Text

Rev 4 to Gpu Nuclear Corp Recovery QA Plan for TMI Unit 2
	ML20133K560
Person / Time
Site:	Three Mile Island
Issue date:	07/17/1985
From:	Kazanas N; GENERAL PUBLIC UTILITIES CORP.
To:	;
Shared Package
ML20133K554	List: ML20133K550; ML20133K560;
References
	1000-PLN-7200.0, NUDOCS 8510220153
	Download: ML20133K560 (131)
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7 ATTACHMENT 1 (4410-85-L-0176) 131 Pages ENuclear REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 i

l GPUNC Recovery Quality Assurance Plan for Three Mile Island Unit 2 4-00 0

hisIlanhasGPUNC-WideApplicability. TuaNUyk'dYurance 6100 This document is important to safety g YesC No Effective Date Ust of Effective Pages See Page y for List of Effective Pages.

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Signature l Concurnng Organizational E!ement Cate I Onginator !l fMgy ( k g ,, , l Director, Quality Assurance l 2[ee /Y

'Concurreo cy!

/s/ F. R. Standhfer j Office of the Director-TMI-2 l 5/21/85

/s/ R. F. Wilson l Vice President-Technical Functions 5/21/85 g[g g i Vice President-Nuclear Assurancel 4//y/g3 '

l /s/ R. P. Fasulo f l Vice President-Administration l 5/20/85 I

/s/ R. W. Heward !

Vice President-Rad. & Environ. Cbntrols 6/14/85 g

i /s/ R, S. Renzi , l Sr. Analyst Admin. Proj./Org. Policy 5/20/85 j g fpQ,,f ;

Responsible Technical Reviewer l7/j7/pg i' (/ i '

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3 h Approved Dy

/ Office of the President g

7/j 7,/ff 8510220153 851014 PDR 0.0 Aoooiosisi.s2 P ADOCK 05000320 PDR

N " ber ENuclear asCoveRv QUAllTY ASSURANCE PLAN 1000~PLN-7200.02 Title Revision No INTRODUCTION 4-00 GPU Nuclear (GPUN) is responsible for the recovery of Tril Unit 2. The f Quality Assurance Plan contained herein describes the fora l and comprehensive plan which has been established to assure compliance with 10CFR50, Appendix B; 10CFR71, Subpart H; and applicable Regulatory Guides, during the recovery effort. This effort includes various aspects of construction, nodification and plant operations.

Recovery activities include decontamination, assessnent of damage, design, i procurement, fabrication, handling, shipping, storage, cleaning, erecting, installation, inspection, test, operation, maintenance, repair, and modification.

This Plan replaces the " Operational Quality Assurance Plan for Three liile Island Nuclear Station" for Unit 2 and will be inplemented in lieu of that Plan during the recovery period.

This Quality Assurance Plan is formatted in such a manner as to provide all users with a functionally workable document. It is structured to describe how the Quality Assurance Progran is to be functionally inplenented with due regard to the safety and health of the public and the personnel on site. The Plan contains a description of the organizations responsible for the inplementation of the Quality Assurance Progran (Section 1) and an overall description of the Progran (Section 2).

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The remaining sections are structured in a functional nanner.

i I j The requirements for administrative controls are generic and apply to all l j subsequent sections. Control of documents and records is contained in Section 3.0; !

j control of design is contained in Section 4.0; control of naterials and services,

! including procurenent, is contained in Section 5.0. Sections 6.0 and 7.0 contain the ; ,

! progran requirements for those direct and supportive inportant to safety activities I

! associated with the operation and safety of the plant; construction and/or I i nodifications associated with corrective maintenance, plant improvenent, and/or f repair; and the processing and transportation of radioactive wastes. Specific !

requirenents such as control of measuring and test equipment, inspection, special !

processes, test control, and status of inspections, tests and coerations are included l t

ltherein. Sections 8.0 and 9.0 again apply to all functions covered by the scope of '

I this Quality Assurance Progran. Section 8.0 addresses the identification and l l disposition of nonconformances associated with all aspects of the Program. In i addition, this section contains the nanagement controls provided for evaluating '

I collectively all nonconformances and determining what corrective actions should be ;

l taken to preclude their recurrence. Section 9.0 contains the requirements and l adninistrative controls applicable to audits. Appendices A, B and C contain j _

additional Quality Progran requirenents associated with the functional areas 2 discussed in the Plan. Appendix D contains the definitions of terms used throughout I

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Number ENuclear REC 0VERY QU TY ASSURANCE 1000-PLN-7200.02 Title Raision No.

TABLE OF CONTENTS 4-00 Page INTRODUCTION i TABLE OF CONTENTS 11 LIST OF EFFECTIVE PAGES/ RECORD OF REVISIONS v 1.0 ORGANIZATION 1.1 President GPUN 1 1.2 Executive Vice President 2 1.3 Office of President 2 1.4 Office of the Director - TMI-2 2 1.5 Director Technical Functions 8 1.6 Director Nuclear Assurance 8 1.7 Director Administration 17 1.8 Director Radiological and Environmental Control 20 i 2.0 QUALITY ASSURANCE PROGRAM 2.1 General 27 2.2 Scope 27 2.3 Recovery Quality Assurance Plan 29 2.4 Quality Assurance Program Review 34 2.5 Indoctrination and Training 34 2.6 Classification 35 2.7 Regulatory Commitments 36 2.8 Safety Reviews 36 2.9 Responsibilities 37 3.0 CONTROL 0F DOCUMENTS AND RECORDS 3.1 Instructions, Procedures, Drawings and Policies 40 3.2 Document Control 42 g 3.3 Quality Assurance Records 45

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ENuclear REC 0vERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No TABLE OF CONTENTS 4-00 Page 4.0 DESIGN CONTROL 4.1 Policy 49 4.2 Requirenents 49 4.3 Responsibilities 51 5.0 PROCUREt1ENT AND !!ATERIAL CONTROL 5.1 Control of Procurenent 53 5.2 Identification and Control of Materials, Parts and Components 59 6.0 CONTROL OF STATION ACTIVITIES 6.1 Policy 61 6.2 Control of Inspections 62 i 6.3 QAtionitoring 65 l 6.4 Control of Special Processes 67 6.5 Test Control 68 l 6.6 Control of Measuring and Test Equipment 70 6.7 Handling, Storage and Shipping 73 6.8 Inspection, Test and Operating Status 75 ,

6.9 Housekeeping and Cleanliness 77 6.10 Equipment Control 78 6.11 Control of Recovery, Defueling, liaintenance !

(Preventive / Corrective) and tiodifications 79 6.12 Control of Surveillance Testing and Inspection 83 g 6.13 Radiological Control 84

{ 7.0 CONTROL OF RADI0 ACTIVE WASTES g 7.1 Policy 86 5 7.2 Requirements 85 j 7.3 Responsibilities 87 a

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TABLE OF CONTENTS 4-00 8.0 CONTROL 0F CORRECTIVE ACTIONS AND NONCONFORMANCES 8.1 Policy 90 8.2 Requirenents 90 8.3 Responsibilities 93 9.0 AUDITS 9.1 Policy 94 9.2 Requirenents 94 9.3 Responsibilities 97 APPENDICES: 99 Appendix A - Comparison Chart of Quality Assurance Plan l Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards 100 Appendix B - QAD Management Control Requirenents for

l. "Important to Safety" Documents 101 Appendix C - NRC Regulatory Guide Comitments and Exceptions 102 Appendix D - Terns and Definitions 120 l

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& Nuclear nec0venr Quatzrv AssuaANCe PLAN 1000-PLN 7200.02 Title Revision No 1.0 ORGANIZATION 4-00 Policy It is the policy of GPUN to conduct recovery activities at THI-2 in such a nanner as to ensure the safety and health of the public and the personnel on site. To implement this policy, GPUN will meet the applicable quality assurance requirements of the Nuclear Regulatory Connission as presented in the Code of Federal Regulations and applicable Regulatory Guides, codes and standards; the ASME Boiler and Pressure Vessel Code as applicable to the State of Pennsylvania; other pertinent federal, state and local quality assurance regulatory requirements; and the GPUN corporate policies.

To conoly with these requirements, the Office of the President has authorized the establishment of a formal and comprehensive Quality As-surance Progran. This Progran, which is described in the following sections, shall be implemented through documented and approved policies, procedures and instructions which comply with this Plan.

Due to the nature of the recovery activities, construction and oper-

! ation activities will coexist. Therefore, this Plan addresses the require-nents and responsibilities related to both activities. Detailed procedures will be used to control the transition from construction to operations.

Responsibilities l

The general structure of the organizational elenents responsible for l the recovery of TMI-2 is illustrated in Figure 1. This organization chart I identifies those functions normally located on site and off site. The GPUN I Organization Plan sets forth specific responsibilities and the implementing .

l procedures identify the interface requirements. j l i l 1.1 President - GPUN {

i The President - GPUN has the overall responsibility for the i establishnent, implementation and effectiveness of the TMI Unit I 2 Recovery Quality Assurance Progran. This responsibility is administered through his management staff, including:

G Executive Vice President - GPUN

Office of Director - TMI-2

. Director - Technical Functions 5 Director - Nuclear Assurance 5 Director - Adninistration

[I Director - Radiological & Environmental Controls I s b

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1.2 Executive Vice President - GPUN '

The Executive Vice President - GPUN reports directly to the President - GPUN and shares in the duties and responsibilities of the Office of the President.

1.3 Office of the President The President and the Executive Vice President constitute the l Office of the President. The two officers work in close co- {'

operation and share the executive duties of GPUN. As used in this Plan, the Office of the President means either the President or the Executive Vice President.

1.4 Office of the Director - THI-2 The Director - THI-2 and the Deputy Director - TMI-2 constitute the Office of the Director - THI-2. The two individuals work i in close cooperation and share the duties of the directorship. I The Deputy Director reports directly to the Director - TMI-2. .

As used in this Plan, the Office of the Director - TMI-2 neans !

either the Director - TMI-2 or the Deputy Director - TMI-2. l The TMI-2 organization is shown in Figure 2. The Office of the l-Director - TMI-2 is responsible to operate and conduct recovery operations of THI-2 in a safe, environnentally sound, reliable i

. and efficient manner in accordance with corporate policies and i j all applicable laws, requiations, licenses, and technical l l requirenents. This includes design and construction of l required facilities. The Office of the Director - THI-2 is i responsible for the following najor functions:

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a. Ofrect and control the plant decontanination and recovery l programs, including the design and construction of I required facilities. ,

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b. Provide and maintain a qualified staff.

c. Operate and maintain all systens and equionent required l for decontr.11 nation and recovery of systens in a safe, i reliable and efficient nanner. i i

d. Direct all licensing matters related to THI-2. )

c.

y 5 e. Provide safety review of significant procedures, plans

& and design changes independent of Engineering and g Operation Groups. ;

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f. , Provide risk assessment of all najor THI-2 activities.

g. Establish cardinal dates for plant evolution, decontanination and recovery activities.

h. Control the scope of work in the plant.

i. Define and establish priorities for the preventive and i corrective maintenance and refurbishment work needed to I ensure needed nateriel condition. I

j. Establish and nafntain plans and schedules, policies, procedures, standards and practices for the Division, )

k. Develop, gain approval, and operate within approved .

annual budget, annual operating plan, and the multi-year strategic plan.

1. Establish day to day priorities for plant support.

n. Develop and naintain effective consultation and advice i

with other Divisions to help assure efficient functioning i of GPU Nuclear. l 4

The Office of the Director - Tf1I-2 gives full support to the quality j assurance requirenents set forth in this Ouality Assurance Plan, assuring conpliance to the fullest degree by the staff. In the event of a disa-greement on a safety issue between the Di, rector and Deputy Director, it shall be referred to the Office of the President for resolution.

The office of the Director - Ti11-2 utilizes the following managenent staff nenbers in carrying out his responsibilities:

Site Operations Director itanager - Recovery Prograns Director Licensing and Nuclear Safety g ;

Technical Planning Director ;

Itanager Government and Industry Prograns fianager Progran Controls i j 1.4.1 Site Operations Director l

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~ The Site Operations Director is responsible to conduct

" plant operations maintenance and engineering at Tii!-2 in a safe, reliable an,d efficient manner consistent with corporate-

-;l requirements and in compliance with all applicable laws, g

ifcenses, regulatory and technical requirements.

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The major functions of Site Operations are to:

a. Conduct plant operations and maintenance activities to provide for efficient recovery in a nanner consistent with license, regulatory and corporate requirenents.

b. Ofrect the inofenentation of preventive and corrective maintenance prograns including the prioritization to assure the plant is naintained in a safe, efficient and reliable nanner.

c. Direct the operation of Radioactive Waste Facilities including the conduct of the Radioactive ffaterial On-Site Moyenent and Shipnent Prograns,

d. Coordinate with Recovery Programs, Technical Planning, Administration and Radiological Control to assure proper support and control of activities, is achieved with respect to plant operations. {

e. Follow Technical Specifications compliance.

1.4.2 Manager - Recovery Prograns .

The llanager - Recovery Prograns reports to the Office of the Director - THI-2 and is responsible to provide. engineering and i field operations necessary for decontamination of the THI-2 l facility and fuel renova 1. This includes design and ;

construction of new facilities and nodifications of existing i facilities required for recovery. Activities shall be conducted in a safe, reliable and efficient nanner and in l-compliance with all appifcable laws, ifcenses, regulating and !

technical requirenents. ji The Design Enoineering organization is located in the Bechtel !

office in Gaithersburg MD and performs their activities in accordance with the Bechtel Nuclear Quality Assurance Plan for l THI-2. This plan, and all revisions thereto, are reviewed and approved by the GPUN Director - Quality Assurance and the

_ Office of the Director TMI-2.

2 The najor functions of the Recovery Prograns Office are to:

E a. Direct and control TMI-2 recovery through the decontam-R ination and cleanup of buf1 dings and spaces and the

-e construction of required support facilities in a safe and j efficient nanner.

9 s b. Direct and control the activities required to renove the g damaged core from the reactor including the construction

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of required support facilities in a safe and efficient manner.

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c. Provide technical support services to Site Operations for modification to existing plant systems and structures,

d. Direct Engineering services, including configuration ;

control of systems, structures and components, in support :

of Site Operations. !

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e. Direct the maintenance of the naster recovery cost and schedule and attendant performance neasurement systems for the Recovery Progran Office scope of work.

1.4.3 Director Licensing and Nuclear Safety The Director Licensing and Nuclear Safety reports to the Office of the Director - THI-2 and is responsible to:

a. Provide primary interface with NRC and provide Licensing :

services for Tril-2. j

b. Provide independent safety review of all procedures, !

design changes, tests, experiments, etc., as required by Technical Specifications. -

i The najor functions of the Director Licensing and Nuclear l Safety are to. ,

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a. Act as interface with the NRC on licensing natters l related to TMI-2. -

b. Responsible for preparation and/or coordination of !

responses to NRC including I&E bulletins, circulars, I notices and inspections.

c. Provide systens for control of Licensing Basis i Docunents-technical specifications, SAR, Technical {

Evaluation Reports, Systen Descriptions, and License. l 5 d. Nenotiate, within limits established by nanagement, with l' NRC on requirenents, schedules, or connitments.

c. ;

5 e. Coordinate the evaluation and reporting of responsible !

R items under technical specifications, NPDES permits (as (

assigned), 10CFR21, 10CFR50.55(e), or other regulations j or licenses.

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f. Provide principal interfaces with NRC's Inspection and Enforcement inspectors and resident inspectors. Resolve issues in apparent conflict with licensing or permit documents or TMI-2 licensing positions,

g. Perform independent safety review of Review Significant procedures, design changes, tests, experiments, and proposed activities.

h. Review audits performed by QA in specified areas and make l appropriate recommendations. '

i. Provide for the technical assessment of fire protection.

J. Prepare Licensee Event Reports and investigate same.

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k. Follow Recovery Operations Plan surveillance, results review and trend analysis.

1. Generally review all TMI-2 activities from a safety :

perspective. I l

'l.4.4 Technical Planning Director i

The Technical Planning Director reports to the Office of the !

! Director - TMI-2 and is responsible for providing technical guidance and direction to the Recovery Program Department and .

Site Operations Department, in the form of technical plans I which detail the approach to be employed, functional criteria, sequences, priorities, and objectives of major recovery steps.

l The major functions of the Technical Planning Director are to: I I

I l a. Identify, prepare, issue and routinely update technical i plans needed for recovery. Ensure that these plans are i concise, quantitative and practically useful documents, i l

b. Identify, cause to be resolved, and document resolution !

of key technical decisions related to recovery planning.

5 c. Establish functional criteria applicable to major recovery steps.

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d. Manage the acquisition, evaluation, recording and reporting of technical data applicable to recovery.

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e. Review recovery scheduling activities as necessary to ensure that planning requirements (sequences, priorities, and the like) are appropriately reflected therein,

f. Interact closely with Recovery Programs and other Ti11-2 Departments to ensure that technical planning is useful and constructive in the overall recovery effort.

g. Serve as the primary technical interface with the Technical Assessment and Assistance Group (TAAG).

t 1.4.5 fianager Government and Industry Programs The Fianager Government and Industry Prograns reports to the Office of the Director Ti1I-2 and is responsible to:

a. Provide coordination and overview functions in connection with government and industry sponsored programs at Ti1I-2.

b. Develop a broadened base for financial support of the ,

Ti1I-2 recovery and inproved nethods for transfer of I outside funding into the GPUNC work effort.

c. itaintain technical interface with the worldwide external connunity in order to benefit from the expertise !

available in such organizations, and to ensure that the !

valuable experience gained during the recovery is ;

disseminated appropriately, g

d. Itaintain interface and provide support to the Safety !

