audit program will be as defined in Section 6 of the nuclear units' Technical Specifications.
- 2. Section C.3.b(1). Source surveillance will be utilized in lieu of or in addition to receipt inspection. As permitted, external audits of such procurement actions will typically not be scheduled.
- 3. Section C.3.b(2)
External audits of selected suppIlers of services which are witM n the scope of this Plan will be scheduled and conducted at least once within the life of the' activity or every three years. Refer also to 10.2.5 of this plan.
t An annual evaluation of suppliers of items, parts, materials and services will be conducted. These evaluations will be conducted -
utilizing the results'of source surveillance, source inspectlen, i receipt inspection and/or audits; and, other factors. These l evaluations will determine the need to conduct audits of suppliers of l
items, parts or materi*als; or, increase the frequency of conducting '
l audits of suppliers of services.
l 107.0 3900L (12/88)
i
>s 1
4 GPUNC OPERATIONAL QUALITY ASSURANCE- Number !
i IUlNuclear u^"#d"sl# '5'^"""" ' ' "- '
i Revision No. l Title Appendices 2 ^ I APPENDIX D I L Terms and Definitions 1
This Appendix contains certain terms and their' definitions that are i important to a uniform understanding of the requirements of the GPUN Operational Quality Assurance Program. ANSI N45.2.10-1973, as endorsed by Regulatory Guide 1.74, and NOA-la-1981 contain terms and definitions '
l- applicable to the nuclear industry. The terms and definitions found in these l= documents are applicable to the GPUN Operational Quality Assurance Program and, for convenience, are included, in part, herein. Those terms and definitions which are the same as listed in ANSI N45.2.10-1973 or NQA-la-1981 l
+ are identified by footnote (1). Certain exceptions to the terms and definitions found in ANSI N45.2.10-1973 and NQA-la-1981 have also been taken.
These exceptions are identified by footnote (2).
I
' 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 placed on characteristics of an item, L process, or service. defined in codes, standards, or other documents. (1)
ADMINISTRATIVE CONTROLS: Rules, orders, instructions, procedures, polict'es, 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) j Al0!T: A formal, independent activity conducted with the intent to verify conformance wtth established requirements. This activity is performed in accordance with written procedures or checklists to verify, by examination 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 require-ments. The terms " source surveillance", " source inspection", " inspection"
'" surveillance / monitoring," and " survey" are not synonymous or equivalent to the. term "audtt." (2) 108.0
, 3900L (12/88)
l GPUNC OPERATIONAL QUALITY ASSURANCE Number fMUlNuclear us"JfM"!H#S'^"
"""' '**""2*'
1 Revision No.
. Title Appendices 2 g ;
APPENDIX D l BASELINE ENGINEERING DOCUMENTS: Includes but is not limited to safety '
s evaluation, oesign criteria documents, flow charts, System Design Descriptions, 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, system, component or part (including design analyses), necessary to assure (1) the integrity of the reactor coolant pressure boundary, (2) the capability to shatdown the rwactor 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 exposures 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.
COMMERCIAL GRADE ITEM: An item that meets all of the foifowing conditions:
Is used in applicttions other than nuclear power plant facilities or activities; Is not subject to oesign or specification requirements unique to NRC requirements for nuclear power plants; I
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 l I
description must match the requirements needed to satisfy the design
! . function of the item. Commercial grade items, when used as a basic I
component, must be dedicated prior to operations CONCURRENCE: Written agreement that the provisions in a document for which review has been requested are acceptable for laplementation within, or from the standpoint of, the reviewer's area of responsibility.
CONDITION ADVERSE TO 00ALITY: An all inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective items, and nonconformances. A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or operability.
1 109.0 3900L (12/88)
- ,- - - _ - . - - - - - - - _ _ _ _ _ _ _ _ _ - _ _ _ _ _______________-__x_.
}{ -
{
Lif GPUNC OPERATIONAL QUALITY ASSURANCE Nu2ber NY i
fE1 Nuclear us"J "J"nl#" 'S'*" ' " ^ "o2 *.0i i Revision No.
- Title Appendices 2
,9 < - i APPENDIX D l
l i CONTRACTOR: Any organization under contract for furnishing items or i services. .It includes the term Vendor, Supplier, Subcontractor, Fabricator and subcontractor levels, where appropriate. (1) )
CONTROLLED DOCUMENT: A document which 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 with current revisions to the
, document.
CORRECTIVE ACTION: Measures taken to rectify conditions adverse to quality and, where necessary, to preclude repetition. (1)
PEDICATION: The process by which a commercial grade item is designated for use in a nuclear safety-related application (s). It includes a point in time, typically after receipt, when the party designating the item assumes deficiency reporting respensibility associated with such use. ,
1 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.
DETAILED DESIGN DOCUMENTS: Engineering design documents derived from the Baseline Engineering Documents that provide the detall of design sufficient to )-
fabricate, instal.1 and test a modification or system. This includes but is not limited to Procurement, Material, and/or Test Specifica'tions, Installation Specifications, Fire Hazard Analyses, construction drawings, fabricatten drawings, Bill of Materials, etc.
DOCUMENT: Any written, pictorial, graphical or other reproducible media information describing, defining, prescribing, specifytag, reportleg, or certifying activities, requirements, procedures or results. A document is not considered to be a record until it is completed and contains the required l signatures. (2)
ENGINEERING (Encineer): This term refers to the technical responsibilities of Technical Functions, Plant Engineering or A/E's.
EXTERNAL ORGANIZATIONS: Any organization participating in the project which is not a part of GPUN. This term includes vendors, A/E's and contractors.
' This term is synonymous with the term supplier.
l 110.0 3900L (12/88)
GPUNC OPERATIONAL QUALITY ASSURANCE Number I
'5'^" """' " " " ' '
DTITUNuclear u^o"JfM"sl#"
Revision No.
Title Appendices 2 APPENDIX D j l
ITEM: Any structure, system, or component of a nuclear power plant including nuclear fuel and radwaste systems. This item also includes licensed radwast6 shipping containers. Quality classification shall be performed for mechanical, electrical, and instrumentation items at the component level. Mechanical items shall include valves, equipment and specialty 1tems. Electrical and instrumen-tation items shall include electrical, distribution, instrument and control panels, cabinets, switchgear, motor control centers, non-panel mounted instruments, transformers and motors. This term does not necessarily include parts of components.
LEAD AUDITOR: An individual qualified to organize and direct an audit, report audit results, and evaluate corrective actions. This term is not equivalent to the term " auditor." The term " audit team leader" is equivalent to the term ,
" lead auditor."
MONITORING /5URVEILLANCE: An act of assuring compliance of activities to program requirements by direct observation or record review. Generally, i monitoring is performed on site and surveillance is performed at a vendors's facility, i
NUCLEAR SAFETY RELATED: Structures, systems and components designed to remain functional for all design basis conditions necessary to assure the following safety functions:
- 1) The Integrity of the Reactor Coolant Pressure Boundary.
l 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 consequences of accidents
) which could result in potential offsite exposures comparable to the guideline esposures of 10CFA100.
, PROCUREMENT DOCUMENT: Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to define the quality and technical requirements for purchase. (1)
OA PLAN SCOPE: This term is a designator used on the coversheet of approved documents wMen prescribe the method of performance of activities or tasks identifled h Section 2.2.2 of this Plan.
! QUALIFICATION (Personnel): The characteristics or abilities gained through 1 l education, training or experience, as measured against established '
requirements, such as standards, or tests, that qualify an individual to perform a required function.(1) i OUALIFICATION (Procedures): An approved procedure that has been demonstrated to meet the specified requirements for its intended purpose. (1)
I 111.0 l 3900L (12/88) l
. \
GPUNC OPERATIONAL QUALITY ASSURANCE Number l
F&lNuclear %"#d"H!J'" 'S'^"""" ' ' ""o2x;0i ;
Revision No.
Title Appendices 2 s APPEN0ix 0 .
00ALITY CLAS$1FICATION: A process for identifying the technical and quality L requirements ot'~ structures, systems, and components based upon regulatory l f
requirements'and commitments, safety function and/or reliability consideration,
@,AQTY CLASSIFICATION LIST (OCL): The approved and controlled document used to record the identification of structures, systems and components that are within the scope of this Plan.
RECORD: A completed document which has been authenticated which furnishes evidence of the acceptability of an item, part, material, or activity, etc.
within the scope of this Plan.
REGULATORY REQUIRED: Those items which are not nuclear safety related but which must meet NRC regulatory requirements or commitments. Sources of regulatory requirements and commitments, as a minimum, consist of those associated with expressed conditions of the unit operating license, FSAR, fire protection (Appendix R and BTP Appendix A), security, environmental qualification of elec-t trical equipment, seismic response capabilities, licensed shipping containers to the extent committed by GPUN, generic letters, IE Bulletins, ICCFR50.54(f) correspondence, certain NUREG documents, etc.
REVIEW FOR CONCURRENCE. A review of a document conducted prior to that docu-ment Deing approved for use. A review conducted by someone other than the individuals who prepared; or, will approve the document for use.
SPECIAL PROCESS: A process, the results of which are highly dependent on the control of the process or the skill of the operators, or both, and in which the specified quality cannot be readily determined by inspection or test of the product. (1) ~
SUPPLIER:. A firm which provides items, parts, materials or services from an offsite facility and opcrates under the requirements of their own QA program.
SUPPLIER OUALITY CLASS!FICATION LIST (SOCL): A approved and controlled list of
. Suppliers who have been evaluated by the GPUN Quality Assurance Department for their capabilities to produce or provide items or services or both within the scope of this Plan.
TRACEABILITY: The abil'ity to trace the history, application, or location of an item and like items or activities by means of recorded information. (1)
I TREND ANALYSIS: A quantitative method of collecting and analysing <
nonconformance/ deviation events with the goal of systematically determining programmatic / procedural weaknesses.
VENDOR: A firm whlen manufactures items at an offsite facility and op? rates under the requirements of their own quality assurance program. ,
VERIFICATION: An act of confirming. substantiating and assuring that an ,
activity or condition has been implemented in conformance with the specified i requirements. (1) 112.0 3900L (12/88)
. : . -- - 3 -
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60bu-88-12fs --
Pe g2 1 of' 40 GENERAL DISPOSITION AND REASON (S) FOR THE CNANGES ASSOCIATED MITN REVISION 2 0F TWE OQA PLAN CEANGE GENERAL DISPOSITION / REASON FOR CNAleGES 4
- 1. General. The phrase "within the scope of this 1. Not a reduction in prior commitment. The reason plan" has replaced the phrase "important to safety." for the change was to introduce and use a generic phrase to provide for the incorporation of the NRC reviewed and accepted GPUN hardware classifi-i catlon terminulogy into the QA Plan without reducing the previously accepted scope of this QA Plan. Ref er also to itecis 2 and 3.
2.
General. The designator "ITS" has been replaced 2.
j with the designator "QA Plan Scope" for docu- Not a reduction in prior comunitment. The reason i
ments which prescribe methods to be used to for the change is to introduce a term to be conduct activities "within the scope plan". specif ically associated with and used inr activities and/or tasks within the scope of this
- plan. Refer also to item 1.
3.
General. The designator "ITS" has been rept. iced 3.
4 by the designator " Nuclear Safety Related" or Not a reductinn in prior coussi tment . The reasoni
" Regulatory Required" for documents which pre- for the change is to introduce terms to be l' specifically associated with and used for items, scribe technical and quality seguirements for items, parts and material "within the scope of parts and materials within the scope of this
( the plan." plan. Refer also to item 1.
- 4 General. The subsection title " Policy" has been 4 replaced by the subsection title " General". Not a reduction in prior cassoitsent. The reason j .
for the change was to eliminate the term " policy" from the plan to provide direct consistency with current GP11M corporate procedure on docemment control.
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- ATTACNNFNT I-6000-88-12a Page 2 cf-49 j CENERAL DISPOSITION AND REASON (S) FOR TWE CHANGES ASSOCIATED WITN REVISION 2 0F THE OQA PLAN CRANGE I
CENERAL DISPOSITION / REASON FOR CNANCES
- 5. General. The " General" subsection of each 5. Not a reduction in prior cosenitment. h reason section has been defined as characterizing the intent of the section (Refer to 2.5). This, for the change is to improve the clarity of the i
alorg with additions to Subsections 2.2.2, 2.3, QA plan by directly stating the objectives to be 2.8 and 3.2.2.2 should leprove the consistency met or results to be achieved. The change also e
of identifying activities and documents which provides a principle or desired effect to be used -
are "within the scope'of this plan". by the Director QA in rendering determinations as provided for in Section 2.1.
I b.
General. The phrase " regulatory requirements 6.
and comuniteents** has been utilized where appro- Not a reduction in prior commiltment. The reason priate throughout the text. for the change is ta directly identify additional source documents to be used to identify what is j
within the scope of this plant and/or, what specific ~ technical and/or quality requirements that apply. Refer also to the definition of
, " regulatory required" in Appendix D.
7 General. The terms "doctament" and " approved 7.
i document" have generally replaced the terms Not a reduction in prior commitment. The reasons
" procedure, instruction, policy, drawing, and/or for the change are (1) to recognize that "docu-specifications." mented direction ** can be provided by formats other than " procedures";, and (2) to simplify the text of the plan by consistently utilizing a fixed terminology. Refer to " document" in Appendix D.
- 8. General. The term " supplier" has replaced the 8.
terms " vendor, AE contractor, and consultant." Not a reduction in prior comunitment. The reason The term " external organization" if used is for the change is to simplify the text of the
) equivalent to the term " supplier". plan by consistently utilizing a fixed termi-o nology. Refer to " supplier" in Appendix D.
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GENERAL DISPOSITIOff AND REASoll(S) FOR TWE CHANGES ASSOCIATED WITE REVISI000 2.0F TWE OQA PIAff CEANGE CENERAL DISPOSITICIf/REASCII FOR CEANCES
- 9. General. Organisational titles have been revised . .
- 9. Not a reduction in prior commitment. The reason 4
as necessary throughout the text.
l' for the change (s) is to molte the text of this plan consistent with the current CPUII organisation a plan.
, 10. General. The ters ** ensure" has replaced the 10. Not a redwetion in prior commitment. The reason word " assure" in certain cesse.
for the change is to use the term which states i
more directly line management's principle accountabilities. Refer also to Section 1.1 and 2.11.6.
- 11. General. The term " record" has replaced the i 11. Not a reduction in prior commitment. The reason term "QA record".
for the change was to add a more general term to more directly state this plan's requirements.
i Refer also to Appendix D.
i
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i 6000-98-126~
.Page 4 of;49,7 ,,
GEIERAL DISPOSIT3000 AND REAS0ll(S) POR' TWE CRAsIGES ASSOCIATED WITN REVISIOff 2 OF. TWE OqA PEAft CSABIGE -
- 12. CENERAL DISPOSITICIf/REASCII FOR CRASICES Introdwetion. The test hoe been revised to 12.
(1) replace " workable" with "meable"; Isot a redwetion le prior comunitment. The reason (2) replace "... is structured to describe ..." for the change wee to revlee thls introduction to wit % " describes"; (3) replace "... the Quality provide plan. direct consistency with the test of this Assurance Program ..." with "this Plan";
(4) replace "the" with "thle"; (5) replace
"... contains a description of ..." with "identifles"; (6) replaces " program" with " plan";
(7) ant replaces "... direct and supportive import-to safety ... and safety ..." with ,
"... operstlenel, empport, and moeurance .. .
este ...."; (8) added the phrase "... and pre- ,
paration for the transport ..."; (9) add
{ "... and 10.0 ..."; (10) replace " functions" i
with " activities"; (11) replace "... Quality ,
i Assurance Program . . ." with ". .. this plan . . .";
(12) replace "quelity nonconformances" with
" material nonconformance and conditlene adverse i to Section of gestity";9.0 (13) identify the revloed subject (14) id
- tify that medlie are l
incorporated in Section 1">.0; (15) add the l phrase "... the coed::t: et"; (16) delete
"... Quality r~rogram ..."3 (17) replace "the" i
with "thle"; and. delete the test associated l with the previous Supplemente I and 2. '
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FaaQ $ ol-40 CENERAL DISPOSITION AkD REASCII(S) FOR Tite CRAIICES ASSOCIATED WITE REVISION 2 0F TWE DQA PtAN '
4 CRAIICE CENERAL DISPOSITIOff/REASCII FDIt CHALICES
- 13. Section 1.0. The level of organisational. detail
!, 13. Et a reduction in prior commmitsment.
has been reduced. The activities previously The reason assigned have been retained. The organizetinn for the change le to minielse the need to revise plan has been explicitly added to Sebacetion the QA Plan when organizat lonel changes necer 3.2.2.1. The current organisation is described. within divisions currently depicted on Figure 1.
j Figure I has been eleptified. Figure 2 has been revloed to provide sore detail.
i 14 Provielen 1.5.1.(a). Previeesty 1.6.1.1.(f). 14.
i The phrase " review and acceptance" Ines been Reduction in prior commoitment. The reason for i
replaced by " review of selected" to be consist- the change was to provide direct consistency ent with the revloed QA document review strategy. between this provision and Appendix R of this Refer to Appendix R. plan.
l 15. Provision 1.5.1.(h). Previonely .l.6.1.1.(e).
l 15.
W phrase " review and acceptance" Ines been Not a reduction in prior casamitsment . The reason j
replaced by the phrase " review for concurrence" for the change was to directly incorporate revised consistent with time revloed QA docessent review terminology and/or phraseology, strategy. Refer to Appendix B and D. .
- 16. Provision 1.5.1.(t). Previously 1.6.1.1.(1). 16.
The phrase " review and acceptance" has been Reduction in prior commitment. The reason for replaced by the phrase " review of selected" to this change was to provide direct consistency be consistent with the revloed QA document- between plan.
this provision and Appendix B of this review strategy. Refer to Appendix B.
f 1
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f.TTACWESIT 6000-08-126 Page O of 09 CEIERAL DISPOSITION AIS REASON (S) FOR TWE CWANCES ASSOCIATED WITN REVISION 2 OF TWE 004 PEAft CRAIICR GE3 FERAL DISF0gITICII/**^9= FOR CEAIICES
- 17. Prowleton 1.5.1.(1). Previously 1.6.t.t.(m). 17.
The phrase " review and acceptance" Ines been Reduction la prior ceamitment. Ylee reason for replaced by the plurase " review of eclected" to thle change was to provide direct consistency be consistent with time revloed QA document between thle provielen and Appendix B of thle plan.
review strategy. Refer to Appendia B.
I8. Subseetion 1.5.2. The quelifIcatten require- 18. Reductlon in prior commitment. The reason for mente for the Director - Quality Assurance position hee been revloed to increase tine years the change was to directly replace "quelity of technical, supervisory and managerial assurance" emperience with empervisory/ managerial experience and decrosse the years of quality emperience for time position.
i assurance emperience required for an individual to assume the position.
! 19. Subsection 1.5.2. The gesellfication require- ,
! 19.
mente for QA Section Managere have been revloed Isot a reduction in prior coessitment. The reason
{ to require supervisory emperience for indivi- for the change was to directly require supervisory duals to seenne the positione. experience for the pocition.
, 20. Subsection 1.5.2. Text related to tine quotift-i 20.
j cation of inspection and enemination personnet Isot a reduction in prior commitment. The reeson that wee in the previous Subsection 2.5 has been for this change was to more cleerly state this j
moved to this paragraph. plan's requiremente, i
i 21. Section 2.0. This section has been reorganteed j 21.
to reduce excesolve subperagraphing. Not a reduction in prior coussitment. The reason for the change see to provide a more direct g i display and discussion of principal concepts.
I i
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Page 7 of.49.
GEIERAL DISFOSIT1010 AND REASCII(S) MR TWE CRAIIGES ASSOCIATED WITW REVIStoff 2 OF TWE 00A FIABI CEAIIGE CESIERAL DISPOSITICII/REASoff FOR CMAIIGES
- 22. Subsection 2.1. The test includes that contained ,
- 22. Not a reduction in prior coassitment. The reason in the previous 2.1 and last paragrapie of for this change was to directly state the '
previous 2.3.
- The test has been revised as: -
(1) the first paragraph mes the second paragraph "
generic. Intent. principles and means of achieving of the previous 2.1; that previous test aves the objective of the CFtNI QA plan.
revised to (1) replace " level" with "CPUlt"; -
(b) replace **... describe the quellty Assurance Program ..." with "... provides the generic ...
to control activities."; (c) replace "... subtler impleeenting policies. procedures and lastruc " .
tions." with "... this plan and approved docu-ments ... this Plan. This Plan is ... througli s
such approved documents; (2) the second and third paragraph are expanded versions of the first paragraph of previous 2.1; (3) the fourth para-graph was the last paragraph of the previous 2.3; that previous text has been revised to (a) add
"... and latent ..."; (b) replace "... quality assurance ..." with "... management control and assurance ..."; (c) replace "to" with "for";
(d) add "... part. material ..."; (e) incorporate "within the scope of this plan"; (f) replace
" degree" with " extent"; (g) replace'"guelity assurance" with "assersace"; (h) replace " system" l
with " item"; (c) replace " degree" with " extent";
and. (4) the fourth peregraph uns the third
! peregraph of the previous 2.1; it bes been reyised to directly provide the Director-QA the authority to determine the extent to which plan applied to activities and/or tasite.
f.M 7 L
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I.TTACINEENT I-6000-88-123-:
- Page 8 of 4')
GEIERAL DISPOSITICII AIS REASON (S) FOR TBE CEANCES ASSOCIATED WIfW REVISIGIl 2 OF TWE OQA FIAll l
CRANCE
! GENERAL DISPOSITION /REA90Il FCE CEAIICES
! 23. Section 2.2. This text has been completely
[
- 23. Not a reduction in prior coassitaments. h reasons revised to (1) incorporate the revised herduere j
classification terminology; (2) directly identify for the change were to (1) incorporate revised activities within the scope of this plan; tersninology and/or phraseology; and, (2) revise j
(3) directly provide criteria for identifyirig the text to more directly state this plen's scope.
tas k within the scope of this plan. .