Advisory Board and other such advisory / assistance groups -

l as required. i The najor function of the fianager Governnent and Industry l Programs is to direct the interface with sponsors of government i and industry / funded prograns including coordination of proposal !

I preparations and overview of performance. !

1.4.6 itanager Progran Controls ,

i j The itanager Progran Controis reports to the Office of the Director Ti11-2 and is responsible for providing progran controis support to the Office of the Director - Tril-2.

The major functions of Program Controis are to:

y a. Provide management of Progran Plans and Sumary Schedules.

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b., Coordinate Program Plan Estinates, Budgets and Costs.

c. Provide administrative support to the Office of the Director - TMI-2.

d. Coordinate administrative activities between the TMI-2 Division and the Administration Division in the area of '

Information Management, Materials fianagement, Hunan Resources, and Security.

e. Prepare and issue summary Program Plan Management Reports internal / external.

f. Provide Program Controls, Policies /Hethods/ Procedures and administer their execution.

1.5 Director - Technical Functions The Director - Technical Functions reports directly to the Office of the President and, with regard to THI-2, is !

! responsible for providing, when requested, technical support of l l the recovery effort.

l 1.6 Director - Nuclear Assurance l

The Director - Nuclear Assurance reports directly to the Office {

l of the President and is responsible to ensure that an ;

appropriate Quality Assurance Program whose scope covers all i the systems and activities that affect safety and reliability I is established, inplemented and verified in accordance with ;

corporate Policies, applicable laws, regulations, licenses and .

technical requirements; selectively review both nuclear station and corporate activities with the aim of identifying areas !

where changes could lead to improvenents in the nuclear safety '

and/or reifability cf plant operations; provide training and ,

education of corporation personnel as needed to carry out their '

duties and to meet corporate policies and all applicable laws, I regulations, licenses and technical requirenents; assure that a high level of emergency preparedness is maintained in accordance with corporate policies and all applicable laws, j 2 regulations, ifcenses and technical requirements. The Director l

- Nuclear Assurance has direct access to the GPU Nuclear Board -

I* of Directors for reporting on issues with substantial safety l 5 implications. The major functions of the Nuclear Assurance j

Division with regard to TMI-2, are as follows: l l

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a. Establish and nafntain plans and schedules, policies, j procedures, standards and practices for the Division,

b. Provide and maintain qualified staff.

c. Develop, gain approval and operate within approved annual budget, annual operating plan, and the nulti-year strategic plan. !

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d. Audit, nonitor, inspect, evaluate and assure that all l activities having the potentfa1 for compromising nuclear :

safety tre adequately addressed.

e. Develop and implement necessary training programs.

f. Develop the site energency plans, inplement procedures and plans, conduct and evaluate emergency drills,

g. Develop and naintain effective consultation and advice with other divisions to help assure efficient functioning i

of GPU Nuclear.

The Director - Nuclear Assurance gives his full support to the !

quality assurance requirements set forth in this Quality l Assurance Plan, assuring compliance to the fullest degree by i bis staff. 1 The Director - Nuclear Assurance utilizes the following l nanagement staff members in carrying out his responsibilities: !

Director - Qua11ty Assurance -

Director - Training and Education l Nuclear Safety Assessment Director l Manager - Emergency Preparedness 1.6.1 Director - Ouality Assurance (Figure 3) '

The Director - Quality Assurance Department (QAD) has the i functional authority, independence and responsibility to verify l the effective inplementation of the administrative controis and '

compliance to the Quality Assurance Program during the recovery l

phase of THI Unit 2. .The Director of QAD reports directly to !

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the Director - Nuclear Assurance. Additionally, he has direct l 3

unencumbered access to the Office of the Director - THI Unit 2 i

& and the President of GPUN with regard to quality activities.

This reporting relationship has been established to provide the l g Quality Assurance organization with sufficient independence I

_g from the influence of costs and schedules to be

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Title Revision No 1.0 ORGANIZATION 4-00 able to effectively assure confornance to Trt! Unit 2 Quality Assurance Progran requirements. Figure 3 identifies the Quality Assurance Departnent orqanizational elements which function under the Quality Assurance Progran.

The Director - QAD has no duties or responsibilities unrelated to Quality Assurance that would prevent his full attention to '

Quality Assurance natters, and he has the authority and re-sponsibility to:

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

b. Audit, nonitor, inspect and evaluate activities of GPUN to assure that they provide the required high degree of safety and re11 ability and are carried out in accordance with all applicable laws, regulations, licenses, 3

corporate policies and other requirements.

c. Identify quality problems and initiate, recomend or ;

provide solutions through designated channels and verify j impienentation of resolutions. <

d. Perforn evaluations on a planned and periodic basis to verify that the Quality Assurance Program is being !

effectively inplemented. l

e. Stop work on nonconforming materials or activities if- '

o it is the oniv process available to protect the health f and safety of tha public and/or plant personnel; l

, o its continuance will require significant rework or 5 I

repair to backfit corrective action; I

o its continuance nay jeopardize nuclear safety; i 1

5 o its repetitive failure to comply with program controls g constitutes a significant QA Program deficiency.

f. Direct and manage the Quality Assurance Department.

2 The najor functions of the quality Assurance Department l include the following:

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a. Develop the Recovery Quality Assurance Plan and pro- l cedures necessary to fulfill GPUN QA responsibilities,

b. Provide for the review and acceptance of Contractor and Vendor Quality Assurance Programs within the scope of this Quality Assurance Program.

c. Provide for the review and acceptance of procedures prepared by other than QA organizations within the scope of the Quality Assurance Progran. l

d. Provide a working interface and comunication with the TMI-2 organizations, contractors vendors, and others with respect to QA natters. AddItfonally,inconjunction with the ifcensing organization provide a working inter-face and communications with the NRC with respect to QA matters,

e. Provide for the nonitoring and evaluation of the ,

inplementation and effectiveness of the QA Program by '

l neans of:

Review Surveillance !

Survey lionitoring !

l Audit Inspection l of all organizations, contractors, and vendors for all

important to safety activities. l l l i f. Estabitsh with Training and Education Departnent the i I

scope and content of an indoctrination and training program for QA and QC personnel.

! t i g. Stop work or further processinq, delivery or installation ,

or take other warranted actions on nonconforming .

naterials or activities. !

h. Imediately notify the Office of the President and the Office of the Director Tril-2 of any significant quality j related problen or deficiency or repetitive failure to comply with progran controls which constitute a

, significant QA Progran deficiency. I

~

e 1. Assure QA indoctrination of appropriate personnel outside 2! of the QA organization is provided.

3!

3' j. Issue periodic reports to the Office of the Director j TitI-2 and the Director - Nuclear Assurance, on the l

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i status of qua11ty activities, and bring to their !

attention immediately any significant quality-related i problem or deficiency. I

k. Provide for QA review and acceptance of design and engineering docunents.

1. Provide for QA review and acceptance of procurement ,

documents within the scope of the program. I

m. Provide for and naintain QA records generated by QAD until turnover to document control for storage. !'

The Director - Quality Assurance utilizes the following manage-ment staff members in carrying out his responsibilities:

fianager - Quality Assurance Design and Procurement Manager - TMI Quality Assurance Modifications / Operations tianager - Quality Assurance Progran Development and Audit fianager - Special Processes and Programs l

!1.6.1.1 ffanager - Quality Assurance Design and Procurenent The itanager - Quality Assurance Design and Procurement is re-sponsible to:

t l a. Review and approve contractor and vendor quality programs j for those supplying Important-to-Safety services or items.

b. 'teview and accept design control procedures prepared by other organizations when these procedures control or '

exercise an effect upon Inportant-to-Safety systens, '

l components or activities. !

c. Perforn the necessary post-award qua11ty related activi-ties, including post-award surveys and source sur-vef11ance, in compliance with this Quality Assurance -

Program,

d. Coordinate with the T!!! QA Modifications /0nerations I 5 Section to assure that documentation of manufacturing

' discrepancies is available to the receivina inspectors and the cognizant purchasing or contract nanager, E i

" I

e. Identify quality problens; initiate, reconnend or provide l

solutions through designated channels; and verify imple- j

[ nentation of the resolutions. '

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Tette Revision No I 1.0 ORGANIZATION 4-00 i

1.6.1.2 fianager - Tit! Quality Assurance Modifications /0oerations The ffanager - TMI Quality Assurance ffodifications/ Operations is responsible for the following:

a. ffonitor the inplenentation and effectiveness of the Quality Assurance Progran on site.

b. Establish adequate site nonitoring and inspection prograns ;

necessary to verify conformance to Quality Assurance Progran requirenents.

I

c. Coordinate and direct QAD activities at TMI-2. I

d. Review engineering specifications and procurement docu-nents to assure quality requirements are incorporated,

e. Provide nondestructive exanination support for nodiff- l cations, maintenance and investigative activities in support of the recovery program. '

f. Notify the Office of the Director Tf1I-2 and the Director - I Quality Assurance imediately of any condition, as defined in the appropriate QAD procedures, that warrants stop work,

g. Identify quality problens; initiate, recomend or provide l solutions through designated channels; and verify imple- ;

l nentation of the solutions.

{

h. Review site procedures for comp 11ance with the requirenents of the QA Progran.

l The ffanager - TMI Qua11ty Assurance fiodifications/ Operations I reports directly to the Director - Quality Assurance and periodically reports on the inplementation and effectiveness of the Quality Assurance Progran to the Director - TMI-2 and the Director - Quality Assurance. The Manager - TMI Quality i Assurance ffodifications/ Operations has the authority to stop !

work on a1] inportant-to-safety activities associated with this Quality Assurance Progran, i i

1.6.1.3 ffanager - Quality Assurance Progran Development and Audit E

" The fianager - Quality Assurance Progran Development and Audit is '

responsible to: l

!! a. Coordinate the development and nafntenance of this Quality !

} Assurance Plan and the QAD procedures.

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b. Coordinate the development and administration of the QAC training and certification program,

c. Coordinate the development of QA training and indoctrina- '

tion provided for GPUN and external organization personnel.

d. Develop, inplement and naintain a comprehensive system of ,

planned and periodic audits to verify compliance with all !

aspects of the quality Assurance Program. '

e. Identify quality problems; initiate, recommend or provide I solutions through designated channels; and verify inple- l nentation of the resolutions.

The Manager - Quality Assurance Program Development and Audit l naintains a full time staff of quality assurance engineers and qualified auditors at both the corporate and site offices. The l audit activities and the results of the audits are provided to the audited organization and to the Safety Review Groups who provide the independent management assessments of the signi- ;

ficance of the audit findings and the effectiveness of the Quality Assurance Program.

1.6.1.4 fianager - Soecial Processes and Programs l The fianager - Special Processes and Prograns is responsible to: !

l, '

a. Direct and supervise the GPUN organizations which have !

the responsibility for weldinq, NDE and ISI prograns.

l b. Develop the ISI program for Tf1I-2, excluding IST, hydro testing, leak testing and functional tests.

l '

c. Provide engineering support for IST, hydro testing, leak testing and functional tests.

I

d. Identify quality problens; initiate, recomend and j provide solutions through designated channels; and verify i implementation of the resolutions.

E e. Provide support related to nanufacturing and systens

materials technology problems. l E

2 l A0001()H 1t82 14.0

gggy RECOVERY QUAlfTY ASSURANCE PLAN 1000-PLN-7200.02 l

Title Revision No l 1.0 ORGANIZATION 4-00 f i

f. Develop and inplement certification progran for GPUN flDE .

personnel. ;

I

g. Review and approve contractor NDE programs and procedures, i

h. Develop a comprehensive program of administrative controis and technical requirenents for NDE activities.

The Pfanager - Special Processes and Programs, through a full-tine staff of qualified engineering personal at both !

the corporate and Site Offices, establishes and ,

inplements the engineering and technical requirements for j welding, ISI and NDE programs for GPUNC. The Special l Processes and Programs activities provide effective interfaces and technical support efforts with and for other GPUNC Divisions.

1.6.1.5 Mininum Qualifications of Quality Assurance Personnel The Director - quality Assurance shall have, as a mininun, a i with at least !

baccalaureatedegreeinEngineeringorScience}antoperations five years of QA experience in nuclear power p l or supporting activities. Additionally,theDirector-Quality ;

Assurance nust be knowledgeable in QA requiations, policies and standards. !

l The qualification requirenents and experience levels for other :

I key Quality Assurance personnel are such as to assure compe- l tence comensurate with the responsibilities of each position. '

Quality Assurance Departnent Section and Sub-section ifanagers l

are required to have a degree in Engineering or Science and experience in a position having responsibility for the i perfarnance of quality activities. The degree requirement may be waived for personnel with exceptional qualifications and a i mininun of seven (7) years of related experience.

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Revision No 1.0 ORGANIZATION 4-00 1.6.2 Director - Training and Education !

The Director - Training and Education reports directly to the Director - Nuclear Assurance. He hn the overall authority and responsibility for providing training of corporation personnel, as needed, to carry out their duties and to meet corporate policies and all applicable laws, regulations, ifcenses and ,

technical requirenents. The Director - Training and Education i is responsible for the following najor functions:

a. Develop and implement all necessary general employee, operator, technician and management training programs,

b. Ensure the integrity, control and administration of the Training Progran and the existence of, and compliance with, the policies and requirements of this QA Plan.

1.6.3 Nuclear Safety Assessment Director

' The Nuclear Safety Assessment Director is responsible for the develonnent, direction and supervision of the Nuclear Safety {

' t Assessnent Departnent (NSAD). The NSAD will have access to i documents and reports including those identifying conditions '

adverse to quality (audit reports, nonconfornance reports, survefilance/ inspection reports, reportable occurrences NRC l inspections,etc.). t I '

An independent office of Onbudsnan is located within the NSAD.

This office is available to all nenbers of the corporation having a concern for nuclear or radiation safety, i The major functions of the NSAD at Unit 2 are to:

i

a. Serve as an Office of Ombudsman for all nenbers of GPUN having a concern for nuclear plant or personnel radiation safety. l

b. Provide staff support for the General Office Review Board ,

as required. '

1.6.4 ttanager - Energency Preparedness '

e I

" The Manager - Energency Preparedness is responsible to assure

that TMI Energency Plans and Preparedness are in accordance l with corporate policies and all applicable laws, regulations, l

[ 11 censes and technical requirenents. Additionally, he is to l l

2 M)OO 10y) I t 1l2 16.0

i l

Number

@ Nuclear rec 0vEnvygtvAssuRAnCE iOOO-ptN-7200.02 Title Revision No 1.0 ORGANIZATION 4-00 i

I provide support and guidance in the Energency Planning area for i the Three Mile Island station and to assure the naintenance of i a high state of energency preparedness at the station. The !

Manager - Energency Preparedness is responsible for the j following najor functions:

a. Coordinate emergency planning between the Three fille Island and Oyster Creek stations. :

b. fionitor, evaluate and assure Three Mile Island and Oyster Creek stations have energency preparedness prograns that are coordinated and maintained current, and assure a high I state of preparedness. l

c. Assure that the Three Mile Island stations' Energency Plan is consistent with the latest requirenents of the NRC and with the FEMA-approved Pennsylvania state, county and local energency plans. l

d. Interface with the Nuclear Regulatory Comission, ". tate and local authorities in energency planning areas. l' 1

e. Obtain, review and coment on proposed Taoislation, industry guidelines and standards in the ar a o' i energency planning. Preparation and submittal of coments will be coordinated throuqh the Director !

Licensing and Nuclear Safety, l '

1.7 Director - Administration '

The Director - Administration reports directly to the Office of the President. He is responsible to establish and implement uniforn policies and prograns in Materials fianaqenent, Hunan Resources, Security, Operations Analysis, Infornation ftanagement and Strategic Planning to help achieve Company objectives in accordance with corporate policies and all

, appitcable laws, regulations, licenses and technical I requirements. With regard to TMI-2 the Administration Division '

is responsible for the following najor functions:

3 a. Provide contracting, procurenent, warehousing and j

inventory control services.

b. Provide and maintain a qualified staff.

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RECOVERY QUALITY ASSURANCE f PLAN 1000-PLN-7200.02 g, Rewsion No 1.0 ORGANIZATION 4-00 ,

i c , Develop and administer the security progran,

d. Develop and administer a comprehensive Hunan Resources !

tianagenent function.

l

e. Provide Operations Analyses.

f. Develop and coordinate GPUN's strategic planning process ,

including issue nanagement, and assure its integration !

with other levels of planning within the company. I

g. Pfanage GPUN information nanagement centers and coordinate GPUN policies and procedure systen.

h. Establish and naintain plans and schedules, policies, procedures, standards and practices for the Division,

i. Develop, gain approval and operate within approved annual budget, annual operating plan, and the nulti-year (

strategic plan.

{

j. Develop and naintain effective consultation and advice with other Divisions to help assure efficient functioning of GPU Nuclear.

The Director - Administration is assisted in the perfornance of I

these responsibilities at the site by individuals with assigned I responsibility for security, contracting, procurenent, (

warehousing, information nanagement, and document control.

The Director - Administration gives his full suonnrt to the quality assurance requirements set forth in this Quality l Assurance Plan, assuring compliance to the fullest deqree by his staff.

The Director - Administration utilizes the following management l staff nenbers in carrying out his responsibilities:

I Director - ffaterials fianag:nent !