24 Subsection 2.2.1. h " nuclear safety-related" 24. Not a reduction in prior commitment. h reason l and " regulatory regstred" terminology is incor- for this change was to incorporate revised
! porated. It should be noted that these terms j
are correlated to " regulatory requirements and terminology and/or phraseology.
j commaitsments" which is more specific then the previous listing provided.
l 25. Subsection 2.2.2. h specific activities j 25. Not a reduction in prior casunitment. h reasons within the scope of the plan are directly identified. Some of this text was previously in for this change were to (1) directly state the i
! Sections 1.0 and 6.1. Criteria has been added activities and/or teoks within the scope of this to be used to identify those tasks eseociated plan; and, (2) provide criteria to be used to with the activities which would be within the determine the estent to which the plan applies to l
i scope of the plan. Refer also to subsections 2.3 those activities and/or tasks. .!
and 2.8.
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Page 9 of e9 GEIERAL DISPOSITION AIS REASON (S) POR THE CEANGES ASSOCIATED WITE REVISION 2 0F TEE 004 FIAII 1
- reasser CENERAL DISPOSITION /RE&SINI FUE CEANCES
- 26. Subsection 2.3. The test wee previously numbered 26. Not a reduction is prior commitment. H e ressees i 2.3.1. H is text hoe been revised to (1) replace for this change were (1) revise the text to more l " degree" with "extest"; (2) replace " procedure" clearly state this. plan's regirementet (2) incor-with " document"; (3) add the phrase "... to an * ,
{ item ..."; (4) in (m) replace "importance" with porate revised terminology and/or phraseology; and, (3) provide direction to determine _the "effect", add " nuclear", and add "or safe plant extent to which the plea applies. Refer also to
! operation"; (5) la (d) replace "...-functional ites 25. ,
j compliance ..." with " functionality"; (6) incor-i parate "within the scope of this plan";
(7) replace "will" with "shell"; and, (8) add a i new paragraph which provides additional basis for j grading tiee extent of the application of the plan i
to activities and/or tasks.
l
- 27. Subsection 2.3. H is text wee previously numbered 27.
l Reduction in prior commitment. The reason for 2.3.1. This text has been avised to delete this change was to revise this test to be
! "... concurred with by the quality Assurance consistent with the revised Appendix 8 of this l Department ... Safety ..." and replace with plan.
i
"... reviewed by the Quality Assurance Department ,
consistent with Appendix B of this plan."
t
- 28. Subsection 2.4. This text consiste of the last
- 28. Not a reduction la prior cemenitment. The reemen paragraph of the previous 2.3.1. A new header has been incorporated. This test hoe been ic,r this change were to (1) revise thle text to '
revised to (1) replace " Quality Assurance Program" he ditsetty consistent with the revised 2.1 and
- j with " assurance process"; (2) insert " consistent" 2.2.2 touts (2) revise the text to more directly between "eatisfactory" and "and"1 (3) replace and clearly staic this plan's requirements; and,
} "
... the program commeneurste with its require- (3) eliminate unnecesanry rea==d==ey in the test of this plan.
{ ments for safety and performance." with "... of this Plan."; and. (4) delete the sentence "The Program's foremost ... the general public's health and safety".
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Fage 13 of t:)
CENERAL DISPOSITION AND REASON (S) FOR THE CHANCES ASSOCIATED WITH REVISION 2 0F THE OQA PLAN CHANGE GENERAL DISPOSITION / REASON FOR CHANGES
- 29. Subsection 2.4.1.- This text was previously 29. Not a reduction in prior commitment. The reason numbered 2.3.1.1. the text has been revised to (1) delete the sentence " Activities et this level for this change were to (1) eliminate unnecessary consist of inspections, checks and tests"; redundancy in the text of this plan; (2) revise (2) delete "First level . . .**, add ". . . at this the text to more directly state this plan *(,
level . . ."; (3) add the phrase ". . . Items, requirements; (3) provide direct consistency with systems, parts, materials and activities within the current CPtJN organization plan; (4) revise the scope of this plan ..."; (4) utilize current this text to be directly consistent with the titles; (5) add " Technical Functions ..."; revised 6.2 text (refer to item 111); and, (6) delete **... pump and valve. maintenance and (5) require more formality and structure for overhaul ..." (7) replace " Plant Maintenance" selected data gathering and/or "as built" review with " Plant Maintenance /Meterial"; (8) insert activities normally conducted by engineers.
"... checks, inspections and/or tests of ...";
(9) add new statement "Te h ic n cal Functions personnel periodically ... condition of plant systems or components."; and. (10) add "...
reports ..."
.10 . Subsection 2.4.2. The text was previously 30.
numbered 2.3.1.2. the text has been revised to Not a reduction in prior conmitment. The reason (1) add the term " survey"; (2) add the term for this change was to revise the text to more
" document review"; and (3) add the phrase "and/or directly state this plan's requirements.
monitoring".
e 4757L a
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l C83ERAL DISrettlTION AND REASON (S) FOR -
TWE CNAIRES ASSOCIATEC WITN RF. VISION 2 OF TWE OQA ' PIAN '
reasac8
~.
GENERAI. DISPCSITION/REASCII FOR CHAIII;E.S
- 11. Subsection 2.4 3. The tomt' woe previevely numbered 2.3.1.3. The tout, hee been revised to ll.
Et a reduction in prior cosmitment. The reason x (1) delete "... The purpose of this level is also for this change was to revise the text to more
' to establish that ..~. Engineering, Noterial clearly state this plan's requirements.
~ .
h eagement etc ..." and replace with "... alI
~
cesantastions conducting activities and/or tasIrs withi.* the scope of this plan ..." (2) delete
"... qualifted medit per - 1 ..." replace with l "... Lead eueiters ..."; (3) replace " satisfy" l wi t h "are quel l f ied to . . ."; (4 ) replace
".. . included as the Audit Tees leader . .."
with "... utilised as Audit Program P ;e=
l ment ..."; and, (5) delete "... for obtaining j
the necessary management direction ..." with the text" "... the necessary access to managecent to ... resolve any leaves ehleh may arise ...
secure additional technical support ... as may
{ be required ..."
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f.TTA01NESIT.1 6000-88-t20 Fage'12 et 4') -
genem48, DISPOSITION AIID REASOII(S) FOR
' TWE CEAleGES ASSOCIATED WITN REVISION 2 0F TWE OQA FIAff ~
l l CSAIEEE GE3IERAL DISPOSITISH/REASCII FUR CHAIICES l 32. _ Subsection 2.5. This embeeetion conelets of 32.
text contained in previous subeections 2.2 and Isot a reduction in prior casustteent. The reasons f or t h i s change we re t o ( I ) rev i se t he t e x t to
{ 2.3. The text has been transferred from and more clearly state this plan's regstrements; and.
! revised as: (1) the first paragraph wse the (2) incorporate revised terminology and/or phrase-i second. third and fourth sentence of the first ology.
) paragraph of previous 2.3; the text of the fourth i sentence was revised to (1) replace " detailed procedures and instruction" with " approved docu-
) neni: ; and (b) insert the perathetical phrase;
- (2) the se d paragraph was the second paragraph l
of 2.2; and. (3) U:- third " paragraph" was the second " paragraph of the p--vious 2.3; the text i
starting with polley has been cusf -tely 8
revised.
- 33. Subsection 2.5.1. This text was previously 33. flot a reduction in prior comunitment. The reasons numbered 2.3.2.1. This text has been revised to for this change were to (1) eliminate unnecessary l (1) delete the first paragraph starting with redundnancy from the text of the plan; (2) revise
- "The Plan includes ..." and endirig with the text to more directly state management 1
l "... comunitment to the quality Assurance accountability; and. (3) provide direct consist-
- Program ..." (2) adding the phrase " originated l by the Director - QA; and. (3) utilise current ency of this plan with the current GPUlf organi-ration plan.
- l titles.
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CEIERAL DISPOSITION AND REASON (S) FOR
- THE CNANGES ASSOCIATED WITII REVISION 2 OF TNE OQA FIAN 4
4 CEANGE CENERAL DISPOSITICII/ REASON FOR CEAleGES l 34. Subsection 2.5.2. The test wee previously 34 Not a reduction in prior casunitament.- The reasons nas6ered 2.3.2.2. The tout has been revised to j
(1) replace "In conjunction with" with "with the for tl.is change were to (t) revise the test to assistance of"; (2) utilise current titles; more clearly state this plan's requirements; j
(3) add the phrase "... this Quality Assurance. (2) provide direct consistency of this plan with Flen ..."; (4) add the phrase "... le this the current CPUN organisation plant (3) revise Quality Assurance Plan previously accepted ..."; the text to more directly state unenagement -
j (5) replace "to" with "by"; (6) add the phrase accountability; and, (4) revise the text to more
... originated by the Director, quality directly state this plan's requirements.
i
~
Assurance ..."; (7) delete the phrase "... and submitted by ... as indicated ... which shall be j
added ... cover page ...".and replace with I "... and any Division Director affected ...";
j (8) add "... The Document Elstory* pege will be utilized to identify such changes ...";
l (9) replace "the" with "this"; (10) add the phrase "... In the quality Assurance Plan pre-viously accepted ...."; (11) replace "to" with
! "by"; (12) replace " Issuance" with "Implementa-I tion"; (13) add "such"; (14) add "... the reason .
). for the change ..."; (15) delete the phrase -
i "... the Safety Analysis Report ... previously accepted by the NRC ..." and replace with the phrase "... to provide a suitable level of contro1 ..."; (16) remove the parentheses;
(!') add the phrase "... originated by the Director-Quality Assurance ..."; (18) replace l ".. concurred with by ... " with "... with the -
l conberrenceof..." and. (19) delete "... sub-mitted by the Director-Quality Assurance ..."
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'ATTACW ENT I-6000-88-126 "Page 14-Ef~C9.
CENERAL EISPOSITION AND REASON (S) FOR THE CRANCES ASSOCIATED WITN REVISION-2 0F TNE OQA FIAN i
i CWANCE CENERAL DISPOSITION / REASON PUR CEANCES
- 35. Subsection 2.5.4. The text was previously
- 35. Not a reduction in prior comunitment. The reason numbered 2.3.2.4 The text has been revised by replacing " procedures" with "documenta". for this change was to incorporate revised terimi-I nology and/or phraseology.
- 36. Subsection 2.6. The tout was previously 36. Not a reduction in prior commoitsent. The reason numbered 2.4 The text has been revloed to
- (1) delete the sentence "... In addition, the QA for the change was to reduce unnecessary redun-Department ... periodically prepares evaluation deney within the text of this plan. Refer s
reports ... effectiveness ..."; (2) replace the principly to 1.5.1 and 2.11.3.
4 phrase "... the activities meet ... of CPUN ..."
with "the QA pro 6 ram is effective in ensuring that l
regulatory requirements and coussitnents; and CPUN policies are met ..."
- 37. Subsection 2.7.
l.
The text was previously 37.
- numbered 2.5. The text hos been revised to Not a reduction in prior commitsment. The reasons (1) delete "The CFUN Quality Assurance Frogram for the change were to (1) provide direct ,
consistency between this subsection and the new includes requirements for . ."; (2) replace "of" I with "for"; (3) incorporate "within the scope of Section 9; and. (2) reduce organizational detail.
this plan"; (4) add the phrase "... are required Some previous text has been transferred to the
{ ... maintained ..."; (5) delete "... at the revised 1.5.2.
- Corporate office ... ette. These training ...
! are each ..." (6) delete "... The specific neede ... to be covered in ..." (1) add the !
sentence "These programs .. In Section 9.0 of this plan."; (g) items (a). (b). (d) & (e) have been incorporated into Section 9.0; (9) item .
(c),)nes been expended; (10) new text associated wit'h certificates of qualification has been added; and, (II) the paragraph starting with i "For personnel performing inspection..." has been transferred to 1.5.2 without revision.
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Pag 2 I S ct : t.4 l- CENERAL DISPOSITION AND REASON (S) FOR i
TBE CRANCES ASSOCIATED WITR REVISION 2 0F TBE OQA Pl>Je ' -~
I l canaams I CENERAI. DISPOSITION / REASON Felt CRANCES
- 38. Subsection 2.8. The test was previonely 38.
numbered 2.6. The test has been eatenelvely Not a reduction in prior cosamitment. The revised to (1) directly provide for the class- reason for the change was to provide sufficient -
ification of activities; (2) directly identify criteria within Section 2 of the plan to deter-how documents are to be marked; (3) introduce mine whether an activity, task, ites, part and/
the hardware classification terminology; or material is within the scope of this plan.
i (4) delete the phrase "... Reportant to i
safety ..."; and, (5) provide the criteria for
{ clasaltying replacement parts and saaterials.
- 39. Subsection 2.9.
'; The text wee previously numbered 39.
2.7. The text has been revised to (t) replace Not a reduction in prior commitment. The reasons
". . . coasmitment s to regulatory regairements .. ." f or ti.e change were to (1) incorporate revised with "... regulatory requiremente and cossait- terminology and/or phraseology; (2) utilize i "
ments ... ; (2) utilise current titles; and, current titles; and, (3) revise the text to smore l (3) transferred and editorialized the last clearly state the plan's reysiressents.
g sentence to 2.11.5.
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CualeGE
- 60. Subsection 2.10.i. The text.was previously GENERAL DISPOSITION / REASON FUR CRAIIGES _
numbered 2.8.1 and 2.8.2.. this text hos been. 40. . Reduction in prior cassnitment.
revised to (1) incorporate the term " technical The reasons for review"; the change were to (1) provide direct consistency .
(2) incorporate the ters ."GPUII Review with Section 6 of the Appendim A Technical and Approval Matrix"; (3) incorporate the ters. . Specifications; and, (2) revise thee text to more
" independent safety review"; (4) replace "first" clearly state this plan's requirements.
and "second" by "first"; (5) replace the phrase
"... all ectivities important to safety including design work or changes, plant operating, emergency . -
and alarm procedures, radiological control '
procedures and plant maintenance procedures" with "GPUN Review and Approval Matrix"; and, (6) replace the sentence "... This review will be performed on all written safety evaluations for design work or-changes, tests and experleents and procedures as described in the Technical Specif1 cations." with "GPUN Review and Approval Matrix" .
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CressmaL DISF051T10st AleD REAspes(S) FUR TWE CNAIICES A%SOCIATED WITN REYid100t 2 0F TWE Of)4 FtJW8 -
CBASIGE GEBIERAL DISPOSITIOff/REASOIf FOR CRAfBGES
- 41. Subsectica 2.10.2 The test was previewsly _
41.
' n suberal 2.8.3. The text Ines been revised to ht a redvetion in peine commitment. The reasons (1) replace " third" with "second"; (2) delete for the change were to (1) revise the tent to the tent "... It provides ... by time fonctional more clearly state this plan's respeitements; organizations. Each 10SRC ... and located on (2) eliminate weniecessary re A-My f ece the I text of this plan; need. (3) provide direct site."; and. (3) et111re current titles.
consistency of this place with tese ewerent CPUps
, orgenization plan.
- 42. Subsection 2.10.3. The text was previewsly
} numbered 2.8.4 42. loot a redwetion in prior casesiteent. The resscems
! The text lies been revised to j
(1) replace " fourth" with " third"; meed, for this cleesene were to (1) re* rise the text to (2) utilise current titles. more clearly state this plan's req.eirceants; and. ;
j (2) provide direct consiste.cy with time current I
CPtNE organization plan.
- t. 3. Subsection 2.10.4 The tent was previewsly 43.
neembered 2.M. 3. The teut hos been rewIsed to Not a redwetion in prior comunitment. The reason (1) replace "fif th" with "feweth"; (2) lasert f or the change was to revise the tewt to more "nneleer" before safety; and (3) Insert " safety" clewely state this pion's regnirements.
! after "cewclear".
i &4 Sehsection 2.ll.1.(b). The text was previously 44 j
numbered 2.9.1.(b). 1he text hoe teeen revised to ht a redwetion in prior commitment. The reesens (t) replace "the" with "this"; (2) replace for the chenge were te (1) revise tBee tent to 1 " meets" with "eneures compilence with"; and. more clearly state this plan's regwirements; esed.
(3 ) add ". . . and casunitments . . ." (2) incorporate revised terminology ased/or phraseology.
, t.5 . Sobeection 2.11.2. The test wee previewsly red 2.9.2. 45.
q Isot a redwetion in prior commitment. The reesons j
m
( @1)*wt lise entcurr The title (s);tent (2) delete has been revised tofor the clienge were te (1) provide direct con- ;
j
"... IIe also hos ... ased Emergency Frepered- sistency of this text with Section 1 et this pima; nes s . . ."; and ( 3 ) replace ". . . IIe . . ." wi t h and. (2) provide direct Indicatiese tiest reports to
"... The Director throengh time Director-4)=ality executive management are provided throwgh the As s en rance". Director ()A.
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- CEIIERAL plSFOSITIGI/BEASOII FUE CWABICES t
- 46. E h tien 2.11.3. Thte test see previewety 46.
number 2.9.3. The test ses reelsed to IIet a redwetion is prior commeltmemt. De re-(1) add "... sotherity med ..."; (2) replace - for the change were te (I) directly state the
"... for verifying ..." with "... te verify ..."; leaderstely role reptred of the Director QA
- (3) add the teet "... This responelbility wee peeltlen; (2) revise the test to snee clearly principenly diocherged tIsrougIn ... promptly state amoegement accountability; (3) revise tine detined and Septemented ..."; (4) replace tent to reence the levet of ergenlastlenet detall; l ;
l "progremf* with "procese"; (5) delete "... to the end. (4) rewlee teme test to more clearly endler
! Director-80meleer Assurance ..."; (6) replace directly state this plan's rewiremente.
"... the quellty Amourence Fregree ..." with
... of Ehle Flen its laplementat ten ...**;
j (7) replace "reporte" with " report (e)"; (8) delete i
! "... to the Director-IIncleer Aseerence ...";
(9) delete "... er their egeote ..."; !
i, (10) replace "owrwelltence/memitering" with v !
monitoring"; (11) delete "... performed by site I
< QA ergeoisettene ..."; (12) replace the test free y
"reporte of eweles.Jees" through "weedore" with j time tent free "evolustless of emppIlere" through
"" service ergenteetless"; (13) tine seetence !
... Corrective actlene einell he fwylemented ...
3 adverse tymmitty troede ..." hoe been editor-
! Salised and treaeferred to 2.11.6; (14) tene term l "monttered" hoe been replaced with " fellowed up";
(15) the phreee "... the Operettemel Samlity !
i Aseerence Plan ..." hoe been replaced with "tt thle Plan ..."; (16) replaced "ttne" with . j ges'pe"; (17) deleted tine oestence **The Director- !
ality Aseerence le respemotble frs ... Qiselity Asserence Fregree leylementetion ..."; and (18) deleted the sentence "... Ne is slee j reopensible for ... trainlag and wellfication ...
ether CFWIf eeroommet ... F.o emf r *. !
i 1
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AT 3ENT I se, .,A-l26 Fame I? of en -
CENERAL DISPOSITION ~AND REASON (5) FOR TWE CBANGES ASSOCIATED WITN REVISifRf 2 0F TNE 004 PIAN
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CEAMCE GENERAL DISPOSITION / REASON FOR CEANGES 47 _
Sebeection 2.ly. The test wee previewsly 47.
ntambered 2.9.4 the tent hoe been revised to Not a redwetlen in peler cosmitment. The reeson (I) delete the title " Director of Engineering for this change was to provide direct conglee.- y Assurance"; and. (2) delete the second of two of this plan =lth the current CPUN orseels tlon plan.
eentences "... se solleite input ... to assure .
welform opproech ... to cleositication ...".
- 48. Subsection 2.11.5. The text was previewely in 2.7.
- 48. Et a vedwetion in prior casanitnent. The reasons
' The text has been added and revised to for this change w-re to (Il provide dirert (1) utilize corrent titles; and. (2) add the e
phrase "... not contained in ... re p ired". consistency of this plan with the current Grips organization plan; and. (2) revise the text to more clearly seste t his plan's rewirement s.
- 49. Subsection 2.11.6. The tent wee previewsly 49. Not a reduction in peler ccamitment. The reasons membered 2.9.5. The text has been revloed to (1) add the phrase "... and Septementation of f or this change were to (1) lacorpora.te revised approved documents; and. ..."; (2) lacorporate terminology and/or phraseology; and. (2) revise the text to more directly state management the phreee "within the scope of thle plen"; ecrowntabilitier.
j (3) add tent associated with the accountability for the condwet of technicet and 1 4 ._t
' solety reviews; and. (4) add test secociated with the accountability for taking poettive action to evelwete sad correct conconformances.
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f.TTACWWIIT I 4000-95-126 Page 20 of 8.9 rammans DISF061Tf0N AIID REA5011(5) FOR 1WE CRAIICES ASSOCIATED WITN REVISIGII 2 0F THE 0Q4 FIAII reamre
- 50. CEIIERAL DISPOSITIGII/REASOII FOR CIIAIICFS Sobeection 2.11.8. The tent mes previously _
masher 2.9. 7. 50.
The test hos been revloed to Iso t a reduction in prior cessmitment. The reseca (1) replace the term " accomplished" with the for this chenge was to revloe the test to more term " resolved"; (2) add the pIvreee "... related directly state this plan's rewiremmes.
to if and to whet degree this Flen applies to activities, quality requirements ...";
(3) replace "... concerning inspection ..." with
- "... and verifleetion ..."; (4) replace " con-cerning" with "related to"; (5) add the phrase
"... cleestlication of items, perto, esterials
! and ..."; and (6) replace "... Quellty Asserence cont rols ..." with *... or this Flen's require-ments."
St. Subsection 3.1. The term " document" is weed
- 51. Ilot a reduction in prior cosmitment. The reason generically to directly recognize the use of
- documents other then " procedures" to prescribe for the change was to incorporate revloed I methods for laplementlas the regelremente of the terminology end/or phreneology.
i plan (e.g., drawings, work outInerlzing documente, specificatione, etc.)
j 52. Sabeection 3.1.1. A more direct Septementing I
52.
document compIIence statement hos been added. Ilot a reduction in prior casumitment. The reason for the change was to directly prescribe the j general principle that documents which prescribe
( methods for Septementing activities and/or teens j -within the scop = of this plan etnell be complied with as written or changed refer to proceeding
! with the activity and/or took.