Director Security .

y fianager Infornation ltanagement Centers i 1.7.1 Director - fiaterials fianagement l

, The Director - fiatorials fianagement is responsible to provide contracting and procurenent, contract administration, ware-lI housing and inventory control services to Tit!-2. l 2

2 AGOQlO M 1t 92 18.0

Number Nuclear RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Ltte Revision No 1.0 ORGANIZATION 4-00 l l

The flaterials fianagement Department is responsible for the following najor functions:

a. Sources, bid, review quotations, negotiate and award materials, equipment, fuels and service requirements for all plants and services divisions, I

b. Administer and expedite perfornance under these contracts and purchase orders. ;

I

c. Review and evaluate vendor clains for changes, extras, delays, suspensions and terninations and equitably '

negotiate those found to be valid. l

d. Receive, inspect, store and issue ordered goods,

e. itaintain inventory levels of repetitively procured items at optinun levels.

1.7.2 Director Security The Director Security is responsible to develop and administer l security programs directed to creating a safe, convenient and i l

, protected environnent for GPUN employees and property. The l'

! Department ia responsible for the following major functions:

l a. Plant security cuard force and surveillance systems and I controls including physical security, physical barriers, ;

access requirenents, detection aids, connunications i

requirements, security equipment testing and naintenance, ;

response requirenents, records and reports involving such

! activities as:

I Insure that it1I-2 is adequately protected against acts of sabotage, arson, theft and civil disturbances.

- Develop and execute plans and nrocedures for the i physical security of THI-2. ;

Provide liaison to regulatory agencies. '

2 Inplement company and NRC rules and regulations, f'

~

Assure all non-company employees and contractors are i properly screened for unescorted access to the !

facility. I 5

.s.

4000io w it 82 19.0

Nuclear RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 l

j Title Revision No i 1.0 ORGANIZATION 4-00 Provide access control through the use of security I surveillance equipment. i Provide physical access control and carry out search requirements.

Plan defenses for civil disturbances and demonstrations, j

Investigate all security incidents. f 1.7.3 Manager Information Management Centers !

l The fianager Infornation Management Centers is responsible for the following najor functions:

a. Inplement and naintain New Information Systems.

b. Provide necessary nanagement, documentation and ,

correspondence control to meet corporate requirements and ;

satisfy ANSI Standard requirements as comitted to in Appendix C of the Plan. j I c. Manage corporate and plant libraries as required.

l I d. Establish, maintain and coordinate GPUN corporate {

l administrative policies and procedures. ;

e. Provide configuration control support. I i 1.8 Director - Radiological and Environmental Controls

i The Ofrector - Radiological and Environmental Controls reports directly to the Office of the President. He is responsible for e the establishment and innlementation of uniforn health, safety, '

radiological and environnental policies, practices and procedures required to assure safe, reifable and efficient operation in accordance with corporate policies and all l

applicable laws regulations and ifcenses. With regard to THI-2theRadiologicalandEnvironmentalControlsDivisionis I 5 responsible for the following najor functions:

l

a. Establish and nafntain corporate level policies, l procedures, standards and practices relatinq to health, y, safety, medical, radiological and environnental activities.

$ b. Provide and nafntain a qualified staff.

l 3 A00010 M II 12 l

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Number MNuclear RECOVERY 0 TY ASSURANCE

_p Revision No. i Title 1.0 ORGANIZATION 4-00

c. Establish and maintain plans and schedules, policies, procedures, standards and practices for the Division.

d. Provide the personnel, procedures and administrative controls to implement the plant health, safety, medical, radiological and environmental protection programs,

e. Provide administrative and technical guidance applicable to radiation protection, radioactive materials, respiratory protection and radiological engineering including ALARA programs and dosimetry control. '

f. Provide professional medical and radiological guidance,

g. Provide administrative and technical guidance applicable to industrial safety, occupational health, environmental protection, environmental monitoring and NPOES.

h. Develop and administer industrial safety programs. ,

f

i. Develop, gain approval and operate within approved annual :

j budget, annual operating plan, and the multi-year {

strategic plan. ;

i

j. Develop and maintain effective consultation and advice l with other divisions to help assure efficient functior.ing l l of GPU Nuclear. '

l

k. Coordinate company activities at Saxton. ,

The Director - Radiological and Environmental Controls gives !

his full support to the quality assurance requirements set l forth in this Quality Assurance Plan, assuring compliance to l the fullest degree by his staff. i The following management staff is utilized in carrying out the ;

responsibilities of the Radiological and Environmental Controls ;

Division Safety and Environmental Controls Director '

2 TMI-2 Radiological Controls Director I E TMI Radiological Assessment Department Medical Director E

I 5

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Number ENuclear REC 0VERY QUAlfTY ASSURANCE PLAN 1000-PLN-7200.02 l Revision No l

Titte I 1.0 ORGANIZATION 4-00 !

i 1.8.1 Safety and Environmental Controls Director .

The Safety and Environmental Controls Director reports directly to the Director - Radiological and Environmental Controls. He is responsible for all environmental, and industrial safety and health matters at Three Mile Island. This is accomplished through the inplementation of all monitoring and study requirements of USNRC, USEPA, and PaDEP as contained in [ :!

Appendix B of the Environnental Technical Specifications, t.he National Pollutant Discharge Elimination System permits, OSHA, 1 NIOSH and other company commitments.

The major functions of the Safety and Environrtntal Controls Department are:

a. Perform Radiological Environmental ffonitoring Programs to l assess impact of radiological releases on surrounding i populations, g

b. Operate and nafntain the meteorological towers. !

I i c. Assess the inpact of plant operation on terrestrial and l aquatic life. i

d. Monitor depth cf water in adjacent rivers and bays to !

ensure sufficient cooling water and determine if !

I navigability has been affected by plant operation, j

e. Conduct other environmerital nonitoring and reporting and !

assure corporate compliance with approprlate Environ-nental Regulations and Licensing requirenents.

I f. Support corporate attorneys in civil and adninistrative l

environmental hearings. '

i I g. Industrial Safety and Health systens, surveys, equipment, l training and implementation of policy procedures, OSHA, l NIOSH and other conmitments. J i

1.8.2 Tril Radiological Controls Director '

l

The Tri! Radiological Controls Director reports directly to ,

4 the Director - Radiological and Environmental Control. He is i 5 responsible for the inplementation of the Tril-2 Radiation l E. Protection Plan and for nonitoring and enforcing the inple- '

mentation of all radiological control policies and procedures i i consistent with the requirements of the plan in support of the f j Tri!-2 operations, naintenance and recovery effort. l A0001060tt 82 22.0

Nuclear aEC0vERY QUALITY ASSURANCE 1000-PLN-7200.02 Title Revision No 1.0 ORGANIZATION 4-00 The major functions of the Radiological Controls Department ara as follows:

a. Control external exposure through the administration of a Dosimetry Program,

b. Control internal exposure through administration of a Respirator Protection, Bioassay and Whole Body Counting Program.

c. Control radioactive contamination.

d. Control radioactive materials.

e. Perforn reviews of the Radiological Controls Program,

f. ffaintain procedures to ensure exposure to workers and the general population is as low as reasonably achievable.

g. Assure corporate compliance with appropriate Radiological !

Regulations and Licensing requirements.

h. Train and qualify TMI-2 radiological technicians in Radiological Control Procedures and techniques. Approve radiological training of others.

l 1. Provide dosinetry program services for both THI-1 and '

l THI-2.

j. Provide respirator protection, bioassay, and whole body counting services for TMI-1 and THI-2.

l l k. ifaintain and calibrate all radiological equipment used by !

the TMI-1 and THI-2 Radiological Controis Department.

f

1. Stop work not being accomplished in accordance with appropriate Radiological Control practices and procedures when deemed appropriate.

_ m. Support plant operations and provide extra support during 2 the recovery effort.

1.8.3 THI Radiological Assessment Department 3 A Radiological Assessment Department is provided at Three Mile

Island. The department performs independent analysis of the i

implementation of the radiological controls program and radio-9 logical (.ontrol practices at the station. The major functions 5 of the department are to

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a. Conduct frequent tours in areas where radiological work i being performed.

's i I

b. Review compliance with Federal Regulations, license re-quirements and radiological control procedures.

c. Prepare periodic radiological assessment reports for {

nanagement. l l

d. Review radiological work practices for ALARA i considerations.

I

e. Stop work not being accomplished in accordance with I appropriate Radiological Control practices and procedures when deened appropriate.

1.8.4 ffedical Department The i4edical Department is responsible for the direction of the i GPU Nuclear !!? dical Progran. This includes direction of !

contract physicians and GPU Nuclear nedical personnel as well I as provision of professional medical guidance and participation !

in radiological natters. The najor functions of the Medical ;

Department are to: '

a. Reconnend sound nedical policies for conduct of business by GPU Nuclear Corporation,

b. Direct and impienent the GPU Nuclear tiedical Progr_.in, and {

certify professional qualifications of the medicte staff.

c. Provide medical guidance to the division directors in th'e medical aspects of radiation exposure and other :

occupational health hazards. I

d. Establish and naintain technically clear and concise medical records. '

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gggy l REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 2.0 QUALITY ASSURANCE PROGRAM 4-00 Policy 2.1 General The GPUN Recovery Quality Assurance Program has been estab-11shed to provide overall quality assurance of recovery activ-ities within the scope of the progran. Adherence to the requirements of this Quality Assurance Program is mandatory for all GPUN organizations and for all external organizations pro-viding items or services covered under the scope.

This Recovery Quality Assurance Plan is the highest level docu-ment which describes the Qua11ty Assurance Program. The term "Progran" as used herein includes subtier inplementing poli-cies, procedures and instructions.

Any conflicts, which cannot be resolved at the Department or Section level, regarding interpretation or implementation of this Plan shall be pronptly reported to the Director - Qua11ty Assurance for resolution. 1 2.2 Scope The scope of the GPUN Recovery Qua11ty Assurance Progran in-cludes all itens and activities applicable to the recovery, operation and nafntenance of TMI-2 considered to be "Important to Safety." This tern is broader than " safety-related" and ,

encompasses structures, systens and components (including '

nuclear fuel and radwaste) which have been designated as Safety-Related, Safety Class, IEEE Class IE, Seismic Category I or Fire Protection. The scope of the Program includes itens l required by the following:

a. Title 10, Code of Federal Regulations, Part 50, Appendix !

A " General Design Criteria for Nuclear Power Plants" j

b. Title 10, Code of Federal Regulations, Part 50, Appendix B " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" 5 c. Title 10, Code of Federal Regulations, Part 71, Subpart H

" Quality Assurance for Shipping Packages for Radio-7.

~

active Material"

=

d. Branch Technical Position ASB 9.5-1 " Guidelines for Fire

[ Protection for Nuclear Power Plants" 3

A0001050t1 82 28.0

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e. United States Nuclear Regulatory Commission Regulatory Guide 1.143 " Design Guidance for Radioactive Waste Man-agement Systems, Structures and Components Installed in Light Water Cooled Nuclear Power Plants"

f. U. S. Nuclear Regulatory Conrnission Regulatory Guide 1.29

" Seismic Design Classification" and the seismic aspects of components which have impact on items important to safety f I

g. Other items when designated by the Office of the Director '

TMI-2.

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

The GPUN Recovery Quality Assurance Program applies to all items on the Quality Classification List (QCL). The QCL will be periodically updated to include new plant modifications or !

construction or any changes in classification. The list will be treated as a controlled document. .

For new design efforts such as plant modifications and new I construction, the classification determination is recorded on design criteria documents. New items will be included in the l' QCL. Documents which control the installation of modifications l' which have been classified as "Important to Safety" will be clearly identified as such.

2.2.1 Activities which are Important to Safety shall include, but not be limited to:

a. Those activities covered by ANSI N18.7 and Appendix A of Regulatory Guide 1.33. j i

b. The requirements of other Regulatory Cuides applicable to !

operations, maintenance, modification, repair, radwaste i shipments and operation of radwaste systems of TMI-2 as l identified in Appendix C herein. ;

2

c. Those activities related to Fire Protection as covered by

<. the Branch Technical Position ASB 9.5-1.

& d. Those activities related to Plant Security as covered by Title 10, Code of Federal Regulations, Part 73.55 3 " Requirements for Physical Protection of Licensed 3 Activities in Nuclear Power Plants Against Industrial i s Sabotage. "

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RECOVERY Q TY ASSURANCE 1000-PLN-7200.02 i Revision No 2.0 OVALITY ASSURANCE PROGRA?1 4-00

e. Those activities defined by procedures which have been

' designated during the review cycle as "Important to Safe-ty."

f. Those activities associated with decontamination and damage assessment.

2.3 Recovery Quality Assurance Plan This Recovery Quality Assurance Plan is the primary document which establishes the policies, goals and objectives of the Program. This Plan is authorized by the Office of the Presi-dent and requires that the appropriate levels of management, as designated herein, inplement the Progran. This Plan is con-trolled to assure that only the latest approved revision is implemented. This Plan is impienented through approved de-tailed procedures and instructions.

With the exception of the Organization, Section 1.0, and the QA ;

Progran, Section 2.0, each section of this Plan contains three -

major subsections:

Policy--A sunnary description of the policy of GPUN regarding the specific subject of the section.

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

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

! The purpose of this Plan is to establish the principles which,

} when implemented, will provide that level of quality assurance which is appropriate to each iten or activity important to l safety. It is recognized that the degree of management control or quality assurance to be applied varies with different sys-tens and activities, and the degree of applicability of any specific iten in this Program will differ fron iten to item and

_ activity to activity.

2 E 2.3.1 Graded Approach

2.3.1.1 Application

The degree to which the requirements of this Plan and its in-i piementing procedures are applied will be based upon the 3 following

=

2 AOOO 105011 92 30.0

Number ENuclear RECOVERY Q TY ASSURANCE 1000-PLN-7200.02 Title Revision No.

2.0 QUALITY ASSURANCE PROGRAM 4-00

a. The importance of a malfunction or failure of the iten 'o

' safety.

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

c. The need for special controls and surveillance or noni-toring of processes, equipment and operational activities,

d. The degree to which functional compliance can be demon-strated by inspection'or test.

e. The quality history and degree of standardization of the item or activity,

f. The intended life during which the item performs an In-portant to Safety function.

The quality requirements for items Inportant to Safety will be established using approved procedures based on the " General !

Logic Considerations" listed in the Appendix to ANSI N45.2.13-1976. Quality requirenents will be established by the responsible department and concurred with by the Quality Assur-ance Department for those items which are Important to Safety.

2.3.1.2 Verification GPUN is comitted to a comprehensive Quality Assurance Progran '

consisting of a three-level approach to assure satisfactory and conplete implementation of the progran connensurate with its requirements for safety and performance. The Program's fore- !

most considerations are the protection of the general public's I health and safety. l 1

Level I - Activities at this level consist of inspections, checks and tests. First-level activities include independent inspections, checks, or tests performed for the purpose of establishing acceptance and/or verification of equipment, sys-tens and activities Inportant to Safety. tihere the first . level

_ activities involve independent inspection for purposes of ac-2 ceptance and/or verification of nodffications to Inportant to E Safety systens, the activity will be performed by the QA De-2 partment or'by organizations authorized to perform those activ-g ities by the QA Department. Level I activities are performed

by Quality Assurance, Operations, Recovery Programs, Radio-

logical Controls, and contractor personnel.

il l e A000 t O5011 82 31.0

ENuclear Number accoveRY QUAllTY ASSURANCE ;

PLAN 1000-PLN-7200.02 l Title Revision No 2.0 QUALITY ASSURANCE PROGRAM 4-00 Operations, Recovery Prograns and Radiological Controls

' personnel perform activities such as surveillance tests, calibration of instruments, radiation surveys, analyses of samples, valve line-ups, pump and valve maintenance and overhaul, inspections of the reactor internals and fuel, etc.

Quality Control personnel perforn receipt inspection and checks and inspections of modifications and maintenance activities.

Contractors perform inspections as applicable to their scope of work.

In all cases, the inspection, check and testing activities are performed by individuals who are knowledgeable of the activity being perforned and are qualified to perform the work. Check-lists, weld history records, travelers, etc., are used for documenting the results of the activity and for providing a record of the performance of the activity. .

Level II - The activities at this level are prinarily those of surveillance or monitoring and are performed as deemed neces- '

sary by the QA Modifications / Operations or QA Design and Pro-curement Sections. The level of surveillance /nonitoring applied is consistent with the importance of the item to safety and the extent of administrative controls utilized for the Level I activity. For activities where GPUN Quality Control is performing first-level inspection, no second-level activity is .

required. I I

At this level, procedures and instructions are established and surveillance records will be completed and maintained. Such surveillance / monitoring normally includes observation of tests and inspections, observation of selected operations, review of i records, verification of test reports, and direct inspection on !

a spot-check basis. The organizations perforning this activity !

have the levels of authority, the lines of internal and exter-nal connunication for management direction, and the properly

_ trained personnel for implementation of these activities.

~

Level III - The purpose of this level of activity is to assure, through a comprehensive progran of review and auditing, that E

the first and second levels of the program are properly func-5 tioning. The purpose of this level is also to establish that

all other organizations, including Operations, Maintenance, g Engineering,fiaterials Management, etc., are properly l

2 satisfying all the requirenents of the Recovery Quality s Assurance Program.

3

?.

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@ Nuclear RECOVERY QUALITY ASSURANCE 1000-PLN-7200.02 nue Revmon No I

2.0 QUALITY ASSURANCE PROGRAM 4-00 i

l At this level, procedures and instructions are established, I including the use of comprehensive checklists for documentation of the audit or third-level activity. The progran requirements l of ANSI N45.2.12 shall be satisfied. C'ualified audit personnel shall be utilized who satisfy the requirements of ANSI N45.2.23. Additional technical experts, from areas with admin-istrative reporting outside the function that is being audited, will be included as the Audit Team Leader deems necessary. The j organization perforning this activity has sufficient authority :

and ifnes of internal and external communications for obtaining l the necessary management direction.

j 2.3.2 Recovery Quality Assurance Plan Control 2.3.2.1 Approval This Plan includes a Statement of Policy which is signed by the President - GPUN. The Statement of Policy provides authoriza- i tion and evidence of management commitnent to the Quality As- ,

surance Program.

This Plan shall be approved by the Office of the President and shall be reviewed for concurrence by the following:

l Office of the Director - TMI Unit 2 :

Director - Nuclear Assurance !

l Director - Administration i

! Director - Radiological and Environmental Control Director - Technical Functions l j

2.3.2.2 Revisions '

I

! The Director - Quality Assurance in conjunction with the Director Licensing and Nuclear Safety, shall for each revision to this Quality Assurance Plan, determine if the changes reduce or do not reduce the commitments previously accepted by the NRC.

l! i l

Revisions to the Quality Assurance Plan that do not reduce the commitments to the NRC shall be approved by the Office of the President with the concurrence of the Director - Nuclear l!

2 ,

Assurance and subnitted by the Director - Quality Assurance as E indicated on an Approvals Page which shall be added to the 2 nanual behind the Cover Page. The Cover Page containing the i

approval and concurrence signatures of the Office of the

~, President and the Division Directors shall be retained.

s Revisions of this type do not require approval by the NRC prior l i' to issuance, but must be submitted to the NRC at least annually. l x

1 2

AOOO t 05011 82 33.0

Neu ENuclear RECOVERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02 f

Title Revision No 2.0 QUALITY ASSURANCE PROGRAM 4-00 Revisions to the Quality Assurance Plan that reduce the commit-menti to the NRC shall be submitted to the NRC and receive NRC approval prior to issuance. Revisions shall be regarded as approved by the NRC upon receipt of a letter to this effect from the appropriate reviewing office or 60 days after submittal to the NRC whichever cc.aes first. The submittal of the revision to the Quality Assurance Plan must include all pages affected.by that change and must be accompanied by a transmittal letter identifying the change, and the basis for concluding that the revision continues to satisfy 10CFR50, Appendix B and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC (the letter need not provide the basis for changes that correct spelling, punctuation, or editorial items). A copy of this letter must be maintained as a facility record for three years. Revisions of this type shall be approved by the Office of the President, concurred with by the Division Directors and submitted by the l Director - Quality Assurance as indicated by their signatures on a revised Cover Page.

2.3.2.3 Distribution I Copies of the Recovery Quality Assurance Plan may be dis- ,

tributed as " Controlled" or " Uncontrolled" copies in accordance ;

with the requirements established in Section 3. '

l 2.3.2.4 Effective Date of Inplementation j Changes to this Plan shall be incorporated in the inplementing I procedures within 60 days of the issuance date of the Plan !

unless an interim action plan is defined and approved by the !

Director - Quality Assurance. '

i 2.4 Quality Assurance Program Review ;

The effectiveness of the QA Program and its implementation is periodically reviewed by various organizations at various levels i and the results of these reviews are documented in reports to j the Office of the' Director THI-2, the Division Directors and the

_ Office of the President for evaluation and corrective action as l ;

I

required. The effectiveness of the QA Program is evaluated and I E reported by the QA Department through the survefilance, !

~

monitoring and auditing functions. In addition, the QA Department periodically prepares evaluation reports on the

Program effectiveness. Other divisions provide additional

infornation/ evaluations as requested. ;

i l B

l l

b A000105011 82 34.0

Number ENuclear REC 0veaY QUALZTY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 2.0 QUALITY ASSURANCE PROGRAM 4-00 In addition to the reviews and evaluations performed by the QA Department, the Office of the President shall have, at least once per year, an independent assessment perforned of the QA Program implementation to ensure that the activities neet the regulatory requirements and the policies of GPUN. This assessment may be performed utilizing the safety review groups, an independent consultant, representatives of other utilities and/or his own staff. Any corrective action which may be deemed necessary as a result of these assessments shall be formally identified and tracked through resolution.

2.5 Indoctrination and Training The GPUN Quality Assurance Program includes requirements for formal indoctrination and training programs of personnel per-forming or verifying activities Important to Safety. Training departments are established and staffed at the Corporate office and at the Ti1I site. These training departments are each re-sponsible fc: planning, scheduling and providing training to GPUN personnel. The specific needs and the subject naterial to ,

be covered in the indoctrination and training programs are j established by both on-site and off-site organizational units responsible for the activities. These prog"ans are implemented by appropvfate trsining plans and procedure; which assure that:

a. Personnel are instructed as to the pcrpose, scope and inplenentation of manuals, procedures and instructions,

b. Personnel are trained in the principios and techniques of the activities being performed. Training requirenents ,

will be established consistent with tha importance to I safety of the activity requiring qualification. !

l l

c. Proficiency is maintained by retraining, and/or reexamin- j ing. i d.

l The scope, nethod and objective of the training is docu-mented.

i e. Records of training sessions are prepared and maintained,

including identification of the content, the attendees, and the date the training was conducted.

For personnel performing inspection, examination, and special

processes, the qualification criteria shall be delineated to the g techniques of inspection or itens being inspected and the a technical abilities of the person being certified will be con-s sistent with the assigned tasks (e.g., electrical inspection, mechanical inspection, etc.).

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REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Revision No.

2.0 QUALITY ASSURANCE PROGRAM 4-00 2.6 Classification 2.6.1 General The significance of an item or activity to an Important to Safety function shall be considered in its classification.

Procedures shall be prepared, at the Corporate and/or Division levels, which establish the requirements for identification and control of classification of Important to Safety items and activities. These procedures shall be reviewed and concurred with by the Quality Assurance Department prior to issuance.

Procedures, or portions thereof, for controlling Important to Safety activities shall be identified as such. Systens and major components, but not parts thereof, which are Important to Safety will be identified on a Quality Classification List (QCL). A QCL will be established and naintained, by Recovery Programs. The classification of the systems and components on the QCL will be subject to independent design verification by Recovery Programs. ,

l For procurement of spare or replacenent parts, where there is a l change to a lower classification, the classification will be l deternined by Plant Engineering or Recovery Prograns and con- l curred with by Quality Assurance. The determinations will be ;

documented and retained. i 2.7 Regulatory Comnitments Records of connitnents to regulatory requirements are main-tained by Licensing and Nuclear Safety Department. Appendix C I

herein lists those Regulatory Guides which contain specific l Quality Assurance requirenents with the stated Company position, j exceptions and/or clarifications. These must be complied with I in conjunction with the QA Plan. Appendix C will be revised, as j necessary, to reflect any change in the GPUN commitment to the j Regulatory Guides. Licensing and Nuclear Safety Department is j responsible for providing GPUN positions and interpretations on all other Regulatory Gui.ies.

5 2.8 Safety Reviews

2.8.1 The safety review program involves three major elenents

E R 2.8.1.1 The first element of the safety review program requires a review of each docunent by someone other than the individual doing the j work. This review will be performed by a qualified Responsible 3 Technical Reviewer (RTR) on all activities Important to Safety y including design work or changes, plant operating, emergency and g alarm procedures, radiological control procedures and plant y maintenance procedures.

A 30105011 82

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I Numbir gggy RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 ll l

Title Revision No l2.0QUALITYASSURANCEPROGRNt 4-00 l 2.8.1.2 The second element of the safety review progran is the Safety l Review' Group (SRG). The SRG is a full time organization with i primary responsibility for Independent Safety Review and does not have ifne responsibility for operations or recovery. It is independent of the plant staff and reports to the Director Licensing and Nuclear Safety. This group will perform or arrange to have performed (by qualified individuais) safety reviews of all activities Important to Safety including those !

required by Technical Specifications and/or Organization Plan !

prior to implementation. In addition, the SRG may review, on a I selective and overview basis, any items determined by an RTR and i the cognizant department head not to be Important to Safety. I These reviews may be performed at the discretion of the SRG, the l!

Director Licensing and Nuclear Safety or the Office of the Director THI-2. These reviews may be perforned after l inplementation. An additional activity performed by SRG is the review of specified audits performed by Quality Assurance and recomending actions as a result of these reviews. Reports of these reviews shall be prepared, approved and then transmitted to the Office of the Director TMI-2 through the Director :

Licensing and Nuclear Safety and the nanagement position j responsible for the area reviewed. The SRG will be staffed by a !

full-time group of engineers, located on-site, each of whor '

shall have an academic degree in engineering or a physical i science field and 5 years of professional level experience lo '

! the nuclear power field including technical supporting functions !

l or 9 years of appropriate experience. Credit toward experience !

will be given for advanced degrees en a one-to-one basis up to a naxinun of two years.

2.8.1.3 The SRG shall have access to the unit and unit records as ne- '

cessary to perform its evaluations and assessnents. Based on I its reviews, the SRG sha11 orovide recomendations to the Office I of the Director TMI-2 through Director Licensing and Nuclear :

Safety.

2.8.1.4 The third eienent of the safety review program is the General ,

Office Review Board. This is a group of senior level indivi- i duals with diverse backgrounds. 'It reports to and takes gen- l eral direction from the Office of the President but has direct ;

5 access to the Chief Executive Officer and the Board of Direc- I

tors. Its charter is broadly defined to encompass all matters 7.

potentially affecting safety so as to foresee potentially sig- ;

j nificant nuclear and radiation problems,

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s '

E I

i

_5 l 2

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Number gggy RECOVERY Q TY ASSURANCE Title Revision No.

l2.0QUALITYASSURANCEPROGRAM 4-00 f 2.8.2 Quality Assurance Department:

The normal audit progran conducted by the Quality Assurance Department as described in Section 9.0 also provides managenent with assessment of progran status and effectiveness.

2.9 Responsibilities 2.9.1 Office of the President i

The Office of the President - GPUN is responsible to regularly assess the scope, status, adequacy and compliance of the Quali-ty Assurance Program to the requirements of 10CFR50, Appendix B. 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 As-surance Progran,

b. Performance at least once a year of an independent as- !

, sessment of the effectiveness of the Quality Assurance t Program to assure that the Program meets regulatory re- l quirenents and the policies and directives of GPUN. This l assessment nay be performed utilizing the safety review :

groups, an independent consultant, representatives from i other utilities and/or the President's own staff. Any I I corrective action which may be deemed necessary as a ;

I result of these assessments shall be forna11y identified l and tracked through resolution.

l 2.9.2 Director - Nuclear Assurance

) The Director - Nuclear Assurance has overall responsibility for '

establishment of the GPUN Recovery Quality Assurance Plan. He ,

also has overall responsibility for establishnent and nanagement i' of the Nuclear Safety Assessment Department, the Quality

, Assurance Department, the Training and Education Departnent and i Emergency Preparedness. He shall provide periodic status !

! reports to the Office of the President on the effectiveness and ,

implementation of the Quality Assurance Program. I I

a i 5 l' 11 1 8 1 :

2 A000105011 82 38.0

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.ggMg' RECOVERY QUALITY ASSURANCE l

l PLAN 1000-PLN-7200.02 Title Revision No 1

2.0 QUALITY ASSURANCE PROGRAM 4-00 1 2.9.3 Director - Quality Assurance The Director - Quality Assurance has the responsibf11ty for verifyin Program.gHe theshall effective implementation establish of the and implement Qualitydocumented a formally Assurance and procedurally controlled progran to evaluate and report to the Director - Nuclear Assurance on the adequacy and continued l effectiveness of the Quality Assurance Progran. The basis for the evaluation reports to the Director - Nuclear Assurance l

includes reports of audits performed by the Qua11ty Assurance !

Department or their agents; survefilance/ monitoring of station activities performed by the site QA organizations; reports of evaluations, surveillance and audits of vendort; and quality trend analyses based on nonconformance and deficiency reports and reports of inspections, examinations, surveillance / monitoring and audits. Corrective actions shall be implemented by responsible nanagement as deemed appropriate when analyses reveal adverse quality trends. These actions may involve specific actions to provide compliance with the Quality Assurance Program and may include follow-up system attribute audits and revision to the Quality Assurance Progran.

Implementation and close-out of corrective actions shall be effectively monitored by the Director - Qua11ty Assurance to ,

assure timely correction and compliance. The Director - Quality ;

Assurance is responsible for the contents of the Recovery Quality Assurance Plan and for ensuring that the Plan is :

I modified and updated as standards, regulations, requirenents and j experience dictate. Proposed revisions to this Plan may be j suggested by GPUN personnel by submitting the request, in i writing, to the Director - Quality Assurance for review and action.

The Director - Quality Assurance is also responsible to provide the required training and qualification of QA Department '

personnel and the indoctrination and training of other GPUN :

personnel in the Quality Assurance Progran.

{

2.9.4 Office of the Director - TMI Unit 2 l The Office of the Director - TMI Unit 2 is responsible, via the 2 Manager Recovery Programs, for development and maintenance of E

the QCL. He solicits input and cocrdinates with affected or-

~ ganizations to assure a uniform approach to classification of I' items and activities Inportant to Safety.

The Office of the Director Tfil-2 is respontible via the Director i i Licensing and Nuclear Safety for performanca of the Safety 3

Review Group.

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AGOO 105011 82 39.0

gggy REC 0VERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02 '

l Title Revision No. ;

l 2.0 QUALITY ASSURANCE PROGRAM 4-00 l l'

2.9.5 GPUN - Management Management personnel in each department are responsible for the implementation of the Quality Assurance Program by their de-partment or group, including the developnent of procedures, training and indoctrination of personnel and implementation of the Program on all Important to Safety activities.

2.9.6 External Organizations l l

Quality Assurance Programs and implementing procedures for suppliers or contractors providing materials and services for GPUN which are covered under the scope of this Qua11ty Assur-ance Program shall be subject, when specified in procurement documents, to review and acceptance by the Quality Assurance Department prior to the commencement of any Important to Safety activity.

2.9.7 Resolution of Disputes and Escalations Resolution of disputes involving quality arising from a dif-l ference of opinion between QA/QC personnel and other organiza-tions (engineering, procurement, manufacturing, construction, j operation, maintenance, etc.) shall, if possible, be !

accomplished at the level at which such disputes occur. If this I is not possible, the difference of opinion shall be escalated l l through supervisory / management levels until resolution is j achieved. ,

{

The Director-Quality Assurance shall make the decision on natters concerning inspection and acceptance to established requirenents. The Manager Recovery Programs shall make the l l decision on matters concerning interpretation of technical !

! requirements or design changes. The Office of the Director ;

TMI-2 shall make the decision on matters concerning plant safety.

The Director - Quality Assurance shall be responsible for i evaluating deficiencies for trends. Significant or repetitive l failures to comply with administrative, technical or operational }

Quality Assurance controls will be further evaluated to '

5 determine the safety significance of the condition. In these

l cases, nanagement af the organization shall be notified of the

~. condition and shall be afforded an opportunity to take l 5 appropriate corrective action. If this action is not taken, a

&_ Stop Work Notification will be issued.

f 5

3 5

A000105011 82 40.0

~*

Nuclear aEC0vEav QUAUTY ASSURANCE PLAN 1000-PLN-7200.02 '

f Title Revision No 3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00 3.1 Instructions, Procedures, Drawings and Po11cies 3.1.1 Policy The GPUN Quality Assurance Program requires that activities Important to Safety be prescribed by documented procedures, instructions, and/or drawings and that these activities be ac-complished in accordance with these documents. All user per-sonnel nust be indoctrinated to the above prior to inplementa-tion. l 3.1.2 Reg'Jirements Procedures, instructions, drawings, and/or policies which pre-scribe the performance of activities Important to Safety shall conply with the requirenents of this Plan. To acconplish this these documents shall:

a. Include quantitative (such as dimensions, tolerances, and operating limits) and qualitative (such as workmanship :

samples) acceptance criteria sufficient for deternining that Important to Safety activities have been satisfac- l torily accomplished. 3 l

b. Require approval and concurrence of responsible personnel !

prior to the initiation of the important to safety '

l . activity.

c. Describe the action to b'e acconplished. I

d. Define the responsibilities and authorities of personnel perforning the activity, j

e. Describe interfaces with other company elements or other )

organizations.

f. Be distributed in a controlled nanner to preclude the use of obsolete documents and with sufficient nunber of copies to assure availability to responsible personnel.

5 5

a b

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AOOO105011 82 41.0

Ne Nuclear RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 l

Title Revision No 3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00 l

g. Require that changes be documented and approved prior tc

'being inplemented.

h. Require that revisions be reviewed and approved by the same organizations that performed the original review and approval or by organizations designated by the originating organizations.

Measures shall be established to control and coordinate the l approval and issuance of instructions, procedures and drawings l including changes, which prescribe all Inportant to Safety :

activities. These measures shall include the requirements for review of the documents by the Quality Assurance Department.

This review is to provide an independent verification that the i docunents have been prepared, reviewed and approved in accor- I dance with established policy and program controls; they con-tain the necessary policy and progran requirements including the inspection and verification requirements where applicable; and they contain clear descriptions related to the extent of documenting results of completed actions when required. These documents include but are not limited to, operating and special i orders, operating procedures, test procedures, equipment and naterial control procedures, maintenance or nodificaticn procedures, etc. .

Plant procedures shall be reviewed by an individual knowledge- l able in the area affected by the procedure no less frequently ;

than every two (2) years to determine if changes are necessary l or desirable. A revision of a procedure may constitute the !

above review provided the results of the review are docunented. !

, 3.1.3 Resoonsibilities ;

! 3.1.3.1 Department Managers i The Director / Manager of each department performing activities l Inportant to Safety is responsible for the preparation, I approval and implementation of procedures, instructions and/or ;

drawings necessary to effectively implement this Plan. They l are responsible to assure that provisions are made for !