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raec 28 of 49 CESIERAL DISPOSITICOI Afete REASCII(S) FOR Tile CIBAIIGES ASSOCIATED WITit aEVISIOff 2 0F TIIE OQA ptAls
- CEAIICE
- 53. CEVIERAL DISPO5ffl0II/REASCII FOR CNeferXS Subsection 3.1.2. Editorial changes were mode 53.
to mete this subsection clearer and more direct. Isot a reduct ion in prior commitment. Tese reason Text hos been moved from other embeections. for the change was to add detail which provides Ptere direct text associated with cenyllence has more specific direction on the control (s) ut illred to provide deceanents that are appro-teen added to directly regelre cleenging time priate for us .
' document if it connet be complied witte as are occarote; and, are enepiled written. with as written or chenged.
Subsect ion 3.1.3.1. The text bee been editor- 54 4
lollmed (I) to incorporate (Ine peeresee Isot a redwet ion in prior commeitam at. The reasons
[
"... within the scope of this plan ..." and " f or t he change were t o (1) incorporate revised i
... documents wIticle prescribe activities and/or terminology and pl.reseology; and. (2) provide en .
tests ..."; (2) to lacorporate tine peersee editorial chosege(s) to improve the clarity of the ,'
text of this plan.
{
"provialons
.. This responsibility incliedes enswring that
...**t end. (3) trasesfer tent to j revloed 3.1.2.(f). '
f %. Subsection 3.3.3.2 TIse text hos been revised to
! incorporate the termo "opproved doctaments". Isot a reduction in prior cosmeitment. The reason
! "empplier." " review for concurrence" and the for the changes was to 'tacorporate revised termi-ptersee "within time scope of this plan." nology and/or phrescology.
! %. Sebeection 3.1.3.3. The test lies been revised %.
to (1) incorporate tIee ptereses "... within the Isot a reductiose in prior commitment. The reesens ecope of tiels plan ...
" esed ". .. documente which for the clienges were to (1) incorporate revised prescribe activities osed/or teeke ..."; (2) to termistology and/or peereeeology; esed. (2) revise j
lacorporate the plersee "...This reopensibility text to amore directly state thle plen's regsf re-lac ments.
(3)/ odes ensuring tInst previolons ...": and.
transfer text to revloed 3.I.2.(f). <
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57 Subeection 3.2.1. CENERAL DISPOSITICII/REASCII FOR CRAfBCES The test hos been revised to 57.
f accommodete ttse replacement of hes" with 90nt a reduction in prior reassiteent. The reeeens 4
" approved documents"; to directly eyecify the Ior tie cInesegea weee to (l) laceepovate revieed
, teslas associated with "decument centrol"; and, terminology specific and/or phraseelegy; and. (2) add more tent
, to directly accommodate approved documents which to clarify and/or more directly ,
] prescribe technical or gaelity regstremente. state this plan's repiremente.
$8. Sebeection 3.2.2.1.
! The text has been empended 58.
to specifically identify la more detail the types Slot a reduction la prior commitment. The reason
$ of approved documents which regoire docessent for the change was to directly identify the control procedures. document l types wenich typically provide direction l
} 59. Sabeection 3.2.2.2. This text hos been revised and/or goality and/or techselcal rewirements.
i 59.
by (1) adding new prevlelene (a) sad (b) to Isot a redwetion in prior commitment. The reasoes i prescribe how to merk approved documents within for the changes were (1) to establish direct
! the scope of this plan; (2) reletter prevlows consistency between this plan and tine HRC 1 provielene; (3) molting two sentences; replace eccepted CPUlf resposene to Generic Letter 83-28; '
i "mesure" ~with "eneere"; replace *1 met" with (2) incorporate revised tereismology and/or j "lacorporated" la previelen (c) (previavely (a)); phraseology; and. (3) revise the text to clarify i
! (4) expending the text le previelen (3) (pre- thle plan *e regelremente. ;
i i vlosely (c)); (5) replaclag '9miset" with "ohell";
and, deleting "at conventeet locatiesis" frass provielen (g) (prevlemely (e)); and. (6) adding i
...", or" indices ...", "... states ... approved i j ... In addittee to ..."; and, inceri
- peesting "... within the scope of this plan."
i lato prevision (h) (previously (f)). ' ;
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Pane 23 of C9 CDIERAL DISPOSITION AND REASON (S) FOR i THE CNA10CES ASSOCI ATED WITN SF. VISION 2 0F THE OQA PIAff CNA10GE CENERAI, DISPOSITICOs/REAsnes Ftut CleafsCES 60.
Subsection 3.2.3.1 and 3.2.3.2. The previons 60. IIot 3.2.3.1 has been split into the current 3.2.3.1 a reduction in prior com.Itnent. m reason and 3.2.3.2. for the change was to provide dieert consistency l '
between tion plan.
this plan and the (werent CPUN organiza-bl. Stebsection 3.2.3.I. The text hos been revised 61. ht a redwetion in prior roamitsent. The reason to be consistent with the current CPUIs organi-sation plan. for the change was to provide direct eensistency betweeee this plan meed the currevet CPWII or g asilza -
tinn plan.
il 62.
Subsection 3.2.3.2. h text hos been revised 62.
to be consistent with tese current CPUlf organi- Not a redwetion in prior coeuritment. The reason i
zation plan. foe the change was to peovide dieert too.s i s t ever y between tion plan.
this plan ased the current CPUN orgmasza-
) 61. Subsection 3.2.3.3. The text was previewsly number 3.2.3.2. The text hos been revised to 63.
Not a redwetion in prior commitment. The reasons l
(1) utillae current titles; (3) replace "CPUN for the change were to (I) wtilize twerent titles:
Document Control Program" with " document and. (2) revise tese text to more clearly state ,
i I cont rol"; and. (3) replace the terse ** review" this plan's rewirements. !
1 with the term "doceanent review". ,
I 1
l 64 Subsection 3.2.3.3. Ylee test was previously i
number 3.2.3.2. The text hos been revised to 64 R__edwetion in prior commitment. The reason for replace "revlew and approvet" with "rewlew". this change was to revise this text to be directly consistent wIth the revised Appendix B of thIs text.
- 65. S d ection 3.2 y . The text has been revised to ;
65.
replaced the term "for" with the term " provide". Et a redwetion in prior comunitment. Tlie reason for the change wao to revise the text to more clearly state this plan's rewirements. ;
l 41811.
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f,ti .
Subsection 3.3.1. h test time been eevie,d ta t,6 . Et . ,ed (1) replace " Quality Assurance record" with -t s.. In y, Ior v.n-1am t . TI- rca
" record"; (2) reptoce "stens and activities" for the change were to (1) incorporate revised with "... Stees, ports, esteriale and active- terminology and/or phraseology; and. (2) add test itsee..."; (3) incorporete the phrase "within to more directly state this plass's regelrements. '
3 j
the scope of thle plan ..."; and. (4) add the ;
text "... As a sintene .... retention and j retrieval of each records."
'! E 7. Sebeection 3.3.2. The test has been revised to 67.
s ll[ Incorporate the term " approved decoments": Ilot a reduction in peler causentment. The reasons l
(2) add the terms "... Identifiestion ... for the cleange were to (1) incorporate revised i
retention and ..."; (3) replace "be described" terminology and/or pherseology; (2) add to a.ed with " provide for"; (4) sed " computer codes" to revise text to more directly state this plan's
' provision (e); (5) replace "aquelity" with regelsenents; and. (3) reletter and/or renesuber i
" acceptability"; replace "itees and activities" as a result of text additions and/or delettant. !
with " items, ports, meteriets or activities"; ;
and, incorporate the phreee "within the scope of this plan "in previolon (b); (6) delete the '
previous provision (c); U ) reletter previews provision (d) to (c) and (S) reletter the prevlees provision (e) to (d); and, replace the prevlees text after " legible" with "... In original or reproduced fore ..." ,
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1 Psen*-2% at 49 GEIERAL DISPOSITIDII AIID REASON (S) Feet TWE CaAsInsg Ass 0CIATED WITN IIEVIStest 2 0F TWE 004 plAII CSAIIGE GENERAL DISPOSITIGII/REASCII FOR t.18AfEGES
- 68. Subsection 3.3.3.I. The text hoe been revised 64.
' to (1) wee current tittee; (2) replacing the Isot a reduct ion la prior rneeritment . The reescas text efter " procedures" with tInst Indicated by for the change were to (I) revloe the test to be in prevlolon (e); (3) replacing "a program" with consletent wlth Section I; (2) add to and revloe text "peocedwres and/or lastructions"; and, adding to more directly state this plan *o rep tre-the termo "... geneestion, collection, retention ments; and, (3) lacorporate revised terminology l.
j ..." to provielen (b); (4) replacing " Quality and/or phraseology.
Assurance recorde" with "recorde"; and.
! replacing "enternal organisettone" with i "owppliers of services" to prowlsion (c); and, '
(S) add provielen (d).
- 69 Subsectlen 3.3.3.2. The tent hee been revised i 69 I to ( I ) add t he t e r mo ". . . Identification, sent a rednctinn in re for c-limmet . The ressan for the gene ra t i on . . ."; add t he piermee ". . . or change were to (I) revloe the tent t o 5.e i
j instructions"; and, replace " Director- consistent with Section I; (2) add to and revloe 4
Adelnistretlon" with "... applicable Informetion text to more directly state this plan's eepire-Menesement Center ..." la provlefon (e); and, mentet and (3) incosporate revloed terminology (2) replace " procedures wInich" with " direction end/or phroscolony.
! in approved documente"; add the teres "...
l Identification, generation ..."; add the phrase
"... with enffIctent detail ..."; incorporate the phrase "... within the scope of this plant i
end, add the phreee "with this plan" to previolon (b).
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ATTACWWWF Ic 6eng.gn-l 28.
Faste 26 of 49 muntAL CispostTinII Aasp REAgoge(s) Me TWE reasses* ASSOCIATED tdITN REVISIDIE 2 0F TWE OQ4 FI,AN ruanesr i
- 70. CENERAL DISPOSITIOW/9EASEM FUE CWeNGES j Sebeectlen 3.3.3.3.
to (t) utillse currentThe test hos been revised _
titles; (2) delete " 70.
... IInt a redesction in peler connetteemt.
and policy ..." free provielen (1); (2) add The reemens l "... and/or lastructions ..."; add the teres' for the thenge were to (I) revise the tent to be consistent with Sectlen 1; and (2) add to i "... storage and retriewablitty ..."; and to delete sad revise text to enere directly state tiels delete the prevlees test after " record" la plan's regesirements.
provision (b).
71.
Sebeection 3.3.3.4 The test hos been revised 71.
j to (1) incorporate the term " supplier"; (2) Isot a reduction in prior casueltment.
i replace "I)4" by "CFWI"3 (3) replace "to cont rol" 19e reesoses for time change were te (I) incorporate revised
- with tese penrese "... for ttee identification. terminology and/or ytermeeology; and. (2) add to I generetten. collection, eterage. malatemence, and revise tent to more directly state this plan's
{ retrieval and/or transmittet of..."; ased. (4) requirements.
sed the terus "searce inspection".
i
- 72. Subsection 4.2.2.
j 1he text hee besse revised to 72.
1 (1) replace "deelse regeletion" with "regels- Ilot a reductlen la prior coussiteemt.
- tion"; (2) add "ef fective" (3) add tese peermee The reasons
- "... utilised in, reviewe for revielen, and for the cineage were te (1) add to and revise the
- j revloed as necessary ..."d; and. (4) delete the text to more meets; and. (2) directly deletestate tent thle plan's reqeitre -
to provide direct i eentence approval of "they can only be d _-4 with specific tine IWtC". consistency of this plase with IOCFR50.59.
3 i
- 73. Subeecties 4.2.3.
The test hee been revloed b 73.
deleting "... associated computer programs . .."y Not a reduction in prior coussitament.
The reason
,,- for time cleenge use to remove the pterase becewee
( it hed the apperently poet. "; - been Snappropriately lacluded i
la not been revised.~ .... refer to 4.2.11 which lies l
l 4 7s 71, _
i
__ _ _ ~. ~. . _ . . . . - - - , ~ . _ - . . _ _ . . . _ - _ . - _ . .. ,,. - - _ ....._ _ . . _ _ _ _ .. _______ _._ _
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Feste 27 of 4's CE31ERAL DISPU5171086 AND REASOW(S) FOIt THE CRAIICES ASSOCIATED WITil 8tEVISf 088 2 0F TWE OgA ptAtt i
CEABIGE CEIEERAL DISPOSITICII/ REASON FOR CHAffCES Swbsection 4.2.7. The tent has been revised to
, 7 ta .
74 1
(I) replace the ytersee "stensterd ofI the shelf" Et a ced.ection in peine enessitment. The reasons comunercial meterial etc. ..." -ith "comunerc.at f or the change were to (8) revise the tent to amore grade item" (2) replace "oppilcation" with clearly state this plan's acapeelevements; and.
"use"; (3) lacorporate the phreee "within the (2) incorporate revised terminology end/or phraseology.
l scope of the plan ..."; and. (4) replace i
, "se lect ion" wi th **euch wee".
- 75. Subsection 4.2.8. Tlie text has been revised by 15.
adding the phrase "... and completed prior to Isot a reduction in prior coussiteent. The reason turnover for operation ..." for the chenge was to edst text to amore directly state this plen's resquirements.
- 76. Subsection 4.2.9. The text has been revised 1,y ,
- 76. Et a reduct ion in pt ior comm itsment. The s ease,n (1) adding the phrase "... Including approved fteld changes ..." to provision (b); (2) moving f or the change were to (I) add and revise time text and renumbering previoma provision (c) to to more directly state this plen's reagistre-4.2.13; and (3) addises tine phreee "... of the ments; and. (2) renesudper/re_8etter as needed to "
j accomem,dete the transfer of ter.t.
verification ..." to corrent provision c. '
- 77. Subsection 4.2.10. The text has been revised by P 77. Not a redwetion in prior commoitment. The reason edding the word " solely".
for the chenge was to revise the text to more 1 clearly state this plese's re<ystressents.
{ 78. Subsection 4.2.12. The test hos been revised by i 78.
(1) replacisig " Design and specification changee Ilot a redwetion in prior ceamitment. The reasons
" with "Chesiges to approved engineering .
for the change were to (I) revise the text to -
j decomments ..." and (2) deletisig the phrese "... more directly state this plan's resguirements; esid, j
cogumesseurate with those applied to time most (2) delete text to more clearly state this plen's recently verified design ..." rewirements. i l
t 6 7% 78.
. . - .. . . - - _ . ,. .- - _ . _ _ . . _ _ . , _ . _ . ~ _ . , . -
CTTAIWENT I 6000-RR-t24.
Fase 28 of th l CEIIERAL DISPOSITICII AND REASOIs(S) Fnt i TWE CIIANCES ASSOCIATED hlTW REVISICII 2 0F THE 004 FIAft 1
_. CLAIICE
,_ GEhERAL_ DISPOS I TICII! REASON . FUR, CRAIIGES
- 79. Subsection 4.2.I3. This test was previously j 19. Het a redwetion in prior commitment. The reeeen numbered 4.2.9.(c).
i
' for - the change was to provide for a project oriented instead of a document oriented deelga ver1fIcatlos process.
- 90. Subsection 4.2.14 This test wee previonsly j 90. Et a redwetion in prior commitment. The reason numbered 4.2.13. The test has been revised by i
the addition of the parese "... weilch include for this chenge was to more directly state this j procedure -hensee ..." plan's re wirements. ,
+
- Mt.
Subsection 4.3.2.1.(b). The test hoe been 81.
revised to delete (I) the phreee "... and the Not a redwetion in prior commitment. The reasons i
Engineering one Deelge Department ..."; and, for this change were to (1) provide direct con-j (2) add the phreee "... es any be needed ..." elstency with the current GPWIf organlastion plan; and. (2) revise the tent to more clearly state management accountability.
! R2. Subacetion 4.3.2.1.(c). The test has been 82.
- j Isot a redwetion in prior commitment. The reason revised to delete " Mete: "This design ... who -
performed the design. for this change was to delete text to more clearly I state annegement accountability.
] 83. Subsectlen 4.3.2.1.(d). The test hos been j 83.
revloed to replace " review and conewerence" with Redwetlen la prior cemeltment. The reason for the '
i " review". change was to revloe this test to be directly con-
{ sistent with the revloed Appendim p of this plan.
- 84 j
Sabeectlen 4.3.2.3. The test has been revised 84 to delete the title " Director-Engl=eering Not a reduction in commitment. The ressen for
} Assermace". the change was to revise this test to provide ,
! direct consistentcy with the corrent GFWII Y organization plan.
l 4
4757L l
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C1 AENT I
~6005 99-126 -
rage 29 of 49 CEIEERAL DISPOSIT1088 AffD REASOII(S) FOR TWg ceasaret ASSOCf ATED WITN Rf VISlost 2 OF T1IE 04M Pl.AII 4
_._ M AI. Dl_SPOSITION/R N ., @ M .ES _ ,,_.,
R4 Swheection 4.3.3. This owbeection hos been R5
! revised to indicate tInst audits of time design Not a rednetlen in commitment. The reason for control process wilf include verification of the the change was to add test to more directly state j
technical adewecy of tIee engineering prodered. the plan's reepstrements.
4
) R6 Swhse dian 5.1. The tent lose been revised to 86.
(1 ) add the termo "... Items . .. perte, consum- tent a reJwet ion in peler ensenitsuret . The reasons j
sbles ..."; (2) lacorporate the plersee "within for the change were to (1) revise the text to j
the scope of thle plan"; and (3) lacorporate unre directly state this plass's rep irements; the term " approved document". end. (2) incorporate revised terminology and/or phraseology.
4 l
) R7. Swheection 5.1.1.1. The text hoe been further
- 87. Isot a reduction in prior commitment. The reason j
revloed to (I) replace "... and shell provide measures to comply with applicable regwletory for the change was to revise the text to aw,re i re w irements ... " with "... These methode shall clearly state the plan's rewirements.
ensure that te @nical ... applicable to the procurement are me:' as a minimum ..."; (2) replace
"... appropriate mese +e steell be established to evaluate ..." with "... *%ee metloode shell j
ensure that procurement meerces a.e evaluated;
( 3) delete the phreee "... monitor tone act ivit ies of ceasettante, vendere end contractore ..." and replace with " confirm that tine activities of ..."; (4) add the phreee "... and/or compet-1ble ..."; and. (5) replace "Frogram" with " Flan".
- 88. Sobeectlen 5.1.1.2. Ylee test Ones been further 88.
l re{leed to (1) replace " delineated" with " pre- Et a reduction in prior commeitment. The reasoes
- J scribed"; and. (2) refer to 2.3 of thle place for for 'he change was to revise the text to more re wirements to determine Llee polity program clearly state the plan's rer,wirements.
rewirements.
I I
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Page 30 of 49 1
MfERAL DtSFOSITION AND REASON ($) FOR
!_ TWE CHAIICES ASSOCIATED WITN REVISION 2 0F TWE 0Q4 F rinaanrs
- M9 i Subsection 5.1.l.3. CXJIERAL DISF051TinN/REA50N pgR CnAgeGES The test hos been forther revloed to (t ) add the phrase "greded approach"; 69. Not a redwetten in prior reassiteent.
I (2) add time yhteee "... and plity ... *; for the change were to (1) add text to The reeson (3) add the phrases "... se any have been ... more upgraded ... regulatory regstrements or comunit- direc (2) girovide t ly state direct thle plee 's revleemeset s; ased, this text to the newly added mente; and, (4) adde direction en tesw to proceed 5.1.2.4 j if. gaellty and tecesitcal regstremente are not ;
aveltable; grade and (5) refers to 5.l.4 for commercial item meege.
,I 90.
1 Subsection 3.1.2. ,
j' The test has been revloed to 90.
(1) replace "dellmeeted" with " prescribed"; Not a redwetion in prior enameitment.
j (2) reploce "seewre" with "enewre"; (3) f aco r- The reasons
{ porate the pterese " regulatory regelrements and for the the textchange were to (1) add to and revise i' coenniteente"; (4) incorporate the phrase "within to enre clearly state the plan's re wir e- t I
the scope of this plan"; (5) replace " ... the ments; and phraseology.and, (2) incorporate revised termieseltwy CPUH lheelity Assurance Fregree ..." with "this i
plen"; and (6 ) add the term "... regelstory .. .** .
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.- TIIE CRASIGES ASSOCI ATED IdITN REVISIO88 2 OF TWE OQA PIAff CSABICE d
CF_9fFRAL DISPOSITICII/REA500f FOR CWAffCES
- 91. Subsection 5.I.2.2. Ylee text has been revised ..
i 95.
by (1) replacing tine yterase "... supply the Et a reduction in prior commitment. Tlee reaseen items or services that meet the design and for the change were to (I) provide direct con-quality requirements of the specification." sistency of this tent of t*is n plan with the newly wi t h t he phe mse ". . . seet the technical and added 'e.l.2.4; (2) incorporate revised termi-quality requirements of Line procurement docu- on logy a.ed/e.r gderesce.Ingy; meed. ( 3 ) add t o e wl ment (s)."; (2) replacing " accomplish" with nevise the tent to amere dieectIy state the
" prescribe"; (3) adding thee terms "... Items ...
- plan's re pirements.
' ports. consumable ..."; (4) lacorporating the phrase "within the ecope of tiels plan";
(5) replacing " reviewed med approved" by j
" reviewed for concurrence"; and (6) replacing the text af ter " commercial grade Stee" to indi-
) cate that the procurement process will be con-i trolled to ensure that (Ine 3.1.2.4 regis t rement s ;
] .
are met. '
l !
- 92. Subsect iose 5.1.2.3. Text less been revised to 92.
} (1) replace " vender" with "emppIler"; IIot a redwetion in prior comunitment. Ylee reasoses
}
(2) repInce " approve!" with " acceptance"t and, for this change vere to (1) facorporate revised i j (3) adding provision (d). terminology and/or peersseology; and. (2) add tent i t
to more directly state this plar.'s requirements.
i 93. Subsection 5.1.2.3.(c). Text less been revised
) 93. E t a redwetion in prior commitment. The reason to (1) add " identifying and reporting";
1 (2) adding the phreee "... of time suppIler dis- for this change nas to add to and revise the tent I positten of nonconformances ..."; and, to more directly state and clarify this plan's regelrements.
(3) clarify that CFWII will verify timet " repairs" legtead of " repairs a_nd ese as le" dispositions ,
j mee accomplished. '
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7mme 32 of 40 CEIEEBAL DISPOSITIcel Af8D REASON (S) FOR 1
tut Cuaficas ASSOCIATED WITN REVISioes 2 0F TWE OQA PIAft CSAIICE CENERAL DISPOSITIGII/REASCII FOR CRANCES
, 94 Subeection 5.1.2.3.(e). Text lese been revloed 94 to directly state tInst medite are weed to Not a reduction in prior consmitment. The reason verify the performonee of service emppIIers; for the che:3te was to revise the tent to more i I
and, source surveillance, source inspection clearly state this plan's rep ir-ments.
and/or receipt inspection are wood to verify the
- performance of harduore suppliers.
i 95 Seheection 5.I.2.4. A new embeection specific 95. Ilot a reduction in prior causeltment. The reeenn to the control of the use of casesercial grade i Items In nuclear safety related applications has for the chenge was to add specific requirements been added. to ensure consistent centrol of the usage of !
ca==rcial grade itees in nuclear safety related spelIcatlens.
%. Provision 5.1.3.l(c). Text hee been added to 4
t %. IIot a reduction in prior comaltment. The reason i
j directly aselga tine reopenelbility for soeuring for the change was add text to that bido are evaluated for conformance to state this plan's requirements.
ente directIy technical and quelity requiremente.
l
- 97. Subsection 5.1.3.1.(f). The text has been !
97.
revloed by (1) incorporating the yIersee "within Ilot a reduction in prior commeltment. The reasons the scope of this plan"; and (2) replacing the for this change were to (I) !acorporate revised terminology and/or phraseology; and, (2) add text j
text after "organisatione" with "Iloted on the Sspplier quality Classification List". to more clearly state this plan's requirements. i i
- 98. Subeection 5.1.3.2.(b). The piermee " review for t
- 98. Isot a redwetion in prior ceamitment. The reeson concurrence" has replaced the ytersee " approve f all." for the change was to incorporate revloed termi-nology and/or phraseology. !
V wou.
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Tite CllAIICES ASSOCIATED IflTW REVIS1088 2 0F TJE 004 FRAN
-a#
cnAleCE coereAL sistoSITtoes/REA5088 Foe Cisager.t.s-99 _
Seheection 5.1.3.2.(c). TIse piiraec " review for 99
- concurrence" has replaced th term " approve". flot a reduct ion in prior comunitment . - The reososi s
' f or the change was to incorporate crevised termi-nology and/or peeraseology.
100.
Subsection S.I.3.2.(d). The phrase " review for 100 concurrence" has replaced the ptersee " review and teot a reduct ion in prior consultam nt . The reasons accept"; and, the piireese "... as re g ired by for the clienge were to (I) incorporate revised i
applicable procedures or procurement docu- terminology and/or 7eraseology; 0 and, (2) add temi-asents..." has been added.. to more directly state this plan's regesirements. '
1 =
i 101. Subsection 5.1.3.2.(e). The text has been revised to (1) add " source" before "serveil- 101. Isot a reduction in prior commitment. The reason lance"; and, (2) replace "suppIler compliance" for the change was to add to sad revise the tent with "... Items, parts, meteriale and consum- to more clearly state this plan's resysirement s. '
4 ables within the scope of thle plan comply ..."
102. Subsection 5.1.3.2.(f). The text lies been 102.
i revised to add additionet review criterie to leot a redwetion in prior casesitment. The reason for this change was to add text !
assure identification of source veriflestion or receipt inspection and specification of minimism state this plan's requirements. to more directly l documentation to be suppiled.
103.
Subsection 3.3.3.2.(D . The test hoe been revised 103.
to (1) replace " review and concer" with " review": meduction in grier eneseitsent. The reason for i
and, (2) provide additiosnel text consistent with this change was to revise this text to be con-l I Appesadia B of title plan. sistent with the revised Appesadin 3 of this plan.
j 106 Sebeection S.2.2.3. Text has been added to 104 j
cidrify inow, when and to what entent trace- Isot a redwetion in prior coeuritment. The reason ability will be provided. for the change was to directly provide the :
criteria to consistently grade the extent of traceability required. ;
- e. um m -
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ATTACWWIIT I "
4099-05-126 j
Fase 34 of 4?
CEIIERAL DISPOSITICII AND REASOR(S) FOR TsE CaAIIGES ASSOCIATED WITN REVIS3000 2 0F TWE 0Q4 FIAII CEAIICE I CEIIERAL DISPOSITVCII/SEASOII Pgn reassnee
- 105. Subsection 5.2.2.7. The text hos been revised by (1) adding time pIerase "... utsen specified by 105. Isot a reduction in prior coespitment. Ylee reason j
procureesent documents ..."I and (2) . l. ling text for the change were to (1) add test to more to address grade items.
the receipt inspection of c-relet directly state this plan's requiremental and, ,
(2) provide direct ceneistency of thle text of this plan with the newly added 5.1.2.4.
106. Subsection 5.2.3.2. The text has been revised 106.
j by utilizing current titles. Isot a reduction in prior ceanniement. Ylee reason i
for this change mes to make thle text consistent 1 with the current CPUII organisation plan.
\
107. Subsection 5.2.3.2.(e). The test less been revised 107 i
to replace " Quality Assurance review and concur- Reduction in prior casesitmeset. Time resoces for rence ..." with " review". this change was to revise this text to be con -
106. sistent with the revised Appendin B of this plan.
Subsection 6.1. Fortions of the text from l 106. Ilot a reduction in prior censitment. Tlie reason l Revision and 3.0. 1 have been moved to Sectione 1.0. 2.0 for the change was to transfer previces text
{
without reension to other sections / subsections
! within this plan to more clearly state this plan's requirements.
! 109. Subsection 6.2.1.2.
l Tlee text has been revised 109.
by replacing " training" with "... er CFWII Isot a reduction in prior e sca teemt. 7tse reaseos i accepted quellfication ..." ,
for the change mes to revloe thr. text to more clearly state the plan's regidr,umenits.
110. Subsection 6.2.1.3. The tent hee been revised t
110. Isot a reduction in prior commitment.
by adding the phrase "... and/or examinations ..." The reason for the change was to more directly state the plan *s regelremento. '
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CENERAL DISPOSIT1988 AND REASOII(S) FOR
. - THE CRANCES ASSOCI ATED WITN REVISION 2 0F TWE 004 FIAff reanus --
CENERAL DISPOSITIOII/REASCII FUII CIBAfeGES III. Subsection 6.2.1.3. Test hos been added to permit ladividucIs reporting to supervisors Ill. Itedvet ion in prior comunitment. The ressen for 4
Ismediately resycnolble for the work to peeform the changes were it ) to provide for the laspections of maintenance activities. Also, imple-t at ten of ** Qual i t y ste int enence" t ype
! the term " examine" has been added. teams wittsowt further revision of the 0Q4 plan; and (2) to provide clarity by directly indi-i cating that the "l " 6 ". ,e" provisions apply ll2.
to " examining" as delineated in this paragraph.
Subsection 6.2.2.2.(e). The test hos been j
revised by replacing the prevlees tent after 112. Not a redwetion in prior comunitment . The reeson
" standard" with "... regulatory rewirements and for the thenne was to incorporate revised termi-comunitments; and. CpWN or CpWII accepted nology and/or phraseology.
i quellfication programs ..."
i13. ,
l Subsectlens 6.2.2.2.b and 6.2.2.3.b. These I
subsections have been revlSed to delete QA iI3. Redwet ton in erf or commeltment. The reason ior
{
review for concurrence of my maintenence and the change was to provide the direct censistency installation procedures. of this text of the plan with the revised l Appendia R of this plan.
i 114 Subsection 6.2.2.2.(b). The text has been .
i revloed to ensure that QA continued to review lla. Reduction la prior coussitment. The reason for the maintenance and leistellation documents for change mes to revise this text to be consistent incluelon of hold /and or witnese points. with the revised Appendix R of this plan. -
115. Subeection 6.2.2.3.b. The text hos been revised to eneere that QA continued to receive the 115. Redvetion in prior couaitment. TIse reason for the oppropriate work authorising A _ .ts to pro- change was to revise thin test to be consistent vig for the inclusion of hold and/or witness with the revised Appendix B of this plan.
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- ATTACWENT I 4008-80-826
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GEIERnL DISF05IT1885 AIID REASCII(S) Fna 1 TWE CEAIICES ASSOCIATED W1711 REVISIGII 2 0F TWE OQA PIAII #
i i
GAIIGE GEBIERAL DISPOSITIGII/REASCII MIR CEAIICES __
116. Subeection 6.2.2.3.(e). The test hoe been 116.
revloed by replacing time previews tent ef ter Not a redwetion in prior commitment. The reeeen
" standard" wlth "... regulatory reylrements and for the change was to incorporate revired termi-i comunitmente, and CFWI er CPUel accepted nology and phraseology.
wel3ficatIon programe."
I17 Subsectnon 6.3.2.1.(c). IIuw test hos been Inserted to re, sire that eenowre(s) be estab- i17. Not a reduction in prlor coastteent. Tone ree on Ilsh to assure QA aueranees of plant status. for the change =es to enhance ttee direct con-4 Previous (c) renumbered to (d). alstency of this OQA plan with the IIDC Standard Review Flan.
l ifl. Subsection 6.4. This subeection has been 118.
j revised to directly identify ptent cheekstry IIst a reduction in prior coassitment. TInc reason
] control and the preparation of redlooctive for the change was to directly -tete Lleet j
westes for shipment es special processee. cheelstry control activilles and the preparation
- of radloective westes for shipment are "speclat j processes" within tlee content et time 0Q4 Flen I
and that the indicated controle apply.
119 sobeectlen 6.6.1.3. The test lies been revised i
by inserting the peermee "... reawletery 119. test a reduction la prior commitment. 7 tie reason i
regelremente and ceansitments". for the change wee to incor:norate revloed termi-I nology and/or pieceseology.
- 120. Subsection 6.5.1.1.
i The test lies been revised 120. IIst a reduction in prior comunitment. W ree ons j by (1) lacorporating "... wittiin time scope of i
this plan ..."; (2) adding the peermee "... for the cimenge were (I) incorporatisig revised installed or modified ..."; (3) adding the terminology and/or peersecology; and, (2) adding
) plarese "... or instructione ..."; (4) replacing to and revising the test to more directly state j "
. beoed on regelromente and acceptonce 1imite this plan's repiremente.
co$telmedin..."with"...comeletentwithor
' incorporate the tectuelcal and gaelity reestrements ..."; and. (5) replaced " contained In" with "speciffw by".
1.__
f 4757L i
S C- Misei I s.8%-nn- 128.lc~7 -
Page 11 of 4's CEIEERAL DISPOSITION AND REASON (S) FOR
~
TWE CIIANCES ASSOCIATED WITN RF: VISION 2 0F TWE nO4 FtAN i m ._
CEANCE 121.
CENERAL DISF05ITIflN]REA50ll FUR CRANCES Sebeection 6.5.1.1.(c). The tewt has been 128.
revised to add "... test empervisor or ...". Sint a redwet ion to prior conneitment. The reason i for the change was to more directly state this j
plan's requirements.
I i22. Subsectton 6.5.2.3. The test hos been revised 122.
l by (1) utilizing corrent titles; (2) replacing ht a redartion in prinr ensumitament. The reason the work " assure" with tine word "eneere"; (1) for the change was to provide direct consistency j
adding provision (b); (6) relettering previous of t hi s QA P lan wi t h t he cor rent CPUN orgen t -
sation plan.
j provision (b) to (c) and adding "... or post meIntenance ..."
l i
! 12 L Sohsec t ios, 6.6_. l . l ._ This subeection hos been 121 revised to clarify that the calibration ht a redwetion in prior enummi t ment . The reaum requirements of this Flan apply to both for the change was to provide terminology to-installed and portable test and meesurement clarify the generic types of test and measweement
! eqwIpuent. equipment to which these reyirements of this p1an apply. ;
l 124 i
Subsection 6.6.1.2.(c). The test hee been 124 revised by (I) deleting "operatione"; flot a redwetion in prior comunitment. The reason (2) replacing " measuring" with herement"; for the change was to revise the text to clarity and. (3) replacing "... Iebeled tagged or this plan's requirements.
{
otherwise ..." with "... Identified and ...".
t 125 Subsection 6.6.1.2.f. Tent has been added.to to 125. Isot a reduction in prior comunitment. The reason l clarify that some test and messerement equipment j will not be cellbrated becewee of construction for the change was to directly indicate types of or lack of adjustability. measurement equipment to which the calibration
' I prowlsions of this plan can't be applied.
l
~
i 4151L i
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CTTACWIFWT I-6000-88-126 Fase 18 af 40-CESIERAL DISPOSITintf AND REASnH(S) FDR TWE CEAffGES ASSOCIATED WITN REVISION 2 0F TWE 0Q4 FIAll CEAIIGE CENERAL DISPOSITICII/SEASOII FOR Ceamrre i
126. Subsection 6.7.2.2.(e). The text hos been 126. ;
revised by replacing "appIIceble to" with "for leot a redwetion ir. prior comunitment. The reason the". for thls chosege was to enre clearly stote f,hls i plen's reyirements.
- 127.
Subsection 6.7.2.2.(c). The text has been revised by (I) adding tine term " Item"; and. (2) 127. Isot a redwetion in prior cosmoltment. The reseen incorporating the peersee "within tine scope of for this chosege were to (1) add tent to enre thle plan". directly state this plan's repiremente; seed, (2) lacorporate revised terminology and/or peoreseology.
j 12R. Subsection 6.9.2.2. This embeection has been 128.
j added to directly state MCF Division's tesponse- Not a reduct ion in prior commitment. The reason lbility in tlw- nousekeeping activities. for the change was to add text to directly indi-cete responsibility under this plan.
129. Subsection 6.9.2.3. The text hos been revised i 129
! by deleting "... and for identifying problems teot a reduction in prior commitment. The reason and laltleting recommending or providlag a for the change was to etlainete unnecessary
{ eolution througen deelganted channels. re i--M ;y from the text of tiels plan.
?
l 130. Sebeection 6.10.1.2. The test has been revised 130. Isot a redwetion in prior comunttment.
l by repiscing the plersee "... piecement back into Teme eceson
" with "... return to ...". for the clience was to simplicy tine tent of this plan. !
131. Subsectlen 6.IO.1.2.(c). Thle embeection has 131.
been revised to incorporate additiossel controls Not a reduction in prior casmstement. Tese reason
{ for temporary modificatione provided by ANS for ttw change was to directly prescrthe see 3.2-1982.
edditional method cf I-am M werification for p ensuring epipment hos been properly returned to' service. i i
l l i 1
1 4757L l
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Al W.981 I
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Page 39 of 41 I
CgIERAL DISPOSITIOpf Af0D REA509t(S) FUR T18E CIDABICES ASSOCIATED WITIt RrVISIf198 2 OF TWE OgA PIAff
. NM _
~tt, D_lSPOSITION/Rf*5m FOR CIIAlIGES
~
i 12. %sbeection 6.11.
, This owbeection hoe been 112.
revloed to (I) directly indicate the cylvelence Isnt a rednetion in prior conneltnant. Tene reeeon of the teres " procedure" and "Inotruetions"; (2) f or the change was to provide direct consistency
' clarify current DICF Division responsibilities; of plan.
this plen with the curreat CFille orgeniastion and. (3) establish comeletency with the current 1
CFifle organIsetIon plan.
I 133. Subsection 6.11.1.1. The text ines been revised 133.
by replacing the phrase "... designated opere- Isot a reduction in prior conseitsent. The reason d
- tions monegement personnel in each instance." to for the change was to provide direct consistency
"... Float Division Director or designee (s)." with Teclinical Specification Section 6.0 and tBee current CFWII organiant ion plan.
! 1 38.. Subsection 6.II.I.9. Time first peregraph of the l Rev. I text less been deleted. 134. Not a redwetion in prior cosmeitsent. The reason i
f or the change was to eliminate asenecessary redendency f rome the text of time plan. Refer to peregraph 4.3.I and 4.3.2.
i i
In. Subsection 6.11.1.9. The phrase "... of the 135.
modification ..." hos been inserted into the Isot a reduction in prior commitment. The reeson
) first and third line. f or the change was to clarify tenet this provision of the pless applied to modification het not meintenence octieitles.
j IM. Swi,section 6.11.3.9.
The test hoe been revised 1%. Itot a reductioon in prior cosemitment.
! by (1) replacing "... e docessent package which The reasons i includes the necessary specifications and drew- for the change were (1) simplifying time test of
- inse ..." with "... engleeering document peck- this plan; and. (2) addl.eg to and revising t9ee f oge ..."; (2) edding "... or Emetractioene con- text to more directly state this plan's regesire-ments.
e19 tent ..."; (3) replacing " design" with ,
4 "eAgineering"; and (4) adding "... winich it generated...".
4 7% 71.
- - - ~ , . - -v. - - .._a n . - ,....,..--,,n , ,-- _= . - ,_,._.._ . ._ .._ __ _ - _ _ _ . , . _ _ _ _ . _ _ . _ ___ _--- _ _ _ _ _ . _ _ - - - . .
ATT4fMENT I _
60tWI-98-126. _
Page 40 of 40 CEIERAL DISPOSITICII AIID REASCII(S) FOR
~
TWE r**Mr** ASSOCIATED IdITN REVIS3018 2 0F TIIE 044 ptAW CSAIIIIE i CEIIERAL DISPOSITIGII/REASOII FUR CHAIICES ._
137. Subsection 6.11.2.1. The following changes have been mode (I) the term "polley" has been replaced 131. Ilot a redwetion in prior enemitment. The reason by the phrase "organlaation and malatenance for the channe was to directly indicate the 4 plan" (2) the previews "(a)" hoe been deleted doc. aments that delinente the entent of IOCF involvement in the maintenance activity.
and the previews "(c)" Ines been spilt into two j separate statements..
- 138. Subsection 6.11.2.1.(e). The previews tent has
! been revised. 11R . 18nt a reduction in prior consniement. Refer to 137 above.
139. Subsection 6.11.2.1.(c). This text hos been added. 139. Isot a reduction in prior consmitssent. Refer to 131 above.
- 140. Subsection 6.11.2.1.(d). This text was pre-140. isot a reduction in ye f or cousmitment. Refer to vlously 6. II .2.I.(c).
The text has been revised 137 above.
by delettag "... maintenance and ..."; and, by
- replacing the pierase "... performed at his
' assigned station ..." with "... comeletent with the CPUlf organlaation plan."
141. Subsection 6.ll.2.3.(a). The previews text has heen replaced. 141. Isot a reduction in prior casumitment. The reason for the changes were (I) to directly indicate principle tests associated with the maintenance activity, and. (2) to directly indicate the doew-i i ments that delineate the extent of IICF' involve-ment in the maintenance activity.
i i
142. Schisection 6.ll.2.3.(b). The text hos been I
revised by replacing "... the endifIcation." 142. Isot a reduction in prior casumitment. The reason with "... time assigned work." f or the change was to revise time text to clarify this plan's rep irements.
j 4 7N11, i
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F.ge 41 of 40 CgINSAL DISPOSITION Af8tl REASCII(S) FOR 3
TIRE CEAfEGES ASSOCIATED WITN REVISION 2 0F TIIE OQA PLAl8 CEAfBGE 4 i
143. CEIIERAL DISFUSITIGIB/ REASON FDR CIIAf0GF.S
' Subsection 6.ll.2.3.(c). The text Ones been 143.
revised by (1) replacing "... tise modifications IIut a reduction in pe ler commitement. The seaswn 4 are insteIIed in accordosece ..." with for the change was to revise the text to clarify j "... Installation of a modification is imple-t his plan's requirements.
1 eented in ..."; (2) replacleeg " approved spe -
it lentione" with **engineeriseg requirements"; (3) replacing "... Teclinical Functions ..." with
"... engineering ...".
t 148..
Subsection 6.II.2.3.(c). The text has been
{ 14 f. .
t revised to require qA reinew for comenrrence Reductiose in feler ceuushmeyt. The reason for II -
of deviations from engineering requirements only change was to revise this tent to be consistent i if the deviation effects t;.e inspectability or with the revised Appendix B of this plan. '
planned laspections associated the installation.
i l '+ 5 . Sesbsection 6.ll.2.4.(a). The test hee been 145.
i revised to (I) replace time plurase " review and Redaction in prior coasmitment. The reason for the i
concurrence with ..." with the term " review- change was to revise this text to be consistent with the revised Appendix B of this plan.
4 ing"; and, (2) indicate that QA will review any i type of usintenance and installetion procedures or any work outloorising decisment within the i
ocope of this plan to provide for inclusion of hold and/or witness points.
i lu. Subsection 6.ll.2.4.(b). The text hee been IM.
revised by replacing " seed" by "and/or". IIot a redesction in prior commitment. The reason for the cheonge was to clarify Lleis plan's requirements. Both inspection a_nd emaninetion is
! seet required on s_Il installations.
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CTTACNp4!WT I 6000-#R-126.
Fase 42 of 49' CENERAI,DISFOSITION AND KEASON(5) FOR i TWE CNAIIGES ASSOCIATED WITN REVISION 2 0F TWE 0Q4 FIAff 1 r1manece CENERAL DISPOSITIGN/ REASON FOR CNAIICES 147. Subsection 6.ll.2.4.(c). Test hos been revised
) by replacing "Concorrence ..." with **Werify the 147. Reduction la prior ceamitment. The reason for j sppropriateness of ...". this change was to revloe thle tent to be con-E sistent with the revised Appendim B of this plan.
l 148. Subsection 7.3.3. The tent hoe been revised to be consistent with the current organlaation. 148. Not a reduction in prior commitment. The reason for the change was to provide direct consistency with the current GPUN organization plan.
149. Subsection 7.3.3. The text has been revised to eliminate the repirement that QA review and 149. Reduction in prior cceseltment. The reason for the concur with procedures describing the control change was to revise this text to be consistent of radioective moete. with the revised Appendim B of this plan.
150. Subsection 8.1.3. This subeection hoe been added to define when nonconformance reports do 150. Not a reduction'in prior cosmeltment. The reason not have to be used to report deficiencies. f or the change is to enthorize the use of l Such deficiencies are regsf red to be documented " verification reports" (e.g. audit, monitoring.