2 interface controis for internal and external ifnes of i communications anong participating organizations and technical

l disciplines. Where references are required to implement the j procedure, they shall be so indicated along with the identification of the specific requirements of the references q which are applicable to the procedure.

f 5

2 AOOO 105011 92 42.0

N e er ENuclear REC 0vERY auAuTY ASSURANCE PLAN 1000-PLN-7200.02 ,

Title Revision No 3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00 3.1.3.2 Quality Assurance Department (QAD)

The QAD shall review those administrative policies, procedures, and instructions which delineate the methods of complying with the requirements of this Plan.

When specified in procurement documents, contractor and vendor Quality Assurance Plans / Manuals, special process procedures, and inspection and test procedures shall be reviewed and approved by QAD prior to releasing the contractor or vendor to start work. Compliance shall be verified throu surveillance / monitoring and inspection program.gh the audit, 3.1.3.3 External Organizations Those activities Inportant to Safety which are perforned by contractors, suppliers, or vendors shall be delineated by documented, approved, and controlled procedures, instructions or drawings.

3.2 Docunent Control 3.2.1 Policy ;

i Measures shall be established and documented to control the j issuance of documents, such as program documents, design docu- l ments, instructions, procedures, and drawings, including l changes thereto, which prescribe activities as defined in Sec- '

tion 2.0 of this Plan. These measures shall assure that docu-ments, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distribu- l ted to, and used at, the location where the prescribed activity i is performed. .

I 3.2.2 Requirements Written document control procedures shall be established to provide for control of all Inportant to Safety activities.

These procedures shall address all of the Important to Safety activities performed by GPUN, including, but not limited to the 2_ following:

}= a. As-built Drawings

$ b. Quality Assurance Plans / Manuals, and Procedures

! c. Operating Procedures & Instructions l d. Maintenance Procedures & Instructions 3

e AOOO 105011 82 43.0

""D" ENuclear RECOVERY QUALITY ASSURANCE AN 1000-PLN-7200.02 l l

Title Revision No 3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00

e. Design Docunents (e.g., calculations, drawings, specifi-

' cations, analysis) including documents related to com-puter codes.

f. fianufacturing, Construction and Installation Drawings

g. flanufacturing, Construction Modifications, Installation, Test, and Inspection Procedures and Instructions

h. Procurement Documents

i. FSAR and Related Design Criteria Documents J. Nonconformance Reports

k. Design Change Documents

1. Test Specifications

n. Operating and Special Orders !

j n. Equipnent & Material Control Procedures ,

i

o. Refueling Procedures j

p. Quality Classification List (QCL)

q. GPUN Topical Reports All procedures established for document control shall meet the !

following requirenents: !

~

I a. Review, approval and issuance criteria for docunents and their revisions shall be specified to assure adequate I technical and quality requirements are met prior to issue. j

! i

b. The organ'izations or positions responsible for reviewing, !

, approving and issuing documents and their revision shall l be specified.

5 c. Changes must be documented and approved prior to being implemented.

l }

d. Revisions shall be reviewed and approved by the same

~

organizations that performed the original review and ap-proval or by organizations designated by the originating a organizations.

3 AGOO105011 92 44.0

gggy RECOVERY QUALITY ASSURANCE PLAN

[

1000-PLN-7200.02 :

Title Revision No 3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00 t

e. Docunent distribution nust be sufficient to assure that the documents are readily available, at convenient loca- i tions, to responsible personnel prior to comencenent of I work,

f. The user of documents is responsible for assuring that the latest issue of the document is being used to perform work, thus assuring that voided, superseded or obsolete '

documents are not used. Master lists which identify the '

current revision number of docunents will be naintained i to assist users. As an alternative to master lists, document; may be issued as controlled documents, and as l such, shall be stamped " official copy" or " controlled l copy." Holders of controlled documents or master lists are responsible for maintaining their assigned copies in l a current status. Documents distributed for information only wf11 not be considered current, and, as such, will net be t' sed in performing an activity Important to Safety.

g. In the special case of documents containing information !

pertaining to plant security, provisions shall be made to

prohibit unauthorized disclosure of certain safeguards j information. These provisions shall include identifica- '

tion of the documents, restrictions on their distribution and storage in locked security storage containers. ;

I 3.2.3 Responsibilities l

3.2.3.1 Director - Administration

Responsible to develop, maintain and administer GPUN Policies, l j Procedures and Plans including procedures for the control of :

I documents and to establish and inplement the GPUN Document l Control Program. -

3.2.3.2 Director - Nuclear Assurance I i

Responsible via the Director - Quality Assurance for the review i and approval of GPUN Document Control Program procedures for !

quality assurance requirenents and document control neasures; i 5 and to evaluate the overall document control system effective-ness through review and audit.

c.

l a

2 r

AOOO1n5011 82 45.0

Number Nuclear REC 0VERY QUALITY ASSURANCE etAn 1000_etu-7200.02 Title Revision No 3.0 CONTROL OF DOCU?iENTS AND RECORDS 4-00 3.2.3.3 A11 Functional Managers 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 perforned the original review and approval of the document; to ensure that approved changes are promptly transmitted for incorporation into documents; to ensure that obsolete or superseded documents are eliminated from use, 3.3 Quality Assurance Records 3.3.1 Policy Quality Assurance records for itens and activities covered under the scope of the GPUN Quality Assurance Program shall be identified, reviewed, retained, and retrievable. These re-quirements are imposed on all organizations performing activi-ties Important to Safety. Quality Assurance record systems shall be described and controlled by approved written procedures.and instructions.

i 3.3.2 Requirenents l The procedures established for the generation, collection, storage, maintenance, and retrieval of Quality Assurance rec- I ords shall neet the following ninimum requirenents:

a. Design specifications, procurement documents, and GPUN .

l procedures shall specify the records to be generated, supplied and maintained by or for GPUN including reten-tion times. Typical records to be specified include {

operating logs, naintenance and nodification procedures and related inspection results, reportable occurrences, inspection and verification procedures (excluding com-pleted checklists when results are docunented in a separate report), results of reviews, inspections, tests, audits, and naterial analysis; qualification of 5

- personnel,lculations, such as ca design verifications, drawings, procedures, and eq Z specifications, procurement documents, calibration 5

procedures and reports; nonconfornance reports; corrective action reports; and other records required by 2 Technical Specifications.

3

$ b. Sufficient records and documentation shall be maintained

! to provide evidence of the quality of items or activities s Important tc Safety. Inspection and test records shall 5 contain the fo:10 wing where applicable:

A000105011 82 46.0

Number

@ Nuclear RECOVERY QU U TY ASSURANCE i

g, Revision No 1 3.0 CONTROL OF DOCUt1ENTS AND RECORDS 4-00

1. A description of the type of observation.

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

3. Identification of any conditions adverse to quality.

4. Inspector or data recorder identification.

5. Evidence as to the acceptability of the results.

6. Action taken to resolve any discrepancies noted.

c. Documented and approved measures shall be established for complying with the requirenents of codes, standards, and procurement documents regarding record transmittal, retention, and maintenance subsequent to completion of work,

d. Record storage facilities shall be established and utilized to prevent destruction of quality records by !

fire, flooding, theft and deterioration by environmental '

conditions such as temperature or humidity in compliance with the standards, codes and regulatory guides endorsed in Appendix C of this Plan.

e. All records shall be legible and those required to be !

stored in the dupifcate storage facility must be capable l of being reproduced on commonly found copying equipment.

3.3.3 Responsibilities 1

3 Director - Nuclear Assurance ;

I .3.3.1 l The Ofrector - Nuclear Assurance is responsible via the i Director - Quality Assurance, for- l

a. Reviewing procedures for GPUN departments who perform !

activities related to the maintenance of Qua11ty Assurance records.

i b. Establishing a program for the identification, storage, retrieval, and maintenance of Quality Assurance records

generated by QAD, until they are turned over for storage.

=

3 c. Performing planned and periodic audits to verify adequacy and implementation of Quality Assurance records

! requirenents by both GPUN internal organizations and 3

external organizations.

i l b l A0001050 t t 82 47.0

gggy RECOVERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02:

Title Revision No.

3.0 CONTROL OF DOCUMENTS AND RECORDS 4-00 l

3.3.3.2 GPUN Division Directors and the Office of the Director THI-2 i Each Division Director and the Office of the Director - THI-2 is responsible for:

a. The initiation, collection, maintenance, and storage of records in accordance with approved written procedures which conforn to the requirements and policy of this section untf1 such time as they are transferred to the Director - Administration for storage. l

b. Providing procedures which ensure the maintenance of records sufficient to furnish objective evidence that activities affecting qua11ty are in compliance with the standards, codes and regulatory guides endorsed by this Plan.

3.3.3.3 Director - Administration The Director - Administration is responsible, via: .

The Manager Information Management Centers, for:

a. The collection, maintenance, and storage of records in i accordance with approved written procedures and instruc-l tions which conform to the requirements and policy of j this section. I i

b. Providing procedures which ensure the naintenance of rec- l ords sufficient to furnish objective evidence that acti-vities affecting quality are in comp 11ance with the stan-dards, codes and regulatory guides endorsed by this Plan. - I I c. Establishing and implementing the GPUN Records Contro1 i System. l 3.3.3.4 External Organizations Records generated by contractors shall be controlled according to contractor procedures ur.tf1 such time as they are turned over to GPUN for review, acceptance, and transmittal to the 5 pernanent records file. Purchased equipment records shall be retained by the vendor until the equipment is released ~for shipment at which time the records required by procurement i g documents are to be submitted to GPUN. '

5 E

, T b

2 l A00010$011 92 48.0

Number

@ Nuclear atC0nav ygn ASSURANCE 1000-RN-7200.02 Title Revision No.

1 0 enNTRnf nF nnCHMENTR AND QrrnQnS 4-00 When required by the procurement documents, contractors and vendors shall establish procedures to control Quality Assurance records. Implementation of these procedures shall be assured by performance of source surveillance, monitoring and audits performed by QAD.

Records to be silbmitted with the shipment or retained by the vendor will be specifically identified in procurement docu-ments. These records will be reviewed as necessary by QAD and/or Engineering to provide the required degree of confidence in the adequacy of compliance of the vendor with the require-ments of this section.

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l A00010$oIi 82 49.0

Number N a h r" RECOVERY Q TY ASSURANCE 1000-PLN-7200.02 i Title Revision No. i 4.0 CESIGN CONTROL 4-00 4.1 Po11cy fieasures shall be established and documented to assure that the applicable specified design requirenents, such as design bases, regulatory requirements, codes and standards are correctly translated into specifications, drawings, procedures or instructicns. These neasures shall include provisions to assure that appropriate quality standards are specified and included or referenced in design documents for design of systems and structures; external design of systems and structures; and assessnent of damage.

4.2 Requirements Design control measures require that:

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

4.2.2 The design bases, safety analysis, design regulations, codes and standards and Plant Technical Specifications including all anendments will be reviewed in the design process. They will be adhered to unless specific NRC approval of the changes is obtained.

4.2.3 The naterials, parts and processes selected by design are reviewed to assure that they are suitable for the intended application, including compatibility of naterials, accessibility for inservice inspection, naintenance and repair, associated conputer programs, and auality -

standards. The review will also evaluate suitability with regard to ,

-human factors which nay effect safe operation and the suitability of I comercial grade naterials, parts and equipment to; the application. l l

4.2.4 Internal and external design interface controls, procedures, and lines of connunication anong participating design organizations and across technical disciplines are estab11shed and described for the preparation, review, approval, release, distribution, and revision of j documents involving design interfaces.

E 4.2.5 Errors and deficiencies in approved design documents, including 2 design nethods (such as computer codes) that could adversely i

E R

E

-5 5

l AOOO105011 82 50.0

f gggy REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 4.0 DESIGN CONTROL 1 4-00 affect itens and activities Inportant to Safety shall be docu-nented, and action shall be taken to assure that these errors or deficiencies are corrected. In addition, any errors or deficiencies resulting from the application or use of the design documents shall be identified and corrected.

4.2.6 Deviations in specified quality standards shall be identified and procedures shall be established to assure their resolution and control.

4.2.7 Review of standard "off the shelf" connercial materials, parts, and equipment for suitability of application to structures, systens, and components Important to Safety shall be conducted prior to selection.

4.2.8 Design verification nethods (design review, alternate calculations or qualification testing) shall be established.

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

l a. The verifier is qualified and is not directly responsible for the design.

b. Verification shall be complete prior to turnover of the component or systen to Operations.

c. Design documents subject to procedural control include, but are not limited to, specifications, calculations, computer programs, system design descriptions and drawings, including flow diagrams, piping and instrument l diagrans, systen diagrams, facility drawings showing .

equipment locations and site arrangenents. j

d. The responsibilities of the verifier, the areas and features to be verified, and the extent of documentation shall be identified in procedures.

4.2.10 When verifications are to be accomplished by test:

5 a. Prototype, component or feature testing shall be performed E prior to installation of ecuipment, or prior to the point when the installation woulc becone irreversible.

R b. Verification by test shall be perforned under conditions

that simulate the nost adverse design conditions as g determined by analysis.

1 AAOO1050tt 82 51.0

-J gggy RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 ,

Title Revision No r 4.0 DESIGN CONTROL 4-00 4.2.11 Procedures shall be established to assure that conputer codes, and changes thereto, are verified, certified and controlled to prevent unauthorized changes.

4.2.12 Design and specification changes, including field changes, will be subject to design control neasures connensurate with those applied to the most recently verified design. Design changes shall be reviewed and approved by the organization responsible for the original design or by another organization with compar-able expertise designated to review and approve changes.

4.2.13 fieasures shall be provided to assure that responsible plant personnel are nade aware of design changes and/or nodifications, which may affect the performance of their duties.

4.2.14 Design activities directed toward the assessment of the damage to TMI Unit 2 which include Important to Safety activities will be controlled in the same manner as other design activities within the scope of this Plan. However, specialized reviews will be used as cor.ditions warrant to allow for necessary flex-ibility in design control. Advance approval by the Director - !

Quality Assurance is required where full compliance with the design control progran is not feasible. }

I 4.2.15 Methods shall be employed to ensure that adequate precautions or '

evaluations are in place during recovery activities (including the installation and/or removal of hardware) to preclude damaging, impeding operational movements, or in any way adversely inpacting the ability of ITS itens or items required by the Technical Specifications to maintain the plant in a safe condition. l 4.3 Responsibilities l 4.3.1 Office of the Director - TMI-2 4.3.1.1 The Office of the Director - TMI-2 is responsible through.the Site Operations Director for the developnent and implementation of design control neasures regarding naintenance (and plant engineering activities). .

2 4.3.1.2 The Office of the Director - f*0 ! is responsthie through the

~

Manager - Recovery Prog 9p cv 1e development and inplement-g ation of the design conti W nwces utilized by the engineering

departments and for the coordination and direction of engineer-ing tasks which are outside the scope of Plant Engineering. To g fulfill these responsibilities, the Manager - Recovery Pragrans will

g A OOO 10$011 82 52.0

" *" b * '

gggy RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-720 Title Revision No 4.0 DESIGN CONTROL 4-00 i

I

a. Control and coordinate the activities of A/E's and those i

' contractors with design responsibility. j i

b. Assure the review and approval of baseline design l documents such as design criteria, flow diagrams, system l descriptions, arrangement drawings, one-line diagrams and logic diagrams, as appropriate. l' Note: This design review does not replace or elininate the need for design verification by the organiza- l tion who perforned the design. ,

c. Ensure Quality Assurance review and concurrence of design !

criteria docunents and specifications.

d. Provide technical administration of nuclear fuel-related engineering activities.

4.3.1.3 The Office of the Director - TMI-2 through the Technical Plan- ,

ning Director is responsible for providing conceptual and !

analytical engineering service to other engineering groups as j

, required. !

4.3.1.4 The Office of the Director - TitI-2 through the Manager - !

Recovery Programs is responsible for providing detailed design ;

! and drafting services. He is also responsible for the prepa- l l ration and maintenance of the Quality Classification List (QCL).

l 4.3.2 Director - Nuclear Assurance

The Director - Nuclear Assurance is responsible through the l Director Quality Assurance for providing Quality Assurance i review and acceptance or concurrence with design and engineer- >

ing docunents relating to itens and activities Inportant to ;'

Safety to assure that approoriate quality.requirenents have been ,

included. In addition, Quality Assurance will perforn planned !

and periodic audits of responsible design orqanizations to !

verify impienentation of design control measures. l l

4.3.3 Other Design Organizations i

= l

All design organizations performing design activities for TMI -

shall have quality programs which include design control pro-j visions equivalent to those provided in the THI Quality Assur-

ance Program. l

-e '

4I h

A000105011 32 53.0

Number gggy REC 0VERY Q TY ASSURANCE Title Revision No 5.0 PROCUREMENT AND MATERIAL CONTROL 4-00 5.1 Control of Procurement 5.1.1 Policy 5.1.1.1 Procurement of material, equipment and services which are con-sidered Important to Safety shall be performed in accordance with written policies, procedures and instructions which shall establish methods for preparation, review, approval, and con-trol of procurement documents and shall provide measures to comply with applicable regulatory requirements. Appropriate measures shall be established to evaluate procurement sources, monitor the activities of consultants, vendors and contractors, and confirm that purchased items and services conform to pro-curement document requirements. The programs of all partici-pants shall be in accordance with the applicable requirements of the GPUN Recovery Quality Assurance Program.

5.1.1.2 The general and specific requirements for the Quality Assurance Program of all vendors and contractors, including their l subvendors and subcontractors supplying material, equipment, or !

services which are considered Important to Safety, shall be t delineated by procurement documents. These quality program requirements shall be commensurate with the degree of com- ;

plexity, the uniqueness, and the importance to safety of the items and services being performed. ,

5.1.1.3 Quality Assurance measures shall apply to the procurement of materials including new and spare parts, replacement parts, l i

commercial grade items and consumables. Procurement of spare or replacement parts for structures, systems, and components {

shall be subject to current Quality Assurance Program controls I and to codes, standards, and technical requirements equal to, or better than, original technical requirements, as superseded by regulatory commitments, or in accordance with an approved engineering document, j t

5.1.2 Reauirements !

5.1.2.1 Procurement Documents i The requirements for the preparation, review, approval and

control of procurement documents shall be delineated in T. detailed procedures. These procedures shall delineate j requirements to assure that procurement documents:

I 2

A000105011 - 82 54.0

Number (UCl88r REC 0VERY QUALITY ASSURANCE ptan icoo_PLN-7200.02 t

Title Revision No.

5.0 PROCUREliENT AND ftATERIAL CONTROL 4-00

a. Specify the technical and quality assurance requirements

' commensurate with the requirements of this Plan,

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

c. Specify or reference design basis technical require-ments, including applicable regulatory requirements, material, and component identification requirements, drawings, specifications, codes and standards, test, calibration, and inspection requirements, and special process instructions.

d. Identify the documentation to be prepared,~ maintained, and submitted for review, approval and record informa-tion as applicable.

e. Include an identification of those itens and activities Important to Safety.

f. Identify those records which vendors or contractors

. shall retain, maintain, and control; and those which vendors or contractors shall deliver prior to use or installation of the item.

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

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

i. Include the provision that suppliers shall refrain fron l implementing procedures which require owner approval prior to obtaining such approval.

j. Require design organizations performing design activi-ties for GPUN to have and implement quality programs

! which include design control provisions equivalent to 5 _those provided in the GPUN Quality Assurance Progran.

ifeasures shall be established for the review, approval, and E release of procurement documents and subsequent revisions. The reviews shall assure the inclusion of the applicable technical, quality, and administrative rec,uirements in procurement docu-

{ ments prior to their use, a

e A000105011 82 55.0

gggy REC 0VERY QUALITY ASSURANCE PLAN l

1000-PLN-7200.0z Title Revision No.

5.0 PROCUREMENT AND MATERIAL CONTROL 4-00 Review of procurement documents shall be documented to provide objective evidence of their approval prior to their release.

5.1.2.2 Oualification and Selection of External Organizations Evaluations of prospective suppliers shall be conducted and documented to demonstrate qualifications based upon one or more of the following criteria:

a. Review of performance histories which provide records of suppliers' previous capability to provide similar pro- '

ducts or services,

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

c. A pre-award survey of the external organization's facilities and Quality Assurance program to determine his capability to supply the items or services that meet ,

the design and quality requirements of the specification.

Procedures shall be established to accomplish the evaluation ,

and selection of external organizations. Contracts or purchase ;

orders for material, equipment or services covered by the scope :

of the Quality Assurance Program shall be awarded either to: I l !

d. External organizations who have been qualified by the '

QAD as having a Quality Assurance program commensurate with the equipment or services to be provided, or l

e. The external organization will be required, by procure- l ment 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 approval of an external organization's quality assurance program is required, it shall be reviewed and approved by GPUN prior to initiation of the activity affected g by their program.

7. In the case of " commercial grade items" the supplier does not

have to be evaluated; however, the procurement documents shall 2 specifically describe the items to be provided to ensure the 2 appropriate quality is maintained.

3 4

AOOO10$011 82 l

56.0

Ne ENuclear g,

RECOVERY QUAUTY ASSURANCE PLAN TOOO-PLN-7200.02, Revision No.

5.0 PROCUREMENT AND MATERIAL CONTROL 4-00 5.1.2.3 Manufacturina Assurance Measures shall be established to provide control of manufac-turing activities of vendors. These methods shall be described in detailed written procedures.

The attributes of the manufacturing assurance program shall include:

a. Provisions for the review and approval of the vendor's drawings, Quality Assurance manual and manufacturing and quality procedures prior to fabrication. When specified in procurement documents vendors may not implement pro-cedures until written notice of GPUN approval is received.

b. Established vendor inspection plans that defineate, as required the hold and/or witness points in the nanufac-turing process for specified review, inspection, veriff-cation and test. .

c. Methods for resolution of nonconformances where the vendor's suggested disposition is "Use-as-is" or '

" Repair". Such nonconformances require aoproval by the l responsible engineer and approval of the responsible l Quality Assurance organization. QAD wf11 also provide !

followup of corrective action implementation.

d. Planned and systenatic audit and surveillance of vendor quality activities. Scope of coverage and frequency ,

shall be determined by the criticality of the furnished -

itens and the evaluated results of vendor qualifica-tions, including pre-award surveys and quality procedure reviews. Revisions to audit and surveillance plans shall be made as warranted by vendor performance.

e. Control of vendor document package including review for completeness and acceptability. Inadequate records which render the quality status of item (s) furnished indeterminate shall be sufficient cause for rejection of 5 the item (s).

7. f. Assessments of vendor control of quality shall be made E

" at a frequency and depth commensurate with the impor-tance, complexity and quantity of the items furnished.

These assessments shall utilize the qualitative and n

S 2

AOOO 105011 82 57.0

nm.,

ENuclear RECOVERY WAUTY ASSURANCE PLAN 1000-PLN-7200.02 f

Title Revision No l 5.0 PROCUREMENT AND MATERIAL CONTROL 4-00 quantitative information provided by vendor noncom-pliance documents; survefilance, inspection and audit reports; and receiving inspection and test records,

g. Material acceptance procedures that assure:

1. The material, component, or equipment is clearly identified and that the identification and ,

quantity correspond to the information on the shipping documents and quality records. l l

2. The item's handling and shipping requirements have

. been met by the vendor and maintained by the carrier.

3. The item's quality record package or compliance certificate is complete and adequate.

4. The material, component or equipment neets the technical requirements specified in the procure- i ment documents, inspection plans, checklists or

. other special engineering documents.

i

5. Itens delivered which are not in conp11ance with requirements are documented in accordance with the nonconformance orocedure, tagged (As item configuration or storage conditions permit.

l Additional administrative controls shall be used if taggin possible)g is not

, and possible.),

prevented fromsegregated (if being inadvertently i issued for installation or use, j 1

l 6. Items accepted and released are identified as to their inspection status prior to forwarding them ,

to 1 controlled storage area or releasing them for installation or further work.

5.1.3 Responsibilities

5.1.3.1 Director - Administration a

$ The Director - Administration is responsible through the

7. Director - Materials Management for the: ;

5 5 a. Administration and operation of contracting, procurement l 7 and warehousing activities associated with the recovery j operation.

A0001050t1 82 58.0

gUOlea7 REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 5.0 PROCUREMENT AND MATERIAL CONTROL 4-00

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

c. Assurance that the . contractual, legal and commercial requirements are incorporated into the procurement docu-ments in a manner which will enable enforcement of the technical and quality requirements,

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

e. Assurance that purchase orders and contracts for Important to Safety items and services are issued to external organizations that have been evaluated and meet the requirements of this QA Plan.

5.1.3.2 Director - Nuclear Assurance i t

The Dirutor - Nuclear Assurance is responsible through the Director - Quality Assurance to:

a. Assure that QAD procedures for the control of purchased !

equipment, material and services are established, I approved, implemented and effective.

b. Approve all GPUN procedures necessary for the control of purchased equipment, material, and services within the scope of this Quality Assurance Program.

c. Approve supplier Quality Assurance Programs to the j extent required in the procurement documents. I i

d. Review and accept supplier record packages. I

e. Establish and implement an adequate program of source inspection, surveillance and receipt inspection to assure supplier compliance with contract requirements.

5 f. Review and concur with the adequacy of quality require-ments to determine that they are correctly stated,

inspectable and controllable, that there are adequate

acceptance / rejection criteria and that the procurement S documents have been processed in accordance with 2 established requirements.

3 l g. Establish and maintain a Supplier Quality Classification

, 8 List (SQCL) which documents the results of the evalua-

! s tions of prospective suppliers.

8 l A00010W M 82 59.0

Number ENuclear RECO N FASSURANCE 000-PLN-M00.02 Title Revision No 5.0 PROCUREMENT AND MATERIAL CONTROL 4-00 5.2 Identification and Control of ifaterials, Parts and Components 5.2.1 Policy Measures shall be estab11shed to provide for the identification and control of materials, parts and components Important to Safety. These neasures shall assure that incorrect or noncon-forming itens are identified and controlled in order to prevent their inadvertent installation or use. Where required by design documents, the system established shall provide trace-ability of components from the receipt of material through fabrication, 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 nanufacture, installation, or erection. Identification requirements shall be specified in the applicable design and procurement documents.

5.2.2 Requirements 5.2.2.1 Identification and traceability requirenents shall be included in specifications and drawings.

5.2.2.2 ffaterial, parts, and conponents, including partially fabricated subassemblies or subdivided materials shall be identified to preclude the use of incorrect or defec-l tive items.

l 5.2.2.3 Materials and parts Inportant to Safety shall be identi-fied so that they can be traced to the appropriate docu-mentation, including, but not ifmited to: . i i

a. Specifications l i

b. Drawings (including as-builts)

c. Procurement Documents

d. Physical and Chemical Test Reports 5 e. Nonconformance Reports

}= f. Inspection Reports and Checklists l g. Storage Maintenance Instructions A000105011 82 60.0

Number ENuclear REC 0vERY QUAlfTY ASSURANCE PLAN 1000-PLN-7200.02; Revision No

\

l 5.0 PROCUREMENT AND ftATERIAL CONTROL 4-00 ,

h. NDE Reports

1. Vendor Certificates of Compliance 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 identified.

5.2.2.5 Correct identification of naterials, parts and com-ponents shall be verified prior to release for fabrica-tion, shipping, installation, and testing.

5.2.2.6 Where physical identification is either inpractical or insufficient, physical separation, procedural control, or other approved means may be employed.

5.2.2.7 A receipt inspection at the site veriffes that identifi-cation for received items is complete and accompanied by appropriate documentation. l 5.2.3 Responsibf11 ties I l

5.2.3.1 Responsible Departnent fianager {

i Each Department Manager is responsible for ensuring that pro-curement documents issued by their departments contain !

l appropriate requirenents for the identification and control of i i

' materials, parts, or conponents and that only materials, parts '

or components which have been accepted are used.

l 5.2.3.2 Director - Nuclear Assurance l The Director - Nuclear Assurance is responsible through the j Director - Qua11ty Assurance for: '

a. Quality Assurance review and concurrence of procedures for naintaining identification in accordance with the ,

requirenents of this section. I,

b. Verification of identification during receipt inspection. l

[

c. tionitoring and conducting inspections, survefilances and l i

audits to verify conformance to the requirements of this j section.

E l !!

4 AOO0 f 050 t t 82 61.0

Number

$NUCIear RECOVERY QllALITY ASSURANCE PLAN 1000-PLN-7200.02, g Revision No l 6.0 CONTROL OF STATION ACTIVITIES 4-00 6.1 Policy 6.1.1 Station activities considered important to safety shall be conducted in accordance with the requirements of this Plan.

These activities include but are not ifmited to design changes, procurement, fabrication, handling, shipping, storage, cleaning, erecting, installation, inspection, testing, opera- '

tion, maintenance, repair, defueling, decontamination, damage assessment and modification.

6.1.2 The Quality Assurance requirements for station activities are contained in this Plan and include compliance with appifcable USNRC Regulatory Guides and ANSI Standards indicated in Appendix C. These requirements shall be implemented in appropriate procedures governing station activities. The requirenents of this Plan apply to all organizations or positions performing functions which affect the quality of structures, systens, components, or activities inportant to safety.

6.1.3 The following subsections discuss typical activities which are representative of the broad scope of administrative controls ,

i and quality assurance requirenents that are applicable to station activities. The organizational structures and func- l tional responsibilities governing station activities shall be i structured so that attainment of the objectives of this Plan is j accomplished by those who have been assigned or delegated responsibility for performing the work; and verification of conformance to established requirenents is accomplished by '

qualified personnel who do not have direct responsibility for I perforning or directly supervising the work. Quality Assurance !

Department activities such as inspection, monitoring, (

surveillance, reviews and audits are performed to independently i verify conformance to this Plan, to app 11 cable station admin- t istration controls, and to applicable regulatory and licensing l commitnents. These independent verifications are applied to !

station activities on a graded approach to the extent necessary (

to provide adecuate confidence that structures, systems, i components, anc personnel perform satisfactorily to naintain '

5 the safety of the station. Station work functions such as -

routine and abnormal. operations, naintenance, repair or rework, 7.

Technical Specification compliance, fuel handling, radwaste 5

= handling, radiation protection, chenical analysis, housekeepin 2 and cleanliness, fire protection, security, training, environ g nental requirements, health physics, and other activities con-j sidered Important to Safety which are discussed in this Plan l

AOOO 105011 8 2 62.0

ENuclear Number RECOVERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02, Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 are controlled to an extent consistent with their importanc? to safety.

6.2 Control of Inspections 6.2.1 Requirements 6.2.1.1 A program for performance of inspections of Inportant to Safety activities shall be estab11shed and executed by, or for, the l organization performing the activity to verify conformance to ('

the documented instructions, procedures, and drawings for accomplishing the activity. Design specifications, drawings, procedures, or instructions shall include the necessary requirements for performance of inspections. These require-nents include acceptance criteria and reference to codes, standards, and regulatory documents. These requirements shall be further translated into procedures, instructions, or check-lists which shall contain, as required, the following:

a. Identification of characteristics and activities to be !

, inspected.

b. fiethods to be used including necessary neasuring and test equipment and the accuracy requirements. !

c. Identification of organization responsible for l performing the inspection.

d. Acceptance and rejec' tion criteria.

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

f. Documentation of inspection results including identiff-cation of the individual performing the inspection. ;

i i

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

_ kept current and documented.

I'

6.2.1.3 Individuals performing inspections shall be other than those

~ who oerforned or directly supervised the activity being fnspected and shall not report directly to the immediate super-3

~ visors who are responsible for the work activity being 3 inspected. If the individuals performing the inspections are g not part of the responsible quality Assurance organization, the

_(

A00010$011 82 63.0

Number ENuclear g

aEC0vERY QUAL 1TY ASSURANCE PLAN 1000-PLN-7200.02 '

Revision No l

6.0 CONTROL OF STATION ACTIVITIES 4-00 procedures and personnel qualification criteria shall be re-viewed and concurred with by the responsible Quality Assurance l organization prior to the initiation of the activity.

Inspections may be conducted by second line supervisory personnel or by other qualified personnel not assigned first line superviscry responsibility for the conduct of work. These activities, i.e., those performed by individuals not assigned first line supervisory responsibility, are not intended to dilute or replace the clear responsibility of first line super-visors for the quality of work performed under their super-vision. When inspections associated with normal operations of i the plant (such as routine maintenance, surveillance and tests) are performed by individuals other than those who perforned 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 can be demonstrated through a functional test when the activity involves breaching a .

pressure retaining iten.

l

b. The qualification criteria for the personnel are !

reviewed and found acceptable by the Quality Assurance i organization prior to initiating the inspection. l 6.2.1.4 Work authorizing docunents used to inplement work in the field considered Important to Safety shall be reviewed and concurred j with by Quality Assurance Department personnel to determine the need for:

a. Inspection i

[,

b. Identification of organization, perfarning the inspection i i

c. Identification of witness and hold points ,

, d. Documenting results 6.2.1.5 When QA Hold Points have been established, either con-tractually, by procurement, or internally by plant procedures, i work may not proceed beyond the Hold Point until either inspec- l tion is performed or waived by the responsible Quality

- Assurance organization.

=

5 6.2.1.6 Inspections, of nodifications, repairs, and replacements shall be by the same nethod and to the same criteria as the original or by an approved, documented, engineering and QA alternate.

9 e

A000105011 82 64.0

" *" D *'

ENuclear aEC0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.0 l

Title Revision No i 6.0 CONTROL OF STATION ACTIVITIES 4-00 l Where verification of inspection is being perforned on previously accepted lots, sampling inspection shall be I representative and only to the extent necessary to assure adequacy of control. The sampling plan shall be determined by Qua11ty Assurance. Inspection personnel shall be provided with suitable equipment and tools, which are calibrated as necessary, and controlled to assure that accuracy requirenents are satisfied and that inspections are complete.

6.2.1.7 Inspection data and results shall be evaluated by designated i I

personnel to assure that the objectives have been met and that i items requiring action or follow-up are identified and I documented.

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

6.2.2 Responsibilities l

6.2.2.1 Office of the Director - TMI-2 '

't

The Office of the Director - TitI-2 through the Site Operations l Director and the Manager Recovery Programs is responsible for ensuring that requirenents for inspections, are included in design specifications, drawings, procedures and instructions '

and that these requirenents include acceptance criteria and, as app 11 cable, references to codes, standards and regulatory ;

documents.

6.2.2.2 Director - Nuclear Assurance ,

The Director - Nuclear Assurance, through the Director - ,

l Quality Assurance, is responsible for:

a. Assuring that inspectors are qualified in accordance -

with appifcable codes, standards, and GPUN training programs.

b. Reviewing and concurring with procedures and work !

authorizing documents for inclusion of inspection and !

5 test requirenents and QA Hold Points.

l

c. Reviewing and concurring with the personnel qualifica- l E tion criteria of individuals performing inspections, l

_" including those who are not part of the QA organization. l l d. Identification of inspection plans to be used for verification of~ inspections on previously accepted lots.

s' A000105011 92 65.0

Number ENuclear REC 0VERY q TY ASSURANCE 1000-PLN-7200.02.

Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 l

l S.2.2.3 Responsible Department fianaaer Each responsible Department fianager performing work requiring inspections is responsible for:

(a) Notifying the QA Department of the work being performed (b) Obtaining QA concurrence with the procedure and/or work authorizing document.