)
in the verification report and periodically inspection, serveillance reports) as "noncon-i analyzed as specified by Subsection 8.2.8. formance reports" la certain situations without all the prowlsions of 8.2.5 being applied to
. such " verification reports."
151. Subsection 8.2.4.(b). The sentence "...
Licensee Event Neports regelre an 1-24._Lt 151.. Reduction in prior cosmitment. The reason for the !
safety Review ..." has been deleted from the , change was to revloe this test to be consistent '
text. with the revised Appendim B of this plan.
152. Subsection 8.2.8. Editorial -? p were mode. !
They consisted of (1) adding time phreee "... 152. Not a reduction in prior cesspiteent. The reasons f or the change were (I) to provide consistent f those deficiencies addressed in 8.1.3 ..." in with the newly added 8.1.3: and, (2) to revise the first sentence; and. (2) replacing the i phrase ". . . to show gael i ty t rends . . ." wi t h t he the text to more directly state this plan's i reysirements.
phrase **... to detect adverse trends as ney be '
present ..."
47571.
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ATT Iff I GSOL . I26 Fage C3 et CC CWERAL DISPOSITIGIf AIS REASOIf(g) FOR THE CEAleCES ASSOCIATED WITE RETISIGII 2 0F TWE Og4 FEAIB J .
I CEAIICE CGIERAL DISPOSTTICII/SEASOIf FOR CWWICES
- 153. Section 9.0. 1his section hee been added to 153. Isot a reduction in pcter comtmoet. The reason
! directly delineate the mettmeds to be utilised to for the change mee to add test to more directly
! develop, implement and malatein the geselity of state the entent to utnich the plan applies to training associated with activities within the training activittee by directly identifying tIee
] I scope of thle Flan.
j j
controle to be applied to developing, conducting, 1
evaluating and doc eenting training.
. 154 Subsection 9.2.8. Text free previous embsec- 154. Isot a reduction la prior commelteemt. The reemen
- tion 2.5 has been transferred to thle subsec- for the change see to retain an egulwelent level j tion to describe the einlaus content of training of detait previously provided.
j recorde.
155. Section 10.0.Section had previously been 155. Not a reduction in prior ceummitment. The reseeme
! numbered 9.0. Editorial changes and additions for the change were to more directly etete the l have been made to (1) utilise new generet asenner in utitch audits will be scheduled and i terminology (2) more directly indicate the conducted; and. Indicate that CF W intende to j boele and content of the audit progree enintain a comprehensive performance-hosed audit i (3) directly indicate tone topical coverage and program.
i
}- f requency of bette laternal and enternal audito;
! (4) directly indicate the performance and tech- !
I nical results orientation of the audit program; and, (5) reflect the current organisation.. ;
! 156. Appendia A. Editorial changes lieve been mode as 156. Ilot a reduction in prior coussiteent. The reason i a result of adding Section 9.9.
for (*w h woe to amistain the correletten of the sections of to, pi a penwided by the ,
metrix. '
4757L c' -
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ATTAre ten 1 60no-sNt-12e, Fage 44 of 49 CENERAL DISPOSTTION AfsD RFASON(S) FOR TBE CRANCES ASSOCIATED WITN REVISION 2 OF TIIE 004 FIAN
~
1 CRANGE CENERAL DISPOSITION / REASON FOR CNAIIGES _
157. Appendix R. This appendix has been revised to provide for adjusting the timing (i.e. heinse 157. Reduc t ion in pr ior cosmal t ment . The reason for i t he change was to sid.st it ute a per toiseence based and/or after the fact) and scope of QAD review QA department overview of doc eents within the of documents.
2 scope of this plan f or a required QA departiment review f or conurrence of such doewments.
158. Appendix C: Fort 1. h Reg. Culde 1.143 statement has been revised from "fult" to 158. Reduction i n 3 r ior roms =l t ament . The reason for "modifled" degree of compliance. Refer to the change was to provide direct consistency with Appendix C. Fort 2. the Iicensing bases of TMI-I and Oyster Creelt.
159. Appendix C: Fart 2. The cesanitment to Reg. 359. Not a reduct ion in prior commeltament . The reason Guide 1.26 has been modified to clarify the extent to which more rerent codes and/or for the cha"Se was to provide direct consistency
~
standards will be utilized. with the current NRC position with regard to when 1~
upgraded codes and standards would be required to be used.
160. Appendix C: Fort 2. The comunitment to Reg.
l Cuide 1.33 was revised to further clarify that 160. Not a reduction in prior cosamitment. The reason the requirements for the minimum frequency and for the char.ge was to provide direct consistency topical coverage of the CFUN laternel audit between the units' Technical SpecifIrations and program are those provided by the units this QA Plan.
1 Technical Specification Section 6.
I
] 161. Appendix C: Fort 2. The comunitment to ANSI
' 161 Not M18.7-1976 was revised to clarify that this PInn * *
- is the " summary document" referred to in f
h age was to directly state how this 3 g~ * "'* *
! Faragraph 5.1 of that standard.
j i' f. NI. ,
ii e
_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ = -. + _ . - w s_ , - . - - ..w+ ---er,.-%.,-,s .- ---,,,..m -,,y--,,_ --w-, -,- -,,-,,n., ,v ,,,-,,_,,.~m,_,..y..
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';tusRAt. DISPOSITION AaED Rt,A500s(S) FOR -
- TWE CRAIICES ASSOCIATED WITIl REVIS10BI 2 0F TWE OQA PLAff 162. Appendia C; Part 2. The coassitueet to AffSt GENERAL DISF'51TIGIf/REAS006 Feet CSAfscES _
N45.2.1-1973 wee revloed to add portions of the: 162.
ht a reduct ime in prior caeniteent. The reason
~
1990 edition of thle standard for the wee of for the' change was te provide control for the use flutds other than water for flesshing. of f luids' ot her t han water for f lushing activities which are e<gulwalent to those already provided for the ese of water for flushing activities.
163. Appendia C: Fort 2. The comettaent to Reg.
163.-
Guide 1.58 woe revised to further clarify that Et a redwet ion in prior comunisment. The reasons plant personnet utilised to perfore visenet for this change were to (1) directly state the exseinstions for leakage moisId be apselified to atualif ications crite;ia to be utilized for non QA-the edition of ASIE Section IX and related codes department persosessel *esed to perfore the visual currently comunttted to. examination for leakage; and, (2) prevent the 164 misuse of Regulatory G. side I .R in this - sit unt lem.
Appendia C; Fart 2. The canoniteent to Reg.
164. ht a redisction in yefor roamitment. The reason Geside 1.66 was revloed to (1) clarify teint a review of a " field cleosige** to a previonely for the change was to clarify the conduct of verified design for effect on the design con- " design verif icat ion" in specif ic sitisat ions.
stitestes a design verification of these "fleid changes" which are deteralmed ta teve no etfect !
on the design; and. (2) permit not performing design verification of those field changes characterised as "unimor".
165. Appendia Cg Part 2. The couaitseet to AgeSI 165.
Reduction in prior censiteemt.
N45.2.5-1974 hee been revised to utilise Section The reason for 5.2.6 of AIISI Ml8.7-1976 and Sectien 6.6 of this the change was to recognise the e<suivalence at ,
pl in lieu of 5.6 of AIISI 1845.2.4-1974 to AleSI 18.7-1976 with AfISI 194 5 . 2 . 5 controts during c rol tl.e callbration fre<gesency of automatic the operational phase.
cut-of f lepect wreacties and held torarse wrenthes used to make esp and/or inspect high strengtle bolted cosenections.
- M-4*h de e e-w ,, g 1
i
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. CTTArsepW1:TI MM10-985-I 6 F.ege % of Av GEIERAI. DISPOSITION AND REAS010(S) FOR TWE CRAIIGES ASSOCIATED WITM Rf31S10N 2 0F file DQA PtAft CEAIIGE 166. .:
b elm C: Part 2. The casumitment to AIISI GEBIERAL DISPOSITICI5/REASCII FOR CN If45.2.13-1976 166.
has been reelsed to clarify that IInt a reduct ion in prior comunitment personnel who perfatio medits will be geselifled .
The reason to Reg. Guide 1.146. S/98 and not Afest as may be impiled.
for the change was to provide direct consist ency 1845. .2 6 .
3 within the text of time plan as it 167. Appendia Ct Fort walltications of lead auditors. selates to the 2_. . h ceameltsent to Reg .
167 Guide 1.143 hee been modified with the Imc accepted modified cemettaent to to entbe consist Redwet ion in prior commeltment.
The original design basis did change was to provide direct consistency with theT 1
not utilise Guide. the current version of this Reg. licensing bases of 1MI-l and Oyster Creelt .
' 168. A p odim Ct Part 2.
i The commitment to Reg. .
Cuide 1.144 has been revloed to clar if y that the 168.
respairements for the mintamus f repe..cy and Isot a redwetion in prior commaltment . .
j topical coverage of the CFWII internet audit for the change was to provide direct The reason i between the melts
- Technical Specificatlconsistency i
analts* TscheIcai SpecifIcatnorms. program isthe text of this specified byplan.
Section 6 of the nuclear ons and 169. Appendia C1 Part 2.
i The cosmoltmen*. to Reg.
! Guide 1.144 has been revloed to clarify that 169.
i Not a reduction in prior comunitament source serveillance is equivalent to receipt .
The reason j inspection for purposes of compaying with for the change was to provide direct consist s Regulatory Position. between the text of this plan and the Reg ency Guide commoitted to. .
170. Appendix Ct Fort 2.
j Cui The comaltment to Reg.
1.144 has been revloed to directly i170.
) Not a redaction in prior commitment. :
{ and the basis for change of the fregasency for the change orsta wasetothe revisemialamam directly state this plan's registrementsto. more the text The reason frequency, t topical coverage of the enternal medit progeme.
1 i 4
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6000 #R-125 lage 41 of 44 I CGIERAL DISPOSITI081 ASIll REASON (S) FOR THE CWAIICES ASSOCIATED WITM REVI:lott 2 OF TWE OQA PLAff 1 _ - . .
CRAIIGE . ..
1 71 Appendia D. CENERAL DISPOSIT1018/REASOff FOR_CNAferfs,,
! The pterase " review for concurr- 1 71.
Et ence" has been inserted and defined. a reduction in prior commitment. The reason i lor the change was to introduce terminology to more directly state this plan *s regiettements.
i 112. Appendis D.
4 Scae terms have been added. These 172.
terms are identified by a mergin bar. Et a redwetion in prior cosmiitment. The reason
}
for this change was to introdece terminology to
{ 171. Appendim D. more directly state this plan's requirements.
i Some terms ineve been deleted. They 173.
! include confidential-security, deelga change. h t a reduction in prior commitment. The reason notice, fleid change regeneet. CORR. ITS. 10SRG. for the chenge was to eliminate some terms which
) LER. QA Plan. QA Program s safety Related, were either replaced with revised terminology.
! Safety Grade. Safety Review Groupe, can be found in the text of the 10CFt. are 4
adequately detined within the text of this plan
! at tlwir point of use. or, are not used at alI 174 in the text of time Plan. -;
Appendim D.
The text associated with "consercial 174. Et a redisction in prior comitment. The reason grade item" Ines been revloed. The HDTE text has ,
i been revloed to (l) replace " specification" with for the change was to more directly state this
" technical regelremente"; and (2) add the plan's regelrements.
sentence " Commercial grade items. wInen used as a basic component menet be dedicated prior to operation."
175. Appendia D.
The text associated with " document" 175.
! has been revloed to (1) add the terms Et a reduction in prior commitment. The reasons I "... graphical or ottier reproductable media ... for the change were to (I) revise the test to preferibing specifyleng reporting ..."; and, more (2) incorporate directly state this plan's requirements; and.
1 (27 replace "QA record" with " record"; revised terminology and/or i phraseology.
2 .
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OTTACWENT!l 60U0-8R-I28.
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Page_48 of 4Q-.
- CENERAL DISPOSITION AND 'tEASON(S) FOR TWE CEANGES ASSOCIATED WITN REVISION 2 0F TWE OQA PLAN q
CEANGE
-. GENERAI, DISPOSITION / REASON FOR CIIANGFS 176. Appendim D. _
The test associated with "enternal 176. ht a redwetion in prior coassitment. The reason organisations" has been revloed to add the '
I sentence "... This tern le synonymous with the for this change was to introduce revised teral-j term supplier." nology to more clearly and/or directly state this plan's requirements.
177. Appendix D.
,1 The text has been revloed to delete 177. E t a reduction in prior commitment. Refer to the term "QA record." Refer to " record". Item 180.
, 178. Appendix D. The text associated with " quality classification list" has been revised te (1 ) add 178. ht a reduction in prior ccessiteent. The reasons
~ "... approved and ..."; (2) add the terms for the change were to (t ) revise the text to
"... structures ... componente ..."3 and, more directly state this plan's requirements; aewt.
(3) incorporate "... within the scope of this (2) incorporate revised terminology and/or plan ..." phraseology.
179. Appendix D.
The term " record" has replaced the 4
term "QA record". The test has been revised to 179. Not a reduction in prior commitment. The reason
' (1) add "... which has been authenticated ..."; for this change was to introduce revised termi-(2) replace the term "quelity" with " accept- nology to more clearly and/or directly state this ability"g (3) replace tine phreee "... Items phan's requirements.
!j I and/or activities ..." with "... en item, part j
material or activity ..."; and. (4) incorporate I
within the scope of this plan".
180. Appendix D.
The text associated with the tern
" supplier quality cleastfication list" has been 180, ht a reduction in prior comunitment. The reasons l
revised to (1) add the phrase "... apptowed and for the change were to (1) revise the text to .,
i cog rolled ..."; and, (2) facorporate "within the more clearly state thle plaa's requirements; and, eedpe of this plan." (2) incorporate revised terstoology and/or phraseology.
e s.
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-nase 49 of 49 i CENERAL DISPOSITION AND REASON (S) FOR i-TER CEANGES ASSOCIATED WITE REVISION 2 0F TWE OQA PIAN CRANGE
! CENERAL DISPOSITION / REASON FOR CEANGES 181. Su >plements 1 and 2. These supplements have been deleted to reduce the level of specific 181. Not a reduction in prior cosmitment. 'The reason j organizational detail, for the change is to minimise the need to revise this plan when organisational changes occur within divistor.s currently depicted on Figure 1 of Section 1.0 of this plan.
1 i
182. M ndix C3 Part 2. The phrase "within the scope 182. Mot a teduction in prior commaltment. The reason of the plan" haq replaced the phrase "important for the change was to incorporate revised termi-to safety" in the second paragraph of the text nology and/or phraseology.
' associated with exception 1 to the Regulatory Cuide 1.39 consitment.
183. Appendix C3 Part 2. h commitment to ANSI t
N45.2.2 has been revised to clarify that personnel 183. Not a reduction prior cosmitment. The reason for-
! who perform audits will be qualified to Reg. the change was provide direct consistency within
+
Cuide 1.146, 8/80 and not ANSI N45.2.6. the text of the plan as it relates to the qualifi-cations of lead meditors and auditors.
i 5
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Al .dMENT 7 1 6(NM)-MM-IIt.
Fame I of 9 JUSTIFICATION FOR C5ANGES ASSOCIATED WITN *EVISION 2 OF TWE TNAT REDUCE TBE COPMITMENTS FREVIOUSI.Y ACCEPTED BY THE IRC IN REVISION I 0F TITE OQA PLAN CHANGE RESULTING Ilt A REDUCTION (5) 14 JUSTIFICATION Provision 1.5.1.(a). Previously 1.6.1.1.(f). 14.-
The phrase " review and acceptance" has been The documents involved include those which replaced by " review of selected" to be consist- prescribe methods to implement this plan's ent with the revised QA document review strategy. requirements; and, those which prescribe quality i
Refer to Appendix B. requirement for items, parts and materials within the scope of this plan. Refer to 3.2.2.1 of this plan for a delineation of such docweents
, affected and 3.2.2.2.(c) of this plan for a delineation of the general control specified toy this plan to essere that such documents are appropriate for use.
j A performance based review process will be used by Quality Assurance to
- maintain an overview of the adequacy ai such documents produced. Refer also to item 157 of this attachment.
[ 16. Provision 1.5.1.(I). Previously 1.6.1.1.(1).
- 16.
j The phrase " review and acceptance" has been The specific documents involved incInde design 1 replaced by the phrase " review of selected" to and engineering documents within the scope of
{ be consistent with the revised QA document this plan. Refer to 3.2.2. I .(f). (a). (h ), and review strateBy. Refer te Appendix B. (1) of thle plan for a delineation of some of l
l
. such documenta effected. A performance based i
review process will be used by quality Assuracce l to maintain an overview of the adequacy of such documents as prescribed by Appendix B and 4.3.3 of this plan. Refer also to itee 157 of this attachment.
l
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t ATTACIDENT 2.
6000-88-126- "
)
Fase 2 of 9
' JUSTIFICATICII FOR camamset AqSOCIATED WITH SEVISION 2 OF TWE OQA PIAff -
TEAT REDUCE TWE CGOWIITIENTS PREVIOUSLY ACCEPTED BY THE Imc IN REVISIGIf I OF TWE 0Q4 PLAll i
,i CEAlfGE RESULTIllG IN A REBUCTION(S)
JUSTIFICATI0ff t
it.
Provision 1.5.1.(l). Previously 1.6.1.1.(m). 17.
The phrase " review and acceptance" has been The specific documents involved include procure-j replaced by the phrase " review of selected" to ment documents within the scope of this plan.
i be consistent with the revised QA document Refer to 3.2.2.1.(i) and Appendia B of this plan review strategy. Refer to Appendia 3. for a delineation of some of such decismente 4 '
affected. A performance based review process 1
{ will be used by Quality Assurance to malatein~ae j
i overview of the adequecy of such documents as
- prescribed by Appendim B and 5.1.3.2.(f ) of this plan.
l
- 18. Subsection 1.5.2. The quotification require- Refer also to item 157 of this attachment.
- 18. - t ments for the Director - Quality Assurance The asaregate amount and type of experience poJtion has been revised to increase the years directly required by this plan for the position 1
( of tecn=*::', supervisory and managerial of Directer-Quidity Assurance has been increased.
i experience and decrease the years of quality The amount of supervisory and/or manageriet i
assurance experience required for en individual experience required reflects the leaderehty role ;
to assume the position. required of this position. The spe::ific Innow- !
ledge of assurance activities (refer to 2.2.2 of this plan) previously reflected by five years of ,
quality assurance emperience has been retalned.
{ although the amount of quality asserance
- j
' emperience has been reduced.
- 27. Subsection 2.3. This text was previously numbered 2.3.1. This text has been revloed to delete 27. i Refer to the justifications associated with items
! ... concurred with by the quality Assurance 14 and 157 of this attachment. -
Department ... Safety ..." and replace with
"..p reviewed by the quality Assurance Department codsistent with Appendix 3 of thle plan." ,
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A'. JW:NT 2 MM10-88-ISv-l%ge I of 9 JUSTIFICATION FOR CEAlfGES ASSOCIATED HITE REVISION 2 0F THE DQA FIAN i
THAT REDUCE TWE COPSIITNENTS PREVIOUSLY ACCEPTED BY TBE 3RC IN REVISION 1 0F THE OQA PLAN CHA10GE RESULTIIIG IN A REBUCTIOW(S)
I JUSTIFICATIOff
- 40. Subsection 2.10.1. The test was previously
- 40.-
i numbered 2.8.1 and 2.8.2. This text has been CFUM desires that prescribed requirements'for the-revised to (1) incorporate the term " technical conduct of the technical and independent safety review portions of the safety review prosram he 4
t review"; (2) Incorporate the term "CFWII Review and Approval Matrim"; (3) incorporate the tern contained only in Section 6 of the Appendix A, i
" independent safety review"; (4) replace "first" Technical Specifications. The term "CP'NI Review !
and "second" by "first"; (5) replace the phrase and Approval Natria" is used in Section 6 of
"... all activities important to safety including Appendix A. Technical Specification.
design work or changes, plant operating, emergency
^
and alare procedures, radiological control The content of this matrix, which defines what procedure and plant maintenance procedures" with gets a technical review and an independent safety
-review, i !
)
"GPUN Review and Approval Matrim"; and, s directly prescribed by Section 6.cf j (6) replace the sentence "... This review will the Appendix A Technical Specifications. .
be performed on all written safety evaluations .
for design work or changes, tests and experiments The safety review process is currently prescrit.ed and procedures as described in the Technical by a corporate procedure (1000-AEWl-1291.01).
Specifications." with "CPUN Review and Approvst This procedure prescribes how the Appendix A Matrix". Technical Specification requirenents will be met.
This procedure is originated by the Director-Planning 6 Nuclear Safety and approved by the Office of the President.
As an example, the description of safety reviews i in Section 2.10 of this Operational Quality ,
Assurance Flan is consistent with TMI-I Technical
.Specifleation Amendment 141 as recently issued by the NRC.
l I
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I C.TTACWIENT 2 H T-6000-98-t26'.
Page 4 of O ~'
JUSTIFICATICII FOR CBANGES ASSOCIATED WITN REVIStGIl Z OF-TWE OQA FIAII l
> TWAT REBOCE TWE C0f0ft1MENTS PREVIOUSLY ACCEFTED BY TBE -
IIRC IN REVISloff I 0F TWE 00A PIAII -
.e_:-
- r - . y a CHA;4GE RESULTIIIC IM A RESUCTIGII(S)
JUSTIFICATIGII
- 64. Sabeection 3.2.3.3. The text was previously -
64.. - Refer to the justification associated with
' number 3.2.3.2. The test has been revised to replace " review and approval" with " review". items 14 and 157 of this attachment.
- 83. Subsection 4.3.2.1.(d). The text has been 83. Refer to the justification associated with revised to replace " review and concurrence" with
- review". items 16 and 157 of this attachment.
103. Subsection 5.1.3.2.(f). The text has been revised to (1) replace " review and concer" with " review"; 103. Refer to the justification associated with and (2) provide additional test consistent with items 17 and 157 of this attachment.
Appendix B of this plan.
, 107. Sutsection 5.2.3.2.(a). The test has been revised
! 107. Refer to the justification associated with to replace " Quality Assurance review and. concur-rence ..." with " review". items 14 and 157 of this attaclument.
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. Al .W.NT di s MMWi-88-12h rage 5 of 9 JUSTIFICATION F11R CEANGES ASSOCIATED WITW REVISION 2 0F THE OQ TNAT REDUCE TWE Cof9flTMENTS PREVIOUSLY ACCEPTED BY TME i
ISC IN REVISION 10F TIIE OQA FIAff CNANGE RESULTIIIG IN A REDUCTIGII(S)
JUSTIFICATION 111. Subsection 6.2.1.3. Test has been added to Ill.
permit individuals reporting to supervisors CPUN is emphasizing that the emnegement and per-lamediately responsible for the work to perform former of an activiity be directly accountable i
inspections of maintenance activities. Also, for the _ eguality of the performance of such j
the term examine ** hee been added. activities / tasks within the scope of this plan.
j One indication of this emphasis is this revision of this Operationet Quality Assurance Plan.
i 2
j j
To reinforce this emphasis, this plan has been
- revised to allow the workforce and/or workforce I supervielen to inspect malatenance work which they perform. Neuever. Quality Assurance will conduct a performance based overview of ahe.
i
' conduct of such inspection.of maintenence activities by the workforce and/or workforce ..
supervision. Such an overview would resett in the total reassiemption of laspections conducted of maintenance activities if degradation in the conduct of inspection by non QA personnel or the sguality of maintenance conducted was detected by such QA overview activity.
i
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-ATTACHNENT 2' 6000-88-126 Page_6 of C 3
JilSTIFICATION FOR CEANCES ASSOCIATED WITE REVISION 2 OF TWE OQA PLAN TWAT REDUCE TWE C0f0llTIENTS PREVIOUSLY ACCEPTED BY THE-IRC IN REVISION 1 0F TWE 0Q4 FIAN CNANCE RESULTING IN A REDUCTION (S)
JUSTIFICATION ' '
)
113. S_ubcettlons 6.2.2.2.b and 6.2.2.3.b. These 113.
subsections have been revloed to delete QA The documents involved are those which specify j
j review for concurrence of a_I_l, maintenance and general administrative controls associated with installation procedures. maintenance and installation; and. those work authorizing documents which prescribe specific direction to conduct a specific maintenance and 4
4 installation task (s).
I A performance based review process will be used-
' by quality Assurance to maintain an overview of the ade w y of such documents as prescribed by
) Appendix R and 3.1.2 of this plan. Refer also i to item 157 of this attachmerit.
!'r in addition, CPUN QA currently receivec and will l continue to receive work authorising documents i
}
assoclated with meintenance and installetion j
uhich is within the scope of this plan (e.g.,
"shert forms," " job tickets," meIntenance
! schedules, etc.).
! Each of these work author-I ising documents w!!I continue to be reviewed to provide for the inclusion of inspection hold and/or witness points.
114 Subsection 6.2.2.2.(b). The text has been 114. Refer to the justification associated with revised to ensure that QA continued to review item 113 of this attachment.
maintenance and installation documents for inyosionofhold/andorwitnesspoints.
115. Subsection 6.2.2.3.b. The text has been revised 115. Refer to the justification associated with to ensure that qA continued to receive the appropriate work authorising documents to pro- item 113 of this attachment.
vide for the inclusion of hold and/or witness points.
~
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Page 7. ni 4
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' JUSTIFICATION FOR CRANGES ASSOCIATED litTE REVISION 2-OF THE ~
TEAT REDUCE TWE CENSIt1MENTS PREVIDUSLY' ACCEPTED RY TWE NRC IN REVISl0M i 0F TNE OQA FIAN ~ -1
~
! CRANGE RESULTING IN A REBOCTION(S) 144 JUSTIFICAff0N ~
Subsection 6.11.2.3.(c). The text-has been 144.
! revised to require QA review for concurrence Refer to the justifications associated with - '
of deviations from enginee requirements only items 16, 113. 115-and:157 of this attachment.
if the deviation affects tr espectability or planned inspectlone assocf . the InetalIation.-
- 145.
+
Subsection 6.It.2.4.(a). The text has been 145.
revised to (1) replace the' phrase " review and Refer to the' justifications associated with
! i tems 14,113,115,144 and 157 of tiils
! concurrence with ..." with the term " review- attachment.
Ing"; and, (2) Indicate that-QA will review any type of maintenence and installation procedures
~
or any work authorising dociament within the
' scope of this plan to provide for inclusion of _
hold and/or witness points.
147. Subsection 6.II.2.4.(c). Text has been revised i 147 by replacing " Concurrence ..." with " Verify the Refer items to the Jeetificatione associated with appropriateness of ...".
I 149. Subsection 7.3.3. The text has been revised to
! 149. Refer to the justifications associated with eliminate the requirement that qA review and concur with procedures describing the control items 14 and ISS of this attactueemt.
of radioactive easte. '
4 l
151. Subsection 8.2.4.(b). The sentence "... 151.
Licensee Event Reports require an F-f-g.i ..t Refer to the justifications associated with Saf9ty Review ..." hee been delet d from the item 40 of this attacliment.
text.
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ATTACWWWIT 2 t
6000-08-126 4
Page 8 of C JUSTIFICATION FOR CSAIIGES ASSOCIATED WITE REVIS10Il Z OF TWE OQA PIAll
- TEAT REDUCE TWE COMIt1MENTS PREVIOUSI.Y ACCEPTED BY TWE Imc IN REVISIGIf I OF TWE OQA PIAN C5ANGE RESULTING IN A REBUCTION(S)
, JUSTIFICATION ~
157. Appendix B. This appendix less been revised to 157.
provide for adjusting time timing (i.e. before This QA document review strategy is justiftsble and/or af ter the fact) and scope of QAD review 'on the basis that the preperation and technical i
of documents. review of the ac,c n ..ts include the account-j ability for the technical and adminletrative 1
adequacy of tine document. This includes time 1
document's conformance with QA Plan requirements.
! Refer to 2.11.6, 3.1.2, 3.1.3.1 and 3.2.2.2.c.
i The proposed revision would attow QA to perform i
document reviews after rather then before a
- document is approved for use; and, to review only a sample of documents, winen justified by.
l the quality of the documents produced without l QA review for concurrence. This ultimately -
i
' would allow CPUII QA to overview the performance i of the process of providing documents which are !
appropriate for use rather than being a sub-1 stantial portion of that process'.
,'i Current results indicate that QA cannot and would l not lausediately back oct of all document reviews conducted.
- 158. Appendix C Part 1. The Reg. Culde 1.143 158. Refer to the justification provided for item i
4 statement has been revised from " full" to 167 of this attachment.
" modified" degree of compliance. Refer to l A ndix C Part 2.
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6000-88-1St.
Page 9 of 9' JUSTIFICATICII FOR CBANGES ASSOCIATED WITN REVISION 2 OF TWE OQ .
TNAT REDUCE TNE Cof9fITMLPTTS PREVIOUSt.Y ACCEPTED BY THE ISC IN REVISION I OF TWE OQA PLAll CNAIICE RESULTING IN A REBUCTICII(S) 1 JUSTIFICATION-i 165. Appendix CI Fart 2. _
i
{ The commitment.to AIISI 165.
M45.2.5-1974 has been revised to utilize Section The frequency of use of such torque wrenches for i
{ 5.2.6 of AIISI Ml8.7-1976 and Section 6.6 of this makeup and/or inspection of high strength botted
' plan in lieu of 5.4 of AIISI 1845.2.4-1974 to connections is currently low with respect.to the control the calibration frequency of autometic construction phase. As such the requirements of.
{
cut-off impact wrenches and held torque wrenches ANSI Ml8.7-1976 are equivalent to the require- '
- sed to make up and/or inspect high strength ments of AllSI N45.2.5-1974 for.such frequency of' use.
bolted connections.
a t
167 Appendix CI Part 2. The commitment to Reg.
167.
~
Cuide 1.143 has been modified to be consistent The original design basis of Oyster Creek and i
with the IIRC accepted modified commitment to 1Mi-1 did not include-this specific Regulatory
{ Reg. Guide 1.26. The original design basis did Guide. To provide direct consistency with this not utilize the current version of this Reg. basis, this exception is being taken. The text
' Guide. of this exception is consistent with the revised CPUff l.26.
position with respect to Regulatory Guide That position is consistent with the current NRC position with respect to the use of revised codes, standards and/or technical l requirements.
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4 760L _ _ _ _ . .
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CPUN Respose2 to Ims,-
Amento on Rev. 2 e.f CPUN 094 Flam Itovember t. 1988 4
SUBJECT:
Ltr.; U. V. Johneten (IEC) to M. B. Roche (CPUN) dated June 14. 1993 ATTACNMENT 3~
i 6000-88-126 i j
NRC a""*TICII/REGUEST Fact I of 3 ._ i RESPcISE
- l. __
j Replacement of the terme " review for approvel" 1.
and " review for concurrence" by " selected review" h term " review" as it relates to document review in Subsection 1.5.1. can occur before or af ter the document le approved
( for use. h penrese " review for concurrence" as it relates to document review occare before the ,
document la approved for use. h term " selected" l as it relates to docuseet review meses that not all i
documente of tkst type within the scope of the plan will be either " reviewed" or " reviewed for i
' concurrence."
Teut revloed. h yterese " review for concurrence" t l hoe been added to Appendim D, med; defleed as "A review of a document c== ducted prior to that document beleg approved for use. A review comented by seme-one other thee the ledivident who propered; or, will approve the document for use." '
\ Refer also to queetton 10 of Attachment 2.
t 2. Replacement of five yeere " quality Assurance" l l 2. Test revised.
experience with 10 years of esperience which Section 1.5.2 hos been revised to read:
( require levolvement le the esaurence of the " N Director-Quality Assursees shall have. as a leptementation of Quality Assurance Flam mielua, a baccalaureato degree la Easiseerlag or requiremente in Section 1.5.2. Science, with at least fiftece(15) years of technical esserience tecludies tem veere of menemertal/ ;
! esservi s , esperience le escrettemet. technical w I
l port and/or emelity escurance activities associated with aucteer power pleets. At least see weer of this i l emperience sheII be la a IInclear Gustity Assurance -
j oramelsattom or e special treintea -==aram approved
' by the Director. Gaelity and Trefales will be completed withis six months of assumien the position. !
Additlemally, time Director-quality Assurance must be knowledgeable le operating license conditions, other regulatory requiremente and comalteente, plans i procedures and quality and technical etmedards."
t 4526L Refer also to Question 9 of Attacheemt 2. _
I
. - - - . _ _ _ _ _ _ - - - -_-___-_1
CFWI tesponse to IEC r====nto en Rev. 2 of CFWI 0Q4 Flen november 1. 1988
SUBJECT:
Ltr.; U. T. Johnston (IEC) to N. B. Roche (CPUN). dated June 14, 1998 ATTACWWHT 3 6000-08-126 IEC - _ _:s IGN/ -
2---_ _: a FACE 2 of 3
- 3. RESPOWE Changing the safety review requirements without 3.
- providing the rationale la Section 2.10. GFWI desires that prescribed requiremente for the conduct of the technical and ladopendent eefety review i portions of the safety review program he contained only la Section 6 of the Appendia A. Technical-Specificatlees.
i, The phrase "CFWI teview and Agyroval Metrim" le used in Section 6 of Appendim A.
Technical Speciftestion.
As se esseyle. The descrip-tion of safety reviews in Section 2.10 et the OQA Plan le comeletent with IIII-t Technical Specification Amendment 141 as recently teamed by the IRC. Refer i
also to guestions 33 and 37 of Attachment 2. i t
{ 4.
i Changing biennial review of plane, procedures 4. Text revloed. CFWI withdreue this proposed change and 3.1.2. instructions to four weer reviews in Section at thle time. ;
It is currently planned to resubmit j thle proposed revielen at eene fetere time. The
! test will be revloed to that ehleb was previously approved by the ISC.
1 l 5.
Changing QA la line review to selective review 5.
by QA in Appendix 3. aeter to the roepenses to questious 10, 26, 45, 46 and 47 in attachment 2. i
\
l 4626L
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CPUN i _,_ : 13. Int.
_amento on~Rev. 2_of CFWW SQA Plan- -u November 1..1988-
~
e.
I -
4 SURJECT: _m _ . . _
Ltr.; U. T. Johnston (IEC) to N. R. ' Roche_ (CPUN) dated June 14.'1988 ' ATTACW WsT 3 1 '6000-88-126 150 ---- FACE 3 of 3 IGNi- _ _ _ a _ _
! 6.
RN '~
{
Taking exception from the biennial procedure 6.
review requirement of AISI N 18.7-1976 paragraph Test revloed. Change withdraum.. Refer also to pes--
5.2.15 in Appendim C - Part 2.. tion 4 of thle attachment.-
{ 7.
Taking exception from the Weekly Calibration 7.
requirement for torque wrenchea in Section 5.4 Refer to the response to question 15 of attachment 2.
{
i of ANSI 45.2.5 - 1974 and moire frequency based j on manufacturer's instruction and usage without i
providing any additional controle in Appendix C - Part 2.
a i 8.
! Changing full Compliance to Regulatory Guide 8.
1.143 to Modifled Compliance in Appendix C - Refer to the response to question 53 -in Attachment 2.
i Part 2. '
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9 46261.
. .. __ ,__ _.. _, __ . _ . - . , ~ , _ . _ , . . . _ . _ . . . . ~ . _.,. - .- . _ . . .. . _ _ _ .__._,_.._a_
CPilN A xpensa to NRC sta on Ocv. 2 of CPtNf OQA Plan Now.aber 1, I988 f
SUBJECT:
Seyneur N. Weiss to P. R. Fiedler, dated August-5, 1988 ATTACNMUti 4 6000-88-126 pac [1 of 26 1 _
i
-NRC QUESTION / REQUEST i
RESPOIISE
{ 91-8.
- i j See letter dated Junef rom NRC (Johnston) to CPUN (Roche) 14, 1988. 1-8. Refer to attachment 3. '
( 1 i
- 9.
Clarif y which organizations are at the plant 9.
sites and which are offsite and the responsi- Text revised. Figure I has been revised to reffert bilities of each. This assy require lower tier i
! the current divisional striscture but has not been organization charts. (IAS) revised to increase its detail. As noted in Section 1.0 all divisions have some site represen-
- i. tation. .
'4
- Text revised. The previous Figure 2 has been restored and revised to provide more detall as i
i requested. It provides the QA Department organiza-tional structure.
Also, c_larify that the Director-Quality Assur- Text revised.
ance will have at least t year of emperience in Refer to the response to Question 2 a nuclear power plant QA organization before of Attactument 1. Requested clarification provided.
appointament or describe what steps CPtNI will tale if not. (IC2) l l
Identify, by position title, the QAD person i
onsite who is responsible for the onsite QAD _ The Director of QA is responsible for_ all QAD activities at TM:-1 and at Oyster Creek. (IC3) activities. His principal "onsite" representative l is the respective Manager Mod / Ops QA. Refer to =
I Figure 2. '
i l i
i l i
i n
l . .-%. ..
46271, -
- * ^ * * *
- 1 s
CFtNI Exponen to NRC cammanto on Rev. - 2 cf CPINI OQA Plan ~
",,_-1:r
- 1. I988 .
SUBJECT:
Seymour N. Weise to F.
l -
B. Fledler, dated August 5. 1988 ATTACNNENT 4 l 6000-88-I26 i
FACE 2 of 26 NRC vansTION/R-- sai
RESPONSE
10.
j Section 1.5.I(g). (i), and (j) indicate that 10.
QAD will review selected prescriptive docu- Text revised. Refer to the revised Appendix B on ments, design and engineering decommente, and the following pages.
j 1 procurement documents, all within the scope of the OQAD. The proposed revision would allow QA to perform j
i document reviews ofter rather then before a document '
! Stendard Review F1an ($2F. NUREG-0000) itens ie approved for use; and, to review only a sample IBic. 2Bla and b. 3E3. 4A1. and 6A2 from 17.1 of documenta, when justifled by the gensIity of the and 17.2.6-2 indicate that, for items within documents produced without QA review before approval i
' the scope of the OQAF QAD should review all for use. This ultimately would allow CPING QA to such documents, overview the performance of tese process of pro-viding documents which'are appropriate for wse rather than being s substantial portion of that Justify QAD's review of only some of these docsiments indicate who (by position title) decides which documents will and will not be This QA document review strategy is justifiable on
(
reviewed, and provide the bases for the the basis that the preparation and technical review decisions. of the documents' include the accessetability for technical and administrative adagescy of the document.
This includes the doc eents' conformance with QA Plan requirements. Refer to 2.11.6. 3.1.2, '
3.1.3.1 and 3.2.2.2.c.
Current resvits indicate that QA cannot and would not Ismediately back out of all document reviews conducted before the docessent is approved.
With respect to " review" instead of " review for concuppence." describe how CPUN resolves situs- Resolution of differences of opleton(s) as it tions*where the QAD reviewer disagrees with the relates toprovided metters associated with the OQA Plan is docisment being reviewed. (see question 5) directly for in 2.11.8. Refer also to the last paragraph of 2.1. which more directly states the authority of the Director of QA in such metters.
4627L - - -
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_, . - . __ _ . , . ~
. - -m CPUN R2sponsa to NRC s '
sto on R2v. 2 ef CPING OQA Plan -
~
November I. 1988
SUBJECT:
~
Seyneur N. Nelse to P. B. Fledler, dated August 5, 1988 ATTACIONENT 4 '
6000-RS-126 FACE 3 of_26 _
NRC QUESTION / REQUEST REsteIISE
- 10. (Continued)
- 10. APPENDIX B - Text QAD shall selectively review documents which prescribe methods to implement activities within
- the scope of this Flan or provide the quality and/or technical registrements for items, parts, materials and activities that are within the scope of this Plan. The purpose of evch reviews is to verify that such documents are consistent with the requise-l ments of this plan.- The minimism content of a QA l document review, as appropriate to the document _
reviewed, is provided in Subsection 3.1. 2, 4. 3. 3, i 5.1.2.3.(e) and 6.2.2.2.(b) of this rien.
The types of doctaments typically reviewed inclewle j plans, procedures and instructions, procurement documents; worit suthorizing documents, and changes; etc. Refer to Section 3.2.2.1 for specific types of decisments which will periodically be verified
{ by QA doctsment review.
j QA review of documents within the scope of this plan j may be conducted before or af ter the doceements leave -
4 been approved for use. Furthermore. QA may review all or a sample of specific types of documents within the scope of this plan. The timing and scope '
- of the QA reviews shall be based on the teclenical
- and administrat ive sac g
- :y of the doctaments pro-i duced without QA review for concurrence.
i A QA Department procedure approved by the Director, i Quality Assurance, shall prescribe the process for measuring the adeqisacy of decisments produced with-i out QA review for concurrence. Tleis m?asure shall i, be based on the comment types and rates resulting it from QA reviews of such documents. The procedenre
[ 6627L l
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- - ,= - _ _ . __
CPING Response to NRC Ceaumento on R:v. 2 cf CPUN 0Q4 Plan ' '
t Movember 1. 1988 .
SUBJECT:
Seymour N. Weiss to F. B. Fiedler, dated August 5, 1908 ATTACHNENT 4 6000-88-I26 IEC QUESTION /REver.aT FACE 4 of 26 _ .i
! RESPONSE
- 10. (Continued) 10.
APPENDIX B - Text (Continued)
~
shall include requiremente for maintaining a data-base aufficient to provide for the measurement of adeqinacy. The procedure shelI also prescribe periodic adjustments in the timing and scope of QA reviews of specific types of documents based on their measured technical and administrative adegenacy.
s This procedure (s) will also ensure that QA reviews i
of doctaments be consistent with the following:
o Some plans, procedures and/or instructions are i
required by this OQA plan to be " reviewed for
' concurrence" by the Director of QA. Such docu-mente and changes shell be reviewed by QA prior to implementing approvet. Other plees, proce-4 deres, and/or instructione and changes thereto l
may be reviewed for concurrence by quality Assurance. These documents eheti be~identifled on the CPUN Review and Approvat Matrix.
t o
l Changes to the quality closelfication proce- '
1 dere(s) and the SpWN Review and_ Approval Matrix ehall be reviewed for concurrence by the
! J Director-QA prior to implementation of the i
e change.
- -o Procurement, usintenance and installation docu-l
' ments within the scope of the plan shalI be reviewed by QA prior to authorization for use to provide for the inclusion of inspection hold and witness points. Changes to such decomments which affect these hold and witness points will be reviewed by QA prior to implementing the Ag,27L *Mnge. ~
I
~
l -: a -
l~ _- _-.
CPUN Responne to NRC _asts on R v.
November I, I988 2 of CPUN HQA Plan
SUBJECT:
Seymour R. Weiss to P. B. Fiedler, dated August 5, 1988 6000-88-126 i -
FACE 5 of 26
] . _ _ _ _ _ _ _ _ NRC QUESTION / REQUEST
' RESPONSE
- 11. Clarify whether designated QA individuals rou- _
11.
t inely attend anel ,certicipate in daily plant Text to read:revised. A new 6.3.2.1.(c) has been inserte.1 work schedule and status meetings to assure " Assuring that adequate awareness of that the QA organization is Sept abreast of plant status is maintained by site QA Management day-to-day work assignments throughout the plant through discussion with plant personnel, attendence at i
and that there is adequate QA coverage. (186) status meetings, etc. to permit the definition ,
[
of appropriate real time monitoring activities."
The previous 6.3.2.1.(c) has been renumbered to
! .j 6.3.2.1.(d).
Also, QAD stop work authority in Section l
1.6. I . l(c) of Revision I of the plan does stot Stop work authority is in Revision 2 of the QA appear in Revision 2. Clarify. (184b) Plan. Fefer to 1.5.l(e).
12 section 2.5.2 addresses revisions to the plan 12.
and is generally responsive to 10 CFR Text revised. The foil wing phrase will be added i
I
- 50. 54 (a )(3 ). "... identifying the change, Lly reason for the change, and the basis for concluding that the
' However, the requirement of the regulation that revised program incorporating the change continues the forwarding letter submitting plan changes to satisfy the criteria of 10CFR50, AppeneN B and to the NRC must inclued reason for the change the Safety Analysis Report quality assurance does not appear in Section 2.5.2. Clarify. program description commitments previously accepted by the NRC...." .