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

(d) Assuring that all information, records or copies of records associated with their work are made available to QA personnel.

Each responsible Department Manager perforning inspections, is responsible for:

, (e) Assuring that the personnel performing the inspection is qualified in accordance with applicable codes, standards, training programs and procedures. j (f) Assuring that the results of all inspections are ;

properly documented and the results are evaluated by l designated personnel. j 6.3 OA fionitoring 6.3.1 Requirements I f 6.3.1.1 A program for QA fionitoring of activities affectinq Important I to Safety itens or processes shall be estab11shed and executed i by the QA Department, i 6.3.1.2 fionitoring is used to establish adequate confidence levels that l Important to Safety activities are being performed in accordance with the QA Program requirenents and plant adminis-

,_ trative controls, fionitoring will be perforned on a graded 5 approach and the degree of monitoring perforned shall be based

~

typically upon the status and safety inportance of activities, extent of previous experience, thoroughness of overall

_3 coverage, uniqueness of testing or operating activities and 5 trending data, i

1 2

AGOOlOSO 11 H2 66.0

Number ENuclear REC 0VERY Q TY ASSURAWCE 1000-PLN-7200.02!

l Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 f

6.3.1.3 Monitors shall be qualified in accordance with a documented QA l Department procedure that ensures that Monitors are knowledge-able in the activities they are monitoring to the extent that l they can readily verify compliance of the activity being performed.

6.3.1.4 Monitoring reports shall contain as a minimum the following:

a. Identification of activity being monitored including I specific reference to the program or procedural require- l ments governing the activity. !

b. Indication of compliance,

c. Identification of Monitor

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

e. Identification of each nonconformance document when such I nonconfornances exist and are identified as a result of {

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

6.3.2 Responsibilities 6.3.2.1 Director - Nuclear Assurance l The Director - Nuclear Assurance through the Director - Quality l

Assurance, is responsible for:

i

a. Establishing the requirements for QA nonitoring of activities affecting Important to Safety materials, '

parts, components and practices. !

1

b. Assuring that QA Monitors are adequately trained and are ,

_ qualified to perforn their duties. l E t E c. Assuring that reports of the monitoring activities have !

_- sufficient details and provide adequate confirmation of l j the monitoring program.

l 2 !

! i j

l l 2

i

.s A000105011 92 67.0

NUChr REC 0VERY QUALITY ASSURANCE pt43 jooo_PLN-7200.02 Tme Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 6.4 Control of Special Processes 6.4.1 Requirements 6.4.1.1 Special processes are those that require interin in process controis in addition to final inspection to assure quality including, but not limited to, such processes as welding, heat treating, chenical cleaning, and nondestructive examination.

6.4.1.2 lieasures shall be es;ablished and documented to assure that special processes are accomplished under controlled conditions in accordance with applicable codes, standards, applications criteria, and other pecial requirements including the use of qualified personnel and procedures.

6.4.1.3 Procedures for special processes shall be established to meet the requirements, of applicable codes and standards or to neet the requirements of special process specifications which may be produced by or for GPON. These procedures shall provide for ,

recording evidence of acceptable completion of special pro- !

cesses. Procedures and instructions for the control of special l processes shall be reviewed and approved by qualified personnel. Procedures, equipment, and personnel perforning !

special processes shall be qualified in accordance with !

applicable codes, standards, and specifications. Organiza- !

I tional responsibilities shall be delineated for the qualifica- l l tion of special processes, equipnent and personnel. Qualifica- l' tion records of personnel, equipment, and procedures associated with special processes shalT be established, maintained and kept current. For special processes not covered by the .

existing codes or standards, or when item quality recuirements I

! exceed the requirements of established codes or stancards, the l necessary qualifications of personnel, procedures and equipment !

I shall be defined in the procedure. !

6.4.2 Responsibilities 6.4.2.1 Responsible Department fianager l

Each responsible Department Director /lianager perforning special 5 processes is responsible for:

7. a. Assuring that the established progran requirements for i

" controlling and accomplishing special processes are implemented.

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

}

i 2 AOOOtOSOl1 92 68.0

Number ENuclear RECOVERY Q L TY ASSURANCE Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00

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

6.5 Test Contro1 6.5.1 Requirements I

6.5.1.1 A documented test progran shall be established to assure that all testing required to demonstrate that the structure, systen or component considered Important to Safety will perform satisfactorily in service. The tests shall be performed in accordance with written, approved, and controlled test pro-cedures which incorporate or reference the requirements and acceptance standards contained in the applicable design docu-nents. The extent of testing shall be based on the complexity of the nodification, replacement, or repair. Testing, includ-ing proof tests prior to installation, hydrotesting, and preoperational tests, necessary to demonstrate that structures, systems and components will perform satisfactorily in service, i shall be accomp11shed in accordance with written approved procedures. These procedures shall be based on requirements and acceptance limits contained in applicable design and t procurement documents. These test procedures or instructions 4 shall provide for the following as required: j

a. A description of the test objective. j

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

interpretation. I i

c. Test prerequisites such as calibrated instrumentation, '

adequate test equipment and instrumentation including i accuracy requirements, completeness of item to be j tested, suitable and controlled environnental con- I

, ditions, and trained, quaiffied and licensed or certi- !

fied personnel, f

d. Provisions for data collection and storage.

E e. Acceptance and rejection criteria as specified in design

and procurement documents.

E s

S 3

A000105011 8 2 69.0

"e-ee, ENuclear arc 0vrav auALITv ASSuaAuce PLAN 1000-PLN-7200.02

\

l Title Revision No J.0 CONTROL OF STATION ACTIVITIES 4-00 ,

f. Methods of documenting or recording test data and

' results, in sufficient detail to prevent misinterpretation.

g. Mandatory hold or witness points for inspection by GPUN Quality Assurance and/or other designated personnel, Provisions for control of jumpers, lifted leads and

~

h.

jurisdictional or safety tags.

I

1. Provisions for returning a system to normal configura-tion upon completion of the test, including verification.

J. Provisions for assuring test prerequisites have been net.

6.5.1.2 Test results shall be documented, evaluated, and their accept-ability determined by a responsible individual or group.

6.5.1.3 The test program shall cover all required tests including: ,

a. Preoperational tests of components or systems to demon-strate that performance is in accordance with the design intent. ,

i i

b. Tests during initial operation to demonstrate systen !

perfornance (that could not be tested prior to opera- !

tion) to confirn compliance to design criteria, j

c. Tests during the operational phase to provide assurance l that failures or substandard performance do not remain i undetected and that the required reifability of systems !

Inportant to Safety is maintained. j

d. Tests during activities associated with plant nain- I tenance, during the operational phase and to demonstrate i satisfactory performance following plant naintenance or ;

procedural changes. !

l 6.5.1.4 Tests performed following plant repairs or replacements shall l

_ be conducted in accordance with the original design and testing

requirenents or engineering approved, documented alternatives.

E Testing shall be sufficient to confirm that the changes i' reasonably produce expected results and that the change does j not reduce safety of operations.

l U

l 3

2 AOOOtO50tt 82 70.0

Number ENuclear rec 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No.

6.0 CONTROL OF STATION ACTIVITIES 4-00 l

6.5.2 Responsibilities 6.5.2.1 Office of the Director - THI-2 The Office of the Director - TMI-2 is responsible for assuring that testing is performed in accordance with the requirements of this Plan including, as a minimum, the following:

a. Assuring that testing is perforneo in accordance with written, approved and controlled procedures,

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

c. Assuring that identified discrepancies are addressed, resolved and reported as required by the License and Technical Specifications of the Unit.

d. Directing testing and ensuring that operations personne1

, and other supporting personnel have the required special training and skills.

I

e. Coordinating technical assistance cf testing. l t

f. Assuring that all construction testing performed as part l of maintenance and modifications, including i hydrotesting, is performed, documented and the results I acceptable prior to t'urnover.

fl 6.6 Control of Measuring and Test Equipment !

l 6.6.1 Requirements

! l 6.6.1.1 Measures shall be established to assure that tools, gauges, I instruments, and other neasuring and testing devices used in !

activities affecting the function or quality of structures, !

systems, and components, including operations, maintenance, '

modifications, plant chemistry and radiological and environ-mental control activities, covered under the scope of the QA 5 Program be properly controlled and calibrated or adjusted at

specified periods to. maintain accuracy within specified 3

11mits. Additional neasures shall be established to ensure i 5 that the range, type and accuracy of the measuring and test j, equipnent conforms to the specified requirenents.

j, '

3 k

2 A000tO50tt 82 71.0

l Number gggy RECOVERY QUALETY ASSURANCE PLAN 1000-PLN-7200.02 1 l

Title Revision No j4 6.0 CONTROL OF STATION ACTIVITIES 4-00 j i

I 6.6.1.2 Requirements for each control progran shall include inspection and verification of accuracy upon receipt of equipment, identi- l' fication of all gauges and instruments, calibration and }

scheduled recall for calibration and traceability to an accepted Standard. These activities shall be subject to QAD monitoring and auditing. Procedures shall be established to implement the following requirements:

a. Establish the calibration technique and frequency l requirements, naintenance requirements , and controls l for all measuring and test equipment which are used in the neasurement, inspection, and monitoring of con- I ponents, systems, and structures covered under the scope ;

of the Quality Assurance Program (instruments, tools, gauges, fixtures, reference and transfer standards, and nondestructive exanination equipment),

b. The identification.of measuring and test equipment traceable to the calibration test data.

c. Installed operations measuring and test equipment {

requiring calibration shall be labeled, tagged or i otherwise controlled in accordance with written, ;'

approved procedures to assure that approved calibration intervals are not exceeded. Portable measuring and test equipment may be similarly controlled; but shall, as a '

minimun, be clearly labeled to indicate the date on which the current calibration expires. fteasuring and l test equipment that has exceeded the approved calibra- l tion interval shall not be used for measurements or ;

tests until recalibrated.

l d. Establish calibration frequency for measuring and test !

equipment based on required accuracy, purpose, degree of l usage, stabi11ty characteristics, and/ or any other j condition which may affect the measurement. A calibra-tion recall systen shall be impienented to assure l recalibration within the required period for each piece ]

of measuring and test equipnent covered under the scope !

of this progran. l 2 l

e. Establish nethods for deternining the validity of a previous inspections performed when the measuring and 5 test equipment is found to be out of calibration.

E, Inspections or tests are repeated on itens determined to I

be suspect. Such determination is to be dccunented in I Q

3 AOOr)1OSO 11 82 72.0 t

Number Nuclear RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 i Title Revision No.

6.0 CONTROL OF STATION ACTIVITIES 4-00 suitable forn. If any calibration, testing or neasuring 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 instrunents and gages (flowmeters, pressure gauges, level indicators, etc.) shall have been calibrated against working standards with accuracies at least four (4) times greater than that of the equipment being cali-brated. 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 (4) times greater than that of the working standards.

When the above requirenents cannot be met, the standards ,

used shall have a precision and repeatability that i assures the equipment being calibrated will be within l the required tolerance. The basis of acceptance will be i documented and authorized by the supervisor of the !

calibrating organization. !

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

f f

h. Utilization of reference and transfer standards trace- !

able to nationally recognized standards. Where national I standards do not exist, provisions shall be established '

to document the basis for the calibration. l

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

f 6.6.2 Responsibilities 6.5.2.1 Responsible Departnent Manager 4

I

[ Each Department Manager utilizing tools, gauges, instruments !

7. and other measuring and testing devices in activities affecting l

the function or quality of structures, systens, components and 2j activities Inportant to Safety shall assure that the equipment

is controlled in accordance with an approved calibration con-ll trol program which conplies with the requirenents of this Plan.

3 AOOOt0$0It 02 73.0

Nuclear REC 0VERY QUAlfTY ASSURANCE PLAN 1000-PLN-7200.02 l

j Title Revision No -

f 6.0 CONTROL CF STATION ACTIVITIES 4-00 l 6.7 Handling, Storace and Shipping 6.7.1 Requirenents 6.7.1.1 Measures shall be established and documented to control hand 11ng, storage, and shipping, including cleaning, packaging, and preservation of itens Important to Safety in accordance l with established instructions, procedures, and drawings to prevent damage, deterioration or loss. The requirenents for handling, storage, packaging and shipping of radioactive wastes i are contained in Section 7.0 of this Plan.

6.7.1.2 Procedures shall be established to control the cleaning, handling, storage, packaging, and shipping of materials, con-ponents, systems in accordance with design and procurement requirements to preclude danage loss or deterioration by environmental conditions such as temperature or humidity.

These procedures shall be implemented by suitably trained i individuals. The procedures shall include but not be limited f to, the following:

a. Packaging and preservation procedures to provide i assurance of adequate protection against corrosion. l contamination physical danage or any effect which would '

lowerthequalityoftheitemsorcausedeterioration during shipping, handling or storage. Special protec- ,

I tive environments, special coverings, inert gas atmos-I pheres, moisture contents, and temperature controls ;

shall be specified as required and their existence !

verified and documented. i I

l b. Cleaning methods to provide assurance that necessary

! cleaning operations are carried out prior to packaging, ,

I storage or installation. The level of cleanliness !

required, and verification and documentation require- l nents shall be specified in the procedures. !

I

c. Detaffed handling nethods for all items that require special handling. Special handling tools and equipment ,

shall be provided and controlled to ensure safe and !

2 adequate handling. These tools and equipment shall be

naintained, inspected and tested in accordance with l

written procedures at established intervals to ensure

~; their reliability and availability for use.

5 i lE '

l ;s I 2 1

1 ?

2 AGOO t O*30 t I @ 2 74.0

N e ber ENuclear RECOVERY QUAllTY ASSURANCE.

PLAN 1000-PLN-7200.02 I

Title Revision No. .

6.0 CONTROL OF STATION ACTIVITIES 4-00 i

d. Storage practices to provide for methods of storage and the control of items in storage which will minimize the l possibility of damage or deterioration during storage.

Periodic inspections of storage areas shall be. performed and documented to verify compliance with storage pro-cedures. Release of items for installation shall also be procedurally controlled, f

e. Provisions to assure that proper marking and labeiing of j itens and containers is accomplished to provide identi- I fication and necessary instructions during packaging, shipment and storage. l

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

g. reagents, Provisionsforthestorageofchemicals}swhichwillbe Tubricants and other consumable materia !

u:;ed in conjunction with systems which are Inportant to !

Safety.

h. Provisions for " Limited Life" requirements (including !

" Shelf Life" and " Service Life" for applicable '

naterials).

! Responsibilities l6.7.2 l 6.7.2.1 Responsible Department Managers !

Each Department Director /fianager with responsibility for handling, storage or shipment is responsible for identifying in

, procedures, drawings, spec fications or procurenent docunents I

those handling, storage and shipping requirenents necessary to '

assure compliance with the requirements of this Plan. '

6.7.2.2 Director - Administration The Director - Administration, through the Director - fiaterials tianagement, is responsible for: ;

i

a. Providing the procedures applicable to receiving and l' storage of materials, parts and components. !

j

b. Assuring that the personnel responsible for the handling '

y and storage of materials, parts and components are adequately trained in the performance of their duties .

l:I and that they imp'enent the procedures properly.

l' 3

?

5 A000108;011 92 75.0

Number ENuclear acC0veaY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Revision No Title j 6.0 CONTROL OF STATION ACTIVITIES 4-00

c. Providing adequate facilities for storage of Important

'to Safety materials, components and parts.

6.7.2.3 Office of the Director - TMI-2 The Office of the Director - THI-2 is responsible for assuring that the handling, cleaning, storage and shipment activities, under his direction, is perforned in accordance with the requirements of this Plan. ,

6.8 Inspection, Test, and Operating Status 6.8.1 Requirements 6.8.1.1 Measures shall be established and documented to ensure that the required inspections and tests are performed and that the acceptability of itens with regard to inspection and tests performed is known throughout manufacturing, installation, and operation. Status of itens covered by the scope of this Plan !

shall be controlled in accordance with approved procedures. !

, These procedures shall include the use of appropriate tags, !

l markings, lists, logs, diagrams, electrical and mechanical l

jumpers, or other suitable means, to assure that required I inspections and tests are satisfactorily completed to prevent l l inadvertent bypassing of required inspections and tests and to !

l prevent inadvertent operation. j i

6.8.1.2 The requirements for an acceptable inspection, test and j operating status program for structures, tjstems, and com- '

ponents throughout fabrication, installation, test and opera-tion include:

I i a. Design and quality documents which address the require- i ments for the identification of inspection, test, and ;

operating status of structures, systens and components. j

b. Procedures which ir. elude controls for the application and renoval of inspection and welding stanps, and other

_ status indicators such as tags, jumpers, markings, g labels, and stamps. j

_~

c. Procedures for controlling the bypassing or altering of 5

the sequence of required inspections, tests or other critical operations are procedurally controlled with

concurrence by the Quality Assurance organization. The i

3 M)Go t obo 11 82 76.0

Neer ENuclear RECOVERY QUAUTY ASSURMCE PLAN 1000-PLN-7200.02 Revision No l

Title 6.0 CONTROL OF STATION ACTIVITIES 4-00 procedures shall provide for the identification of itens which have satisfactorily passed 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 item shall be considered nonconfornino until ,

such evidence becomes available. Affected systens shall also be considered to be inoperable and reliance shall not be placed on such systems to fulfill their intended safety functions.

e. Procedures requiring identification of the operating status of systens, components, controls, or support equipment in order to prevent inadvertent or unauthor-ized operation. These procedures shall require control neasures 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 neasures, such as tagging equip-nent, have been inplemented correctly.

f. fiethods which ensure temporary nodifications shall be i controlled by approved procedures which include a ;

requirement for independent verification. A log shall !

be maintained of the current status of such temporary l nodifications.

g. fiethods which ensure that nonconforming services and .

inoperative or malfunctioning structures, systen, com- l ponents or naterials shall be identified in accordance i with the requirements of this Plan. !

i 6.8.2 Responsibilities ,

6.8.2.1 Office of the Director - Tf11-2 The Office of the Director - Tril-2 is responsible for assuring that the appropriate requirements for controlling the 2_ inspection, test and operating status, including independent

verification, are incorporated in the procedures used on all

~. fabrication, installation, test and operation activities.