(282 per 50.54)
Also, the Revision I coausiteent to meet 3
Appendines A, B, and R of 10 CPR 50; 10 CFR Refer to (1) introduction (2) definition of 50.49; and Subpart E of 10 CFR 71 does not " regulatory required" in Appendix D (3) Faragraph 2.2.2(4) Paragraph 3.2.2.l(a) & (j) and (5) appear in Revision 2. Clarify. (283)
Section 7 of the plan.
13 Page 1 0.0 of the plan includes a new clarifi- 13. Tent revised _. The current text of 6.2.1.3 provides cation of CPUN's commitment to NRC Regulatory i
Guide 1.58. NRC accepted provisions for controlling the use or j conduct of " Inspections" by individuals who are not Clarify that the use of plant operation per- part of the QA organization. As suggested, the term sonnel performing ASME Section XI visual leak- " examination" will be added to provide further j clarity.
age examinations meet the concepts of items In2-185 and 1981 of 17.1 and item 2 of 17.2 of the SRP. (283) l
, . . , . - - , . . . . - ~
9 CPUN R:eponse to NRC Comument8 on Rev. 2 ef CPUN OQA PIen !
Novesber I,1988 l
SUBJECT:
Seymour W. Weise to P. B. Fiedler. dated August 5.1988 ATTACEMENT I
?
' 6000-88-126 PAGE 6 of 26 INtc QUESTION /REa"**T
RESPONSE
- 14. Pass 111.0 of the plan states that " Field j
- 14. Test revised.
' changes ;%et meet the bounds of Paragraph 7.2 (of N45.2.It ? will not be design verified." 2.
Paragraph 7.2 reie-e to both "significant Sections 6.2. 7.2 and 8.0 of ANSI N45.2.11
- changes" and " minor ca. M es." Clarify what is l neant by " field changes the* meet the bounds of Each of the above sections reiterate the need to l Paragraph 7.2...." (283) apply design control provisions equivalent to
- original or previously verified designs. Design
)
' Note, too, that the second peregraph of 2*em 2 control provisions include revision, review, and needs a concluding statement that reflects tv- approval of the design doctement(s) af fected and I design verification.
GPUN resolves the implied requirement for 2
- separate reviews.
The last sentence of Paragraph 6.2 could be read
{
- n imply that two separate reviews are required.for
( "fleB changes" to previously approved designs:
i (1) the review of field changes for the ef fect on overall desig . nad (2) design verification. As a point of clarification with regard to "fleId
, changes." the effect of the ffeld change wilI be independently evaluated and the need for design
= verification of the specific fic8d change will be determined. _lf the review determines that the r field channe has no effect on the previos ly_
' approved desian then that review constitutes 3, desian verification of that field chante. If the review determines that the field channe does have an effect on the previously :;; ,.-," desian then a
( g desian verification of the resolution of that {
specific field channe will be r- " - t -C Also, fleid changes that are " minor" as described in paragraph 7.2 of the standard will not be design l
verified. Procedural requirements shell be provided to identify when such !ield changes are " minor" in the context of paragraph 1.2 of the standard.
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.:s -
CPING Breponxy to NetC s a'
. ento on Rev. 2 of CPUN OQA Flo:a Movember 1. 1988
SUBJECT:
Seymour N. Weiss to P. B. Fledler, dated August 5, 1988 ATTACIIRENT 4 6000-88-126 FACE 7 of 26 l _
IIItC QtfESTION/ REQUEST RESposeSE
- 15. _ ,,
- Page 112.0 of the plan indicates that torque 15. Text revised. The text has been revised as follows wrenches will be calibrated and controlled con-sistent with CPtfM's " current program" instead "Section 5.4 addresses the calibration frequency of weekly. Briefly describe the " current and method of automatic cut-off impact wrenches -
i program," and provide data which show it is used to make up and Laspect_ high strength holted acceptable for calibrating torque wrenches. connections 1 and, the calibration frequency of hand 1
(283) (Also see Question 7). held torque wrenches used to inspect high strengtle
{
bolted connections. Section 5.2.6 of ANSI 18.7 as well as 6.6 of this plan also specify controls for j
measuring and test equipment. Sections 5.2.6 of- '
ANSI 18.7 in conjunction with 6.6 of this Plan shall
}
I be used in lieu of 5.4 of ANSI 1845,2.5 to control the frequency of calAbration of automatic cut-off impact wrenches and/or hand held torque wrenches used to makeup or inspect high strength bolted con-i nections. The method of calibration will be con-sistent with the manufacturer's reca===ndation(s).
16.
j' In reference to Section 4.2 of ANSI N45.2.13-1976, page 113.0 of the plan indicates that 16.
Text revised. The text has been restored to that historical supplier data will primarity consist which was previously accepted by the Inc. Refer of records of evaluations conducted by also to Question 40. That text is: "3 ..... When accredited agencies such as NBS, UI., ADN,, or evaluation of a supplier is based solely on his-similar agencies of foreign countries...." torical supplier _ data, these data will primarily l
' Describe such records of evaluations and dis- include records that have been accumulated in con-
' cuss how these records indicate compliance with nection with previous procurement actions. Data Appendix B of 10 CFR Part 50. (283) that includes experience of users of identical or slapilar products of the prospective suppiler and j product opersting experfence wiiI be used iI avaiI-able." Refer to question 40.
4627I. ,_ w. -w NS SD# 1 = h
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. 4 CPtNI R x pense to NRC P m ts on Rev. 2 ef CPUN OQA Plan November I.1988 S"BJECT:
Seymour N. Weiss to P. B. Fledler, dated August 5.1968 ATTACNMENT 4 6000-88-126 PACE 8 of 26 _
NRC vuunTION/R88M8EST
< RESPONSE
- 17. -. --- ~
Section 10.2.5 and page 115.0 of the plan both 17.
] Text revised. The tent has been revised to read:-
address external audits and both commit to such audits once every three years. Section "Enternal audits of selected suppliers of services i
C.3.b.(2) of Regulatory Guide 1.144 requires, which are within the scope of this Plan mill be in addition to triennial audits, annual assess- scheduled and conducted at least once within the ments. Clarify CPUN's coassiteent to annual life of the activity or every te m years. Refer assessments of long term suppliers. also to 10.2.5 of this plan.
An annual evatustion of suppliers of items, parts, meterials and services mill be conducted. These evaluations allt be conducted utilfalag the results of source surveillance, source inspection, receipt
, inspection and/or audits; and, other factors.
These evaluations will determine the need to
. conduct audits of suppliers of items, ports or l meterials; or, increase the frequency of conducting l'
4 audits of suppliers of services."
l Also, the last sentence of Section 10.2.5 of Test deleted.
i j
the plan. " 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 conforesace to procurement document requirement." does not j appear to be auditatale. Relate the fuel and
! In-core procurement audit casualtments to the j
guidance of Regulatory Guide 1.144 in an audit-i able menner or justify not doing so. (2B3) a l.
i e
, me h
==-m We 666 O %./
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.. _. _ _ _ ,_ _m__ __._ -~
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CPtNI R.~rponsa to NRC g
ento on November Rev. 2 of CPUN.00A Plan I, I988
SUBJECT:
~
Seymour N. Weiss to F. B. Fiedler, dated August 5, 1988 ATTACNP5itT I 6000-88-126 FACE,9_of 26;.
M C question /RE T ST
RESPONSE
- 18. Include in the plan a coassitment to meet 10CFR _ . . _
18.
- 50.55a and to comply with General Design The OQA plan demonstrates how CPUN meets the refer-Criteria enced parts of 10CRFW. Paragraphs 2.2. 2.3. 2.4 1 in 10 CFR 50 Appendix A or justify not doing so. (283 and 2B4) 2.8 and 5.1.2.4 of the OQA Flan provide for the
]
specific method (s) of meeting 10CFR50 Appendix A, 1
criteria 1.
50.55(a) as it relates to inservice Inspection (i.e.
! nondestructive examination) andinservice Testing is addressed by Paragraphs 6.4 and 6.5 of the OQA Plan as augmented by separate submittels which identify the scope and specific edition of speelfic ASME codes to be used in the development. conduct, ar,d maintenance of the ISI & IST programs.
l.
1 i
+
't 46271,
CPil:
J Rxpense to 95tC Conusents on Rev. 2 of CPt9N OQA Pla n .u_
Slovember 1.1988
SUBJECT:
__._ Seymour N. Weiss to P. R. Fledler, dated August 5,1988 ' ATTACIIPIEE4 ~~
i 6000-88-I26 IIRC gur.sr1088/RF--=si FACE 10 of 26 j 19 RESPONSE j Section 9.0 addresses training. Clarify CPUN's 19.
coannitments to the following:
, a. .
4 Training records (see 9.2.8) include the m.
, content and objective of the program, Text revised. The following sentence has been i
attendees, and date of attendance (2Dc) added to Paragraph 9.2.8 to provide the 3
regnested clarification: "... These training
] records skaII be aufficlent to provide evidence of content and cbjective of the training pro-
- b. vided, attendees, and dates of attendance."
- Proficiency tests .are given to both doers b.
. and verifiers to show they are properly Text revised. Refer to Item 19.d below.
! trained and qualified (2Dd)
J c.
Certificates of apsalifications show the i
!, . specific functions personnel are qualified c. Text revised. The following paragraph has been to perform and the criteria used to qualify added to 2.7: "When certification is required, i
personnel in each function (2De) a certificate (s) chall delineate the specific function (s) the individual is certified to be able to perform and the criteria used to certify
- d. the individual for that function (s)."
- Proficiency is maintained as evidenced by d.
i retraining, reemassining, and/or recerti- Text revloed. The following sentence has been fying (2Df) added to Paragraph 2.7 to provide for the
{
t requested clarity: ". . . The proficiency of personnel shell be evaluated; and, measures to
{ nelatein proficiency shall be implemented
{
\
g through either retraining, reemanining and/or '
! recertifying."
i -
l s6 21l.
~~ ~
i-+ -e-*< - ,- - > - - *u_- _ _ _ _ ___ a_a__ v -_ __.& , = . +
CPtNE R2cronse to NRC ~ ,
.enta on Rev. 2 of-CPIN8 OQA Plan-November-Ia;I988
,= ,
SUBJECT:
Seymour R. Weiss to P. B. Fiedler, dated: August 5.1998 l ATTMENT'4 -- '
l6000-MM-I26 FACE I1 of 26 NRC QUESTION /R*a"ST RESPOIISE
- 20. Section 4.2.3 of the plan has deleted the . ..
20.
reference to computer programs associated with The phrase was removed from 4.2.3 because it had design. _ Reinstate the reference or lustify not apparently been inappropriately included in the.
doing so. (3A) past. However, ref er to 4.2.11 which has not been revised.
- 21. Section 4.3 no longer refers to the Director- 21.
Engineering Assurance. Clarify what organiza- The performence of "desian verification" hao ne,er tion is responsible for the N45.2.ll (Section been assigned to only one organization unit.
- 6) design verification for modificatfons and Refer to the NRC accepted CPUII endorsement of' Reg other design changes at Oconee and 1791-1. (38) Culde 1.64 in Appendix C at the Plan and Paragraph 4.2.9.
" Oyster We assume that "Oconee" was intended to be Creek."
- 22. The words. "whenever practical,"' have been added 22. Text revised. The phrase "whenever practical" has to item 4.2.10.b of the plan. Identify what been removed.
organization determines the practicality of The text has been restored to that testing under conditions that simulate the most which was previously NRC accepted. The purpose of adverse design conditione, the concurrences the proposed revision was to offset the potential required, and the bases for the decision.- (3ES) sementic anamely that only the "most adverse design conditone" could simulate the "most adverse design conditions."
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=
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[J CPUN Response to IIRC Commento en new. 2 of CPWR 944 Ptan C '
8tesenher-1, 1998 m yP
.I ATTNt" 4 --
SUBJECT:
C,_ _ - W. Sieles to P. 8. Fledler, dated Agent 5. - 1998 este-na-176
. CAGE I 2 of 26_ m
__ BRIC MION/990 WEST assygguig 2.l . The werde. "newen deemed necessary." home beese 23. Test revloed. . The ytersee "shor* deemed neceeeery" added to ite.a 5.1.2.1.g of tIse plees. Identify lies lieen renewed. The test tim been restored to what organisetdes deteralees ttee necessity of 'Isot utilch wee prulewely HRC accepted. Ylee purpose having accese to embeler supplier f acilities, of the crepeeed revielen mee to recogelse that la the concurrences regwired, ased tlee boses for sese procurement actlesu no embtlered emppliere are the decielen. levolved.
- 24. Section 5.1.3 of tine ples addresees orgentza- 24 ' Test revloed. Refer to 5.1.3.l(c). The sentence tienel responelbilities for procerement and "Aeeere the< bide ore evolested for comformance to seaterial control. Include organisatlee technical and quality requireassets by ttee requisi-responsibilities for bid evolmations. (481) tieners" hos been . m . Other prevlees items
. retelmed and reiettered.
- 25. Clarify in the revloed section 3.2.2.1 et time 25. a, *er to 6.e l .2.2.(c). (d), and (h). The tere %e
,9Ian that SS-bellt h e are stilltIn (See btallt drewIng** is IseClasded let the ters **dreepisag.**
scope of the decament centrol program and that they are propered la a timely menwr to eccer-ately reflect the actual plant. (6Al med 6Cl) ,
E0 MM' *-
4627I -
CPUR Response to IRK p mentr on new. 2 of cpgu ogn pie.
h . ember I. 194R .
SUBJECT:
4 a N. Helse to P. S. Fiedler. deted August 5. 1998 ATTAdW5NT'6" '
. 4000-n8-126 PAGE 13 of 26 BBC QUESTION /9885EST BESPONSE !
- 26. The actuel effect of the changes to Sectione _
t 26.
l 6.2.2.2. 6.2.2.3 and 6.11.2.6 is met cleer. CFWN QA corrently receives and will contiene to receive all aslotensoce work ootherislag decwnents }
It appears tteet QA will continue to review att malatenance and lastelletten precedures for les g4 pine scope (e.g.. "short forme." " job
' inc1=elen of inspection and test regyulrements tithets." malatemence schedulee, etc.). These and QA hold /witnese pelate but will no longer types of documents are tensee which specify the concur with these precedures med will se longer specific metatessence test. tIsch of these documents
] review csed concer with work motherising docu- will zoetlanee to be reviewed for inclueleen of mente (compering the revise 4 ed unrevised laspectice held and/or witness points. !
6.2.2.2c).
' Nowever. GPUN's 'evolmation states: "Thic sub- I section hos been revised te delete QA review Test revloed. The tent of 6.2.2.3.b hos been for concurrence revloed to state "Asserlag tInst seletenance and proc =dures.of all meintenance end instal-j
- lation Review for cosecurrence of laste11stien decomments within 94 elan scope are adelnistrative procedures for m intenesoce and transmitted to @ to provide for t8ee inclosines of !
installation le retelmed." And CFWu's held send /or witness points." This revised text
- provides for tine consistency between 6.2.2.2
elispositica notes that " review of all socie documente for in:Imolce of inepection points is 6.2.2.3.b and 6.11.2.6 F
saintained." Clarify such that it la cleer_that i the SRP wilB continue to be met in this resord. ['
(17.2.6-2)(Aloe see 4-5) t Also Sectice 6.ll.2.6(a) of the plan addresses Test revised. Sectlen 6.11.2.6(e) hos been revised !
i QA review of instellation and anletenance pro- to state: "Reviewing lastellation and meintenosece cedures, weille Section 6.11.2.6(b) and (c) ;
I addresa installetten but ont metatemence. procedures or egelvstent wortt eetheelslam h a ts l
Clarify this apperent inceneistency. to provide for the emelaamW of g4 held and/or !
t L witness points."
.I i
sect inas 6.11.2.4(b) sad (c) reletes to the j perf ormence of the inspection. All installatinees
{
t will be inspected at leest to 18e entent specified l
! by the engineer. Not all maintenance is inspected, l whicoe is why the term "anintenance" is not need in '
i i
- 6. II .2.4(b) and (c). i I
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CPWR Response ta WRC Csammata en Rev. 2 et cyger ogA Flen moveaher 1, 1998 t~
d ~
Str8 JECT: ATTACIBIEIrF 4 C, ___ ; 5. IIeles to F. B. Fledler, dated August 3,1988 i gg3g-88-126
! FACE I4_ of _ 26 IIRC 00ESTleII/"""eT aggegang
- 27. See
- len 5.1.E.4 et the plan addreeces the deet- 27. Test revloed. Refer to 5.1.2.4. The test corrently cettee of cessercial grade itene for oefety- seeds ee:
related applicatione. IIote that mermal receipt i
inspectlen alone with (i.e., Identity and **The procese of acceptance of commercial grade itese demoge) le met a,e acceptable seene of verifying latended for ese la mecleer eefety related applica-j en Itee's functionality, and section 5.1.2.4(c)I tiene shell be controlled and laplemented through en should be revloed accordingly. approved precedere(s) which lecludes the followiaR:
i a) An engineerlag ewelue:lon to determine if the Forther, historical date se referred to la commercial grade ates perferes e oefety function Sectlen S.I.2.4(c)4 does -nec appear to be en er if it*e fallere could compreelee a safety fonctlen(s).
{ acceptable method of dedication in and of itself.
1 b) A determination that the definittee of ccamercial 3 Also, rellence en an appeeved empplier to dedt- grade item as provided la 19CFR21 le met.
i
' cate replacement perte has not been totally c) A deternimetlen of the critical characteristics eseccessful in the poet (Reft IIRC 12epectlee which are essential for the perferamece of its estety functlen.
Report 30-348/87-11), and me omsgest tivet OpWN d) The definitlen of functlenet teste and/or apply addittenel centrole when thle le done.
Inspectlene, incledlag acceptance lletts. to he Finally, we note en page 7 of Attachment I of perfereed te verify celtical chorectaristles.
the April 15. 1988 CPUN euhaittsi that GFWII e) Verlfleetles thet critical chorecterletics Intende to see the EPRI goldelines to centrol have been met by one of the felleelag:
- 1. Performance of fumetlemet teste and/or the mee of commercial grade items in secleer laepectlene after receipt by CpWH; er safety-related applicatione. These guidelinee. 2. tettneeslag of fumettenet test and/or have not been endermed by the IIRC. While the statf generally agrees with the goldelinee, tespectlene et the supplier *e facility.
- 3. Aseerlag through audit oc e m illance that acceptance metind 4 le not acceptable. CFWII eheeld irecogelse the corrent states of the EFRI the supplier hos a goality program which edegnetely controle the critical character-guidegne as It establishes its precedures. .letice; and. performe test and/or loopectione
(;s4) which verify that critfeel characteristics have been met; I
e 4f. 271 _ _-- _ ..
e
. _ ^' -
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<- :~
- bpj CPUst t , - x to NRC c -
b ts en new.:2 et Crum aga Flen
~
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A . A r I. 190s-
- ~
l- l ~
l sus 3ECT: 4- _ _ n. uelee to P. a. Fiedler, deced Aug.et 5. tsee a 1 T a n ensser 4 .
l 1
esse-no- 26
[ g 1%___M 26 IE M 7 21.
(Coatinmed) __
- 27. (Coatloved)
' 4 Esteh11ehlag a ceammercial grade part perfete-ance histe y cemew-rent with perfec.nlag any -
(- - '
of e(l), e(2) oc e(3) sbowe: or, 5.
any ceabination of e(I) theough E(4) showe.
This dedication process shell result la the dece-mented beels for the epyrepriatenees of the wee of '
I the c-rcial grade item (s) la the specific ,
2
! nuclear safety related application (s). .;
i
{
~
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l I
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%27L . ..
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p e-- r + rw- a-- -,w -m -e, ,_+m-w w~-, + , -s.v er,-- ,- --,--,s, -
- - w , ve w v , .o -.e .-,-<-m,-,,,--m -,w,--.--,---mm-wm-+m----~ . + - - - - , --v
. -- --^- - --
, -g CPUlf Neopense to IMC (*mte en Rev. 2 of cygle eqp pg,e
- Itowember I. 190s
SUBJECT:
Seymour N. tieles to F. R. Fiedler, deted August 5.1998 ATT M T i - 6000-NS-126 PAGE 16 of 26 _
IRC quESTIGII/RE05EST REspoust
- 28. Section 5.2.2.7 of ttee plan states that, as an 28.
alternative to receipt inopoetion, verification Test revloed. The purpose of the revloed test was of proper identification may also be made by ta provide for the woe of commerical grade items.
j The text has been revloed to be consistent with tese inspection personnel prior to instellation.
This should be done in additlen to receipt revloed 5.1.2.4 ten (gesestion 27 responee).
- inspection and not as an alternative. The eene connent applies to Section 5.2.3.2(b). Clarify.
{ (MSI and 8E3)
) 29. Section 5.2.2.3 of the plan emenpte connercist 29. Test revloed. The phrase **. .. thet are not desig-( gra!e items, meterials, perte coneunables, and noted as ceaseercial grade...** Ines been removed.
equipment f ree the identification and documen-j tation re p irements for other hardware within 8efer responoe ).
also to revised 5.1.2.4 tent (Question 27 the scope of the plan. It appears that 5.2.2.3 ~
ltems c. f. and g as e einleum would also be
)
required for connercial items. Clarify. (882) i
- 30. Section 6.5.2.3(b) of the plan indicates that 30. GPUN le currently committed to Af5I 18.7-1976.
l MCF will perform cemetraction and maintenance
- The last peregraph of Section 5.2.6 of that stand-and then prescrsbe the construction and post- ard states in part *1enen egelpeent le ready to be eunintenance teet requirements for that eene work. CIsrlfy wtsether thle le time case, end if returned to service, operating peraennet steell it is, indicate CFWII actions wtelch verify that piece the equipment in operation and verify and l the teste demonstrate ttic acceptability of the document its f unctional acceptability....**
! construction and maintenance. (11AI) i l
)
o Af> 27 L ~
a sed
~. . #- % g wq s'we,,,w ---ww --w---M+ v w wy-' w w-wwgr=*e 4'F we'yev*-e eehg-_-wm-wpw w,,, e_.-* *_w_-6* .m--m--u h___ .m__ - ==M
_ ~
lp- - N' CPWes Elecrossee to W1tC
. sentc. en Etew. 2 af CPWII agm 78en - _
c<
. s. .suber I. IM a
=
SUBJECT:
Seymour B. tieles to F. S. Fledles, dated Aeguet 5.1988
_ eggg.e8-126'
- M I T *C7%. _
umC ouestion/neetast
_ assreuss
, 31. A new paragrope=, added to section 6.6.t.t(f) of -
{
- 31. -Test revloed.- Thr, test oss revloed as felleen.:-
the plan, indicates that ==== eeeewelag tools "Sese er seering isole beccese of their constrectleese
! because of their cesstrectlen (such as sectier.ical dial- isodicaters) seed not be perledically call- (sech as mechealest diet ledicatore) er becease teney j are not adjestable (such me refere) need not be j
brated but shall be meletaleed in r.eed wwking perledicelly cellbretd .
condities. The feerth edition of Inspection and Ensemer, their edipolen1 .. .
Caging by Ku n05 and'Andres hos a section titled conditlen and where appt heble timelt accoracy_ steell
} "Use, Care and Cetibrettee of Indicators" (elolch be restinely checked priee to use."
i doesn't address calibration) followed by a sec-tion titled "Checiting tine Indicater for Acceracy"
} (which does address calibration). Clarify that 2
the accuracy of each egnipment will be periodi- ,
cally verified in accordence eith ttie calibration commelteente of Section 6.6.1.2. (12.1) i i
4 i
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4627L_ _ _ _ -_ _
~ ~ ~ - -
_ . _ , e.e ' "
vt "9V
CPUN Response to WRC Cemeento en Ree. 2 of CFWN 044 Flan =
, November I. 1985
~
SUBJECT:
ATTACEMENf3 Seymour W. teelse to F. B. Fledler, dated August 5.1998 i
ogge.sg.126 PAGE 14 of 26 . __
i IIRC ammerigsfaggggST E823reISE
, 32. Section 8.1.3, added to deflee essen deficiencies 32. If the deficiences are found during the conduct of
] can be reported and analysed estelde tine men-j conformance report, le limited to deficiencies a verification activity they weeld be reported in "diecovered dering veriftestfem activitles." the verification report (e.g. endit, monitoring.
inspectlen, serveillence reperte). Such defieleecles would be restinely trended.
1 Describe how such deficiencies are reported and analyzed when they are diocevered before or Deficiencies are regstred to be reported by noncon-i after verification activittee. (15.5) formance reports. The purpose of thle revielen is I to allow the ese of verification reports as "noncen-l formance reports" in certale sitantiene without the provisiens of 8.2.5 being applied to such verif i-cation reports.
! For delleiencies discovered by QA personnel before
- er after the condwet of a verification activity, either e nonconformance report is origineted a verification activity is initiated to characterize the condition the siteetion is corrected; or.
l
- , other administrative processes are utilised (e.g.
- "sliert f ere." "g; "c e change rept" etc. ) to l assere the conditten le corrected. The detici-eneles whIch are set deceaneted either by a verifi-4 cetion report er a nonconferemece report would not be emelysed fortIner.
. Test revloed. Test has been further revloed to
.g eas.heelse that when deficient altmetiene are such that action te_ prevent recorrence can be initiated at time point of identifying time def sciemey then a nonconformance report is not regelred to be origi-noted. The second sentence now states "... Snch detleiencies are tinose which are leelsted to i
. singular occurences, not repetitive in netwee and/
or are such that action to prevent recurrence can '
be initiated at the t ime t he def iciency !s ident i-fled and do not re g re any action other than ,
reportina the occurrence ..."
46271 _
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.. ... . , . - . ._ ,- .- .- ..-. _ .- ~ . - . . . - ~ . - . . - . - . - - . . _- __ _ - -.. - . - -
CPWI Seepense ta Isec ento en new. 2 of CP95 04pt FI m i -
Isowester t. I988 .
SUBJECT:
~
- 5. Ifelse to P. B. Fledler, deted August 5.1988 ATT M 4 i egeg_gg.126
! ! PAGE 19 et,_26 IRC
- T fl018/38 WEST
RESPONSE
i 33. Sectlen S.2.4.(b) of thee plem has been modified
' 33. The 1 " ,_ '
i by deleting the cemettaestt "I.icensee Event 7. eefety review of Licensee Event Reporte rewire en I ' _ " t Sofety Review."
Reporte le prescribed by Section 6 et the 9mit -
j Justify this deletion er replace the Technical Specificatione. It ses deleted f rom tese commitment. (15.1) QA Plan to leprove tine coneletency between Tectuelcal j Speelfleetlene and ttee g4 Plan. In thle case of j
" safety reviews", the specific review is provided "
for by Technica; Specificatione and listed on the "CPUN Seview and Approval pastria."
34 Section 3.3.3.2(b) of the plan refers to objec- 34.
tive evidence that activities were conducted in Test revined. The ytersee "...this Plan end..."
" compt lance with time standards, codes and rege- has been inserted. e i
latory goldes endorsed by ttels Plan." 70se pota- i tnon should repire " compliance with thle Plan 1
and its endorsed standerde, codes, and regelstery I goldes" or werde to that effect. CIselfy. (17.2) 1
, 35. Clarify thet activities associated witte comyster j 35. Section 2.4.3 of ttee plem reptres audits of all codes such as tteele develepment, procurement, l verification. welldation. see. and security are organ'setiene and all re piremente of tine 0,74 plan.
Sectione 10.2.2.s la conjunctlen witte 4.2.11: ased, l l within the scope of CPWII'm audit program. (10A4g) t i
10.2.5 ladicate that audite of activittee seeoci- ;
! sted with computer codee see repired to be conducted. j I
i
? l l
i l
i i
6 l
l
. [
6M7L ~~
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l
- _ _ _. . . - - . . _ , . _ . _ _ _ - _ _ . . _ . , _ ., _ _ _ . . , . . _ . _ . - - . _ _ _ _ . . _ _ . = . _ _ ___ _ _ _ _ _ _ _ _ _
CPINI Respone to Inc Caseento n Rev. 2 ef CPUN 004 Plan 4
Slovember ..~ 1998
SUBJECT:
ATTA(.554EfffT ~
SeyeSer W. Ifelse to F. B. Fledler, dated Augeot 5,1998 agge-88-128.
FACE 20 of 26. --_
f ISC ggESTISII/deggEST Resreget
- %. Section 10.3.l(e) of the plan addresses the i 36.
1 analyses of medit data. Clerify how often the De results of medits are correntt,* laceeperated res=Its of these analyses are repected and late a deficiency dets beoe. As auch, the results whether they include the results of trend of medits can be routinely trended. A3ar, as part analysis, of a procedurally defined annual aseesoment r,cocess the results of medits are analysed and prese;nted.
Similarly, clarify the periodicity of time
' reports regarding the effectivenees of 004F Corrently, the combination of a Ceepm swe ftenoge- .
imp!enentation repired by 1.5.1(g) of the pfen. meet Audit of the functioning of the qA Beyerteent q
and the conduct of an annuel asoceement by the QA deportment provide for an sinnent report to time 00F on the ef fectiveness of 00AF laptementat ion.
j 37. Sect ion 2.10.1 of the plan refers to tine CFWII 37. The "CFWN Revlee and Approwel f4 stria" is refered l Revlee and Approval festrim. Diocess this metriu-l j
eho (by peeltion title) prepares, reviews, to in Section 6.0 of the Units' Technical Specifications.
meintains; eteether submitted to SAC; oliet is The content of the metrim and w jha I
metrixed; etc..
This section slee states gets a techselcal revlee and an 1--f_mf t safety there will be an I ^ ,_ "
-t safety revlee "as review is directly addressed in teme Tectonical ,
5 Specifications.
' necessary." Indicate eene (by positten title) ,
decides einen each a revlee is necessary and provide time bases for time decielen. The oefety revlee process is currently prescribed by a corporate procedure (1989-AW5-1298.SI). This precedere preecribes how ttie Technical specifica-tles regelresents wiII be met. He precedure ie origineted by Director Planning 4. Itseleer Safety and approved by time Of fless of time Freeldent. t
- 38. Section 2.11.l(b) of the plan ines deleted 38. Text revloed. "in " c " ^." restored. The term "In f-..;
" . t" from the first sentence. He note that'the Freeldent's een staff may perform the ese deleted beoed en the potential anamely of assessment, tigerefore receaselt to an in';p*; t "I-- f w!; t" and "Fresident's een staf f".
essesement er lestify not delas ee. '
- 39. Sectlon 5.1.1.3 of time plan no longer hos the '
- 39. Text revised. The phrase "... subject to current couailtment that certain rerencorements elf t be QA program controls subject to the latest QA con:rsts. Justify med...." has been restored to '
I 5.1.1.3. as sugaested.
this deletion or replace tl.e cosa:Itsent. (7A4)
. - i
. .. . . ~ . - - _ - - _._ _.. . . . . . . - _ _ _ - . _ . _ . . . . . , _ . _ . _ _ _ _ _ . _ - _ _ _ _ _ . . _ _ _ _ _
- CPUN Response to IWC .
nto en Rev. 2 of CP9W 04pA Plan loo.Ar 1,1998
SUBJECT:
Seyueer W. Weise 'o P. S. Fledler, deted August 5.1998 ATTACNMEffT 4 6000-94-826 FACE 21 of 26 i NRC QUESTION / W assromsg
- 40. Provide mGre detail regarding the addition in 40.
l Section 5.1.2.2 et the plan of the use of Test revloed. Prevleuely IWC accepted test hee i
" accredited esencies" to quellfy suppliere been restored. That test le "Bewiew of performance j based on bletorical date. (7A3) histories which provide recer e of suppliere pre-j 'rious capability to provide eleller products and f L services." The latent of
- e propeeed change was l -
to be more specific in identifylag that records of supplier performance weeld include that evettable i
,1 frem enterne8 eserces.
4
- 41. Aedress the slanificaece of tht- chenae to the last o'ed itee la Section 5.1.2.2. of the ylee.
4I. Test revised. There is ne sigalficance to the This item, which used to require some enternet change. Isewever. the prevlemely NRC accepted text hoe been reetcred.
j ormanisettee to " work under the direct control of the CFUN Quality Aesorence ?regram" new requires that they " comply with the CP9ff Qaelity i Assurance Fregram."
1' i Likewloe, address the slaelficence of the cineene Test revised. As a result of revielag 5.1.2.4 to the 1eet peregraph of Section 5.1.2.2 regarding procurement of commercial grade items. (refer to Queetten 27) the teet will reed: "In which used to commit "to emeure the appropriate the case of comeercial grade items, the procurement quality le meletsined" but new comalte to "to process shell be controlled so that the dedication procese descelhed le 5.1.2.4 sheit be met."
ensure the appropriate quality seguiremente are
' specIfled." '
- i l
I -
i 4627L I
CPUN Response to ISC Counmento en Rev. 2 of CPUN GEpt Plan l
Mowenber I, 1998
SUBJECT:
~
Seymeer N. Heles to P. B. Fledler, dated August 5. 1998 ATTACNMEBIT 4 6000-88-126 i FAGE 22 of 26 Inc ,- a ION /S- _--Mi N
- 42. _._
Section 3.1.2.3(c) of time plan no longer ceaselte 42.
that "Q4D will eleo provide followup of correc- Test revloed. The sentence "giselity Asserence tive action laplementatten." Jestify or shell verify that repelre are accompIlehed in
! replace thle deletion. eccordance with the opproved dispoeltlen" hoe been i Inserted.
} 43.
Section 5.1.2.3(e) of the plan has been revloed 43.
l to wee " source inspection and/or serveIIIence"
- Test revloed. Editorial errer. The feet sentence es weII as " source inspection serveIIIences." of 5.1.2.3(e) will rend as " Typically, endits will
' be conducted on suppliere of serviccol a_nd. source lenspection, source owevalliance, and/or receipt inspection will be conducted en emppliere of hardware. Also the phrase "searce inspection and/ '
or serveillance" hoe beeen chooged to " source Enepection and/or searce serveillance."
l It also adde provisions for CPUN review of "the beoelIne and/or detailed engineering produced" Test deleted. The proposed revloed test wee while describing the attributes of CPUN's mone- latended to restate the concept of 19.3.5 o~ Amst facturing eseurance program. Clarify these W45.2.13 wtillaing CPUN opecific terminology which
{ changes. wee included les Appendie D of the plan.
I
- 44. Section 5.1.3.l(e) of the plan refers to CPUN's 44 Supplier's Qinality Closelfication List for pro- CPUN does not latend to malateln a list of ceouser-i curement, and Revision 2 Ines emenyted commercial ciel grade item suppIIere. The previelene for mee j of cemamercial grade items le provided by 5.1.2.4 grade items. Clarify winetteer CPUN hoe any i
almilar controle (or stoller liet) for commercial (refer to gineetlen 27). If an evoluetten of j grade items. ampplier performance le utilleed me part of tIse ,
j -
eedicetlen procese Llee report of tIse evaluation
=
i ,g 111 be included as port of tIee documentation ameociated with that dedlestion.
i i
i
^
5 4527L .
j _ _ _ _ _
.l
- , _ < w. . ,.,-,e .-- e,- _.w , , - - ,v.. .- r, _ . . . ,.--,_,-.-,,...e_ _ .%_- ___e_ _ . _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _
e . .
+ .
CFWI S; ; _ -_ to IRC ,
n soto en Rev.'_2 of CPUN 044 Plan -
Ise.coher I, 1988
SUBJECT:
ATTACIDERIT 4
~
Seymeme N. Ifelse to F. B. Flodler. dated Augeot 5 , 1 9415 i'
egge.gg-126 1
FACEE 23 of 26 IWC 05E373g10/m3g555T 1 mespeligt 1 45. In Section 5.1.3.2(b) of the plos. Revielen 2 45. Tent r,tvloed. The ptweee " review for concurrence" cheeses " Approve att" to "Beview selected" CP9N j
procedeces = ;;---- T for the coatrol of per- hee replaced " review selected".
i cheeed egelpeemt meterial, and services withis the scope of the crWB quality Assurance t
' Program." Justify or elimieste thle change.
j 46. Section 5.1.3.2(d) has been changed from " Review i
- 46. Test reelsed. The phrase " review for eencerrence" and accept supplier reeerd pechages" to "Deview l for concurrence supplier record packages as hee been added to Appendia 3 and defined. Thle j
regelred by applicable precedures or procurement phrew to egelweleet to the peerese " review and accept."
documents." Justify or elleleste thle chenne. '
- 47. The first sentence of Sectice 5.1.3.2(f) tayties 47. meter to the reopease te queetten Ig.
l i
that QAD will review att procurement doctemente,
( but the last sentence (added in Revielen 2) etates the review *%ey leclude sempting review ,
of previously approved procurement documente er le-Ilse revleue of selected perchese requist-tiene er ordere erler to placement." Clarify. ,
I( emeytleg to used, specIfy the eseptlag ples; j if selected perchase regeleittene or ordere are i 4
revleued. Indicate egno (by poettien title) sekee the selecties and describe the bases of the eclect es.
I i 1 .
i I
i j
i 8627L ..
i ,
, +
t n . , - - - - ---,e- -~~-"~~*'~""'#' ' ' ~~~"~~ ~' ~ ~~
l CPUN P% pense to IRC Commento en Cev. 2 cif GPWII UQA Flase Isewee6er I,1998
~
ATTACNIWppy 4
SUBJECT:
Seymour R. Ifelse to P. B. Fledler, dated August 5. 1998 6009-8P1-126
_ , , , PACE 24 of 26 IElc 05E873018/R80585T ay.sponsp
- 48. The intent of the revloed Section 5.2.2.6 of the 48. Test revised. The prev 3emely sac approved i.2.2.6 plan, which states: "tAnere pteysical identifica- text has been restored. Thet lo: "uteere physical tion is determined not to be needed, each as weten identificatalen le either Japractical or inewf fici items are unipely identified and specific trace- ent, pteysient seperation, precedural centrol or ability le not re pired by codes or standerde, other approved messes may be employed."
only segregation controle need be ispeeed." is not clear. Clarify. Test revloed. TOse poesgraph. "Treceability to
" heet and/or lot numbert shelI be provided when re wired by code (s). Tr.eceabif tty le previided for parts of itees within the scope of this plan. How-ever, if the ports de seot provide or contribute to the performerece of a senselear safety related f unc-tion. traceability will not be provided for those ports unless regesired by code (s) or regula'tions(s)."
has been adde:d to 5.2.2.3
- 49. The first peregraph from Section 6.11.1.9 of 49. This peregrap"o was deleted as an< editorial change.
Revision i of tine plan le not in Bewielen 2. -
It use redundset to Waragropese 4.3.1. 4.3.:2 Clarif y wesether thle salesis:. le latentional. 6.II.2.2(a) and 6.ll.2.2(bl. I The remainder of thle secties ses previemely
. limited to modifications.141 Sevielen 2 ellet- Yest rewtood. No Sect son (i.e. 6.11.1.9) is mated thle lleitetten. CI" dip wInether thle specific to tM Jaelge a nd . installation of' section le applicable to c c.catraction ased moln- modificatione. To provide the roguested clarifica-tenance no well as smodific ,iene. tion, time ph%aa "of the modification" hoe been j inserted intt We Ytret and third line of tlee first '
peregraph.
l
- 50. Sectlpp 6.11.2.I Ines been,5 twised to regelre 50. Test reviset r!he tern "polley" le replaced by ,
that preventive ased corrc *t two meintesessece pro- the terms ". r:=nizaticis end maintenesece plians." l grene and work are cenel>( 1st witle company policfee. Srlefly descr*ja, GPWpl pelicles regarding preventive end. errective maintenance and where (Isese policies : ce be found.
4627L -
. . ii i
.; n--M
m_ _ _ _ _ _ - _
e CP9W acopeace to SB , usento na Rev.
- 4f CPgu C3A Plan emeer I 3908 -
ATTACWEENT 4
SUBJECT:
Seyamer E...ielse to F. B. Fledler, dated Aesguet 5.19sti i 6000-08-126 FACE 25 of 26 IRIC GUEST 9 /RWWEST _ ggggggyg
- 51. Section 6.11.2.3 of t N plan see.Igne respemel- SI.
bility for *%sajor me%easace at 1NI-1, and all Test re9 M . The followles reelelene have been meintemence at Oyster Wreek...." Identify the made fewdierther clerificatlaw Belote corrent organitstion reopensit?e for meistenance that 6. I I .2.1:4a ). Reletter currest. 6.ll .2.1.(b) to -
. . . (e ).
le not ** major" at 1W1..?,
Split 6, r.2.I.(c) into two seperate statemente and add e .edditlenei statement ::
(b) Este Fishlag admieletratloc costret procedures for pwweetettwe and correstEve melotenance cenel'rteat with the CPUR ergentsation and maintemence plane.
(c) Flamel->t. schedeltag, perSeselfag, directing and dermtlag unintenance' y:emeistent with the GPUN es:fanisaties and meistemmace plane.
(d) Estabt Ozalag adelaistrative weetrol procedures h
for andWicaties work coastetest with the GFWN ergeoissales plan.
Bevloe 6.1122.3 (a) to read (a) Flanning, schedettag, perferedses. directing -
and decaqstima constreetten insedification and mainteneant consletent with the CPWW eraanl-setles am Emeletenance plane.
Also, dla light of 6.tI.2.3GP and (e). It appeare Test revloed.. The term "documentteg," le being that 6.II.2.3(a) eheeld alwieclude a reestre- .aneerted me sediested. Note that ""Becamenting" le ment for documenting as welf-se for planning. 4enerically re&;ulred by 3.3.2.b.
ochedettag, and directing tras cometraction, modificatlee, and malatemenP'<activittee. i Finally, clarify what organiMilen(s) perform ~.tfer to the showe text.
these activities.
4t27L
^
_ u
CPUN-Utrposse to JIRC Connestc on Re . 2 ef CrtNI OUR Pian FJwenber 1.19h l _
l f.TTaCMPIENT 4 SURJECT: Seymour W. Weise to ?. R. Fiedler. deted Aegest 5. 4909 ' 6000 41B-126
, PAGE 76 ed 26 IEIC O NSTIcH/R800gS7 RESPONSE
$2. Section 6.11.2.4(b) of the plar Andicates EAP 52. "les tallation" as need does m_et ilmelude Neletenance performe inspectione and/or on #netten recesired (po v vent ive/ correct ive)". " Installation" is for the acceptance of the "ineMlation." sys nome =se with "cenetractlen" and is an activity Clarify that "inetelletten." me 44ed in asexisted with " modification." Wlitis respect 6.ll 2.4(b). Incimoes construct 4n. mainteemece ins?allations, inspections willrac conducted at (preventive / corrective), and menfications As Ice 3t to entent peescribe by inneelllation specifi-controlled by Section 6.11 of a h plan, catwoes. It is et latended to1Ipe inspectlens of all immintenance. Ref er also to preestion 26.
- 53. The new CPUN position regarding bgulatory hide 53. Temy revloed. 1he fellowing tems has been added to 1.143 (which approximates the C?M positior. both Reg. Cuide 1 26 and 1.143 rseeritments. The
! regasding Regulatory Ceside 1.26 % t the Int? wnd-rlined text is new or reviend.
l has previonely accepted) Indicaas that modMi-cations and tie-las to existing fact systeNs 1. for modification to emiotingc ipiant systems, as well as new construction may at meet th> Items will be classified by leaelmilcal Functions referenced regulatory guides. Witte regula ary according to the original deelen basis or this l guides are seldom beckfitted, n 44 constreeta== guide. Tliis classification allt not degrade is required to meet the latest c4dence mal +>ss the safety of tine system being; nodified.
compliance would result in hard-M p or inneseal ditficulties wittiset a compensa % g lacrease in 2. Additlens to eulating plant opstems will be the level of quality and safety- 'Similarlyy mode to the amme code, standard and technical modifications and tie-ins to ext.rzing plant requirements winich were originolly applied to systems sInoeld be in accordence 4th time labst the system to wInich ties addiatom is to be anode guidance unless the same conditias would res it. or more recent versions of these codes.
Clarify timese positione in Ilght a* the standards and tectuelcal requisements. The foregoing. addition will not degrade Lisen safety of the system being added to.
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- 3. For new construction, the latesit applicable code will be wtilized unless meet utilization would result in Insedelily or ususseel dif ficulty_
without providing an egesivelewt level of safety.
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