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AOOGIOSO t t 82 77.0

Number

@ Nuclear atC0vtavogtvAssua^"c5 io00-pts-7200.oz Title Revision No 4

i6.0 CONTROL OF STATION ACTIVITIES 4-00 6.9 Housekeeping and Cleanliness 6.9.1 Requirements 6.9.1.1 Good housekeeping practices shall be utilized at all tines to I maintain the work areas 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 Important to Safety parts of the '

nuclear plant. l 6.9.1.2 Housekeeping encompasses all activities related to the control t of cleanliness of facilities, materials and equipment; fire l prevention and protection including disposal of combustible material and debris; control of access to areas, protection of equipment, radioactive contamination cont"o1; and, storage of solid radioactive waste. I l

S Housekeeping practices shall assure that only proper materials,

!.9.1.3 equipment, processes, and procedures are utfifzed and that the l quality of the iten is not degraded as a result of housekeeping 1 practices or techniques. During maintenance activities, cer- i i tain portions of safety-related systems or components may be t i

subject to potential contamination with foreign materials. To j prevent such contanination, control neasures, including

, neasures for access control, and tool accountability shall be established. Additionally, imediately pr for to closure of :

system (s) or component (s), an inspection shall be conducted and !

j documented to ensure cleanliness. Special housekeeping :

i considerations shall be nade for maintenance of radioactfvely i contaminated systems and components.

6.9.2 Responsibilities

,6.9.2.1 Office of the Director - THI-2 l The Office of the Director - TMI-2 is responsible for '

establishing and maintaining programs and practices for '

housekeeping and cleanliness control of all work activities performed by the plant site staff, support organizations and i a

contractors in accordance with the requirements of the GPUN QA E Program. ,

_1 l j6.9.2.2 Director - Nuclear Assurance !

~[ l i; The Director - Nuclear Assurance, through the Director - i i:

Quality Assurance is responsible for monitoring the house- r i

AOOO1050tt 92 78.0

Number ENuclear RECOVERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02 Revision No Title j 6.0 CONTROL OF STATION ACTIVITIES 4-00 f keeping and cleanliness practices at the nuclear generating stations and for identifying problems and initiating, recommending and providing solutions through designated channels.

6.10 Equionent Control 6.10.1 Requirements 6.10.1.1 Authorization to remove plant installed operational equipment i or systems from service, for recovery tasks, maintenance or nodification, 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 opera-tional equipment is in a ready status. Work on equipment and systems, critical to operations, shall not be performed while ;

the system is operating without specific advanced approval by !

the designated Operations nanagement personnel in each in- :

stance. The procedures for controlling the renoval fron ser- l

vice and the placement back into service of equipment shall i require: l 1

l a. Control measures such as locking or tagging to secure .

! and identify equipment in a controlled status, i' I

l b. Independent verifications when necessary to ensure that l neasures, such as tagging equipment, have been inple- I mented correctly. !

c. Control neasures for temporary modifications, such as I temporary by-pass lines, electrical jumpers, lifted <

electrical leads, and temporary trip point settings. ;

Included shall be a requirement for independent verifi-cation of installation and renoval (A log shall be i naintained of the current status of temporary j modifications.) , j

d. Control of inspection and test status on individual 2 items by the use of markings such as stanps, tags, !

labels, routing cards or other suitable neans.

l

} e. When equipment is ready to be returned to service, a operating personnel shall place the equipment in opera-

l tion and verify and document its functional y acceptability.

f. When traceability is required, as determined by Plant j Engineering and Quality Assurance, the equipment shall AOOO10$0 t t 82 79.0

I Number Nuclear REC 0YERY QUAlfTY ASSURANCE PLAN 1000-PLN-7200.02 i l

Title Revision No i 6.0 CONTROL OF STATION ACTIVITIES 4-00 be identified in such a manner that it can be traced to its assoc'iated documentation.

6.10.2 Resoonsibilities 6.10.2.1 Office of the Director - TMI-2 The Office of the Direct $r - TMI-2 is responsible for es- ,

tab 11shing and maintaining procedures and assuring inplemen- l' tation of the procedures for identification and control of equipment to avoid unauthorized use and to assure that oper-ational equipment is in a ready status. These requirenents shall include independent verifications to ensure proper imple-nentation.

6.11 Control of Recovery, Defueling, Maintenance (Preventive /

corrective) and Modif_ications 6.11.1 Requirements t

6.11.1.1 Recovery, defueling, naintenance or modifications which have l

the potential to affect the functioning of structures, systems f' or components Important to Safety shall be performed in a i nanner to ensure quality at least equivalent to that specified :

in the original design bases and requirements, materials ,

specifications and inspection requirements except for temporary ;

systems and structures which shall have quality connensurate i with their function. A suitable level of confidence in i structures, systems or comporients on which naintenance or l'

modifications have been performed shall be attained by appropriate inspection and performance testing. Recovery, I maintenance, or modification of equipment and defueling shall 4 be preplanned and performed in accordance with written l

procedures, instructions or drawings a)propriate to the i circumstances which conform to applica)1e codes, standards, i specifications, and criteria. In this regard, work in areas '

and on systems of the plant, critical to safe operation, shall i not be performed while the system or associated systems ar6 operating without specific advanced approval by the designated

_ Operations management personnel in each instance. Methods shall ,

2 be employed to ensure that adequate precautions or evaluations j E are in place during recovery activities (including the '

~

installation and/or removal of hardware) to preclude damaging, g impeding operational movements, or in any way adversely

impacting the ability of ITS items or itens required by the

Technical Specifications to maintain the plant in a safe l g condition. !-

! 6.11.1.2 Detailed step by step procedures are not required for all

g maintenance and nodification work. The supervisor planning the 1

g -

AGOO1050t1 82 80.0

MUCl88r RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 l

l Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 l job must consider the skills required to ensure proper '

completion of the work and identify the procedural requirements accordingly. Work such as replacing chart or drive speed gears, replacing fuses or tightening valve packinc may not t

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

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

a. Methods for obtaining permission and clearance for oper-ation personnel to work and for logging such work. ,

b. Factors to be taken into account, including the neces-sity of maintaining occupational radiation exposure as !

Tow as is reasonably achievable (ALARA).

l

c. ffethod for identification of what procedural coverage is {

necessary for the maintenance, and nodification activity. j

d. Considerations for system / equipment cleanliness control.

e. fiethod for identification of post maintenance, or nodi-fication, testing, including system /equipnent functional capability to meet operational requirements in all re-spects. '

l

f. fiethod for ensuring that maintenance, or modification !

activities, performed either on-site or off-site, are i properly reviewed. ;

g. Ccnsiderations for other activities already taking place '

in the general area. I i

l 2 6.11.1.4 fieans for assuring quality of maintenance, modifications, j E recovery or defueling activities (for example, inspections, '

measurements, tests, welding, heat treatment, cleaning, 5 nondestructive examination and worker qualifications in accordance with applicable codes and standards) and measures to document the performance thereof shall be established.

j' Measures shall be established and documented to identify the 2 inspection and test status of items to be used in maintenance, s modification, recovery or defueling activities.

s 5

AOOO105011 8 2

81.0

Number Nuclear RECOVERY QUAL 1TY ASSURANCE gLAy looo. gen.,200.02 Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 6.11.1.5 A corrective naintenance program shall be developed to naintain structures, systems and components Inportant to Safety at the quality required for then to perform their intended functions.

Corrective maintenance shall be performed in a timely manner to ensure that Inportant to Safety items are adequately naintained in the original, design, functional status.

6.11.1.6 A preventive naintenance program including procedures as ;

appropriate for operational and accessible structures, systems, and components Incortant to Safety shall be established which l prescribes the frequency and type of maintenance to be l performed. In all cases, maintenance shall be scheduled and I planned so as not to compromise the safety of the plant.

Planning shall consider the possible safety consequences of concurrent or sequential maintenance, testing or operating activities. Preventive maintenance shall be performed in a timely manner to ensure that Important to Safety items are adequately maintained in the original, design, functional j status. ,

6.11.1.7 Proposed nodifications shall be reviewed, approved and con- !

l' trolled in accordance with the applicable requirements of the License and Technical Specifications and procedures governing {

the design, procurement, construction, testing and inspection. :

Modifications to structures, systems and components Important :

to Safety shall be reviewed and accepted in accordance with the l l requirements of this Plan. ;

I 6.11.1.8 Design, procurenent, construction, testing and inspection of all modifications shall be perforned in accordance with the applicable portions of this Plan.

l l6.11.2 Responsibilities I I

'6.11.2.1 Office of the Director - TMI-2 ,

The Office of the Director - THI-2 is responsible for: !

I

a. Establishing and implementing preventive and corrective !

naintenance prog *ans to maintain the station in a safe, i 5 reliable and efficient condition. !

,1

~. b. Ensuring that naintenance, modification, recovery, and '

5 defueling activities are performed in accordance with !

I the requirements of this Plan and the applicable 2

, Operating License and Technical Specifications.

3

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O A000105011 82 82.0

gggy RECOVERY Q ITY ASSURANCE Number j

Titte Revision No l 6.0 CONTROL OF STATION ACTIVITIES 4-00 l I

i i

c. Establishing administrative control procedures for i

' maintenance, modification, recovery, and defueling work.

d. Ensuring that design and procurement activities associated with the recovery, defueling and modifica-tions are inplemented in accordance with appreved procedures.

e. Providing the drawings and specifications used for plant nodifications.

I

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

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

h. Preparing and filing design, engineering, procurement and installation records in accordance with the QA !

Records requirements of this Plan,

f. Providing the design and engineering support during !

installation and testing of plant modifications ;

including the resolution of engineering problems identi-fied during installation. '

t '

f j. fiaintaining control o,f technical configuration of the !

plant and maintaining the associated drawings current. I

k. Providing the supervision and labor necessary to !

, complete the recovery, modifications and defueling.

6.11.2.2 Director - Nuclear Assurance i

i The Director - Nuclear Assurance, through the Director - {

l Quality Assurance, is responsible for.

i

a. Review and concurrence with installation procedures. !

i b. Performing inspections and examinations required for

completion and acceptance of the installation. {.

6 5

c. Concurrence with the quality requirements in fabrication !

and installation specifications. I l !

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AOOO 105011 82 83.0

Number ENuclear RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 ,

Title Revision No

6.0 CONTROL OF STATION ACTIVITIES 4-00 l 6.12 Contrc: 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 Important to Safety structures, systens, and ,

components will continue to operate, keeping parameters within l normal bounds, or will act to put the plant in a safe condition j if they exceed normal bounds. ;

6.12.1.2 Provisions shall be made for performing required surveillance testing and inspections. Such provisions shall include the establishment of a naster surveillance schedule reflecting the status of all planned inplant surveillance tests and inspec-tions. Frequency of surveillar:ce tests and inspections may be related to the results of reliability analyses, the frequency and type of service, or age of the item or system, as appropriate. :

6.12.1.3 Additional control procedures shall be instituted, as !

necessary, to assure timely conduct of surveillance tests and '

inspections and appropriate documentation, reporting, and i evaluation of the results. Following the completion of 1 testing, procedures shall be established to assure proper l review of survefilance test data and the return of systems to an operable status. These procedures shall include provisions ,

for the docunentation of authority, conduct, responsibility, !

and verification involved in returning the systen to an i operable status. Such provisions shall include the use of !

procedures, checklists, and independent verification as

I appropriate, considering the degree that systen status was !

! altered during tha parformance of the test.

I j6.12.2 Responsibilities

'6.12.2.1 Office of the Director - TMI-2 !

r The Office of the Director - TMI-2 is responsible for: !

2 I E a. Providing the procedures, schedules and manpower i

necessary to inplement the Surveillance. Testing and

Inspection requirenents of the License and Technical 3

~

Specifications. j sl r

2 b

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A00010$011 82 84.0

ENuclear N*er aEC0vERY QUAUTY ASSURANCE PLAN 1000-PLN-7200.02 ,

Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00

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

6.13 Radiological Contro1 6.13.1 Requirements 6.13.1.1 A radiological controls program shall be established and implemented to: ,

I

a. Control radiation hazards

b. Avoid accidental radiation exposures

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

. regulatory requirements.

d. Provide guidance and specify appropriate methods or l i

techniques to ensure that the performance of activities !

3 are in accordance with sound radiological control j principles and in compliance with applicable rMalatory requirements. ,

i 6.13.1.2 The radiological controls program is to be fully intecrated [

into each and every phase of the recovery, defueling, l operation, naintenance and modification activities at TMI-2. ;

6.13.1.3 Procedures shall be provided for the implementation of the !

radiological controls program. These procedures shall contain l the requirenents for implementation of the program by the i Radiological Controls Department and the requirements for l f inclusion of radiological controls in the plant operation, t

maintenance and testing procedures. I 6.13.1.4 The radiological controls program includes the acquisition of data and provision of equipment to perform necessary radiation i surveys, measurements and evaluations for assessment and !

control of radiation conditions. l R.

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2 A000105011 82 85.0

Number ENuclear REC 0VERY QUAL 1TY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 6.0 CONTROL OF STATION ACTIVITIES 4-00 l 6.13.2 Responsibilities ,

6.13.2.1 Responsible Department Manager Each Department Manager is responsible for assuring that the requirements of the radiological controis program, as appifcable to their activities, are adequately included in procedures and that the procedures are inplemented properly.

6.13.2.2 Director - Radiological & Environmental Controis l The Director - Radiological & Environmental Controls is I responsible for:

a. Establishing and maintaining the radiological controls program.

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

, c. Providing administrative and technical guidance

applicable to radiological controls, radioactive materials, respiratory protection.and radiological

engineering including ALARA programs and dosimetry '

control.

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2 AOOO1050ti 82 86.0

I gggy RECOVERY QUAL 1TY ASSURANCE PLAN Number 1000-PLN-7200.02 Title Revision No 7.0 CONTROL OF RADI0 ACTIVE WASTE 4-00 7.1 Policy 7.1.1 Measures shall be established and documented to assure that the requirements of the Code of Federal Regulations, Title 10, Part 71 and Title 49, Parts 100 through 199 applicable to the packaging and transporting of radioactive wastes are satisfied. i I

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

These sections of this Plan will be implemented to satisfy the requirements of Subpart H to 10 CFR 71. i t

7.1.3 It is the policy of GPUN to minimize the generation of radwaste

naterials consistent with the ALARA concept to minimize personnel exposures and environnental contanination.

7.2 Requirements !

i l7.2.1 Procedures and administrative controls shall be developed and i l impienented to cover the following: '

a. Processing of raaicactive wastes including the collec-tion, handling and preparation for shipment of radio- I

, active liquids and solids. These procedures shall be :

! consistent with the ALARA program and shall clearly l identify the admini.trative controls and organizational :

l responsibilities, j

b. Training and qualification of personnel operating radio- ;

active waste processing equipment, health physics moni- I toring, packaging and shipping and other operations deemed appropriate by management. ,

d_ i

l c. The activities associated with the packaging of radio- .

~

active wastes to include the proper selection of the '

receptacles to be used for containing the waste E!

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( AOOO105011 82 87.0

Number Nuclear REC 0VERY QUALITY ASSURANCE etAN iO00.gtN.7200.02 Title Revision No.

7.0 CONTROL OF RADI0 ACTIVE WASTE 4-00 materials, the selection of the shipping containers

-(structures used to contain and support the receptacle and its contents), radiological control inspections of the packaging prior to release, proper markings on the outside of the package and the preparation of shipping papers and certificates.

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

e. The shipment of radioactive naterial from the Station to be in accordance with the regulations of the U.S.

Department of Transportation for the transportation of hazardous materials (49 CFR) and of the NRC (10 CFR 71),

f. The packaging used for transporting of radioactive wastes, whether purchased from an outside supplier or designed by GgUN, shall meet the applicable requirenents of 10 CFR 71 and 49 CFR. j

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

7.2.2 The carriers to be used for transporting of radioactive wastes j shall be selected on the basis of.their experience, knowledge '

of DOT regulations, control and maintenance of their equipment and the selection and control of their drivers. The carrier is required to have or shall be supplied documented procedures covering acceptance of naterials from a shipper, certification j requirenents, placarding, stowage control, reporting of ,

incidents and security. I i

7.2.3 Radwaste operations shall he controlled to mininize personnel exposurcs or environmental contamination consistent with ALARA.

' 7.2.4 Operations procedures relating to radwaste shipping and i packaging shall be reviewed by QAD to establish any necessary l witness or hold points or activities to be nonitored. #

2 7.3 Responsibilities g7.3.1 Office of the Director - TMI-2 2 The Office of the Director - THI-2, through the on-site staffs

[ shall develop and implement procedures for minimizing the b

e A000105011 82 88.0

NUchr RECOVERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No.

7.0 CONTROL OF RADI0 ACTIVE WASTE 4-00 i f

generation of radwaste materials and the processing of l radioactive waste and movement of radioactive materials. These I procedures shall include the following: !

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

b. Processing and packaging of liquid and solid wastes.

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

d. Selection of the proper packaging for the specific con-tents to be shipped, taking into consideration the radiation levels, contamination limits and shipping requirenents. Radiological Control surveys the i packaging for radiation level and, if acceptable, the Site Operations Departnent marks the outside of the ,

package with the appropriate markings, completes the !

shipping papers and certificates, attaches the security !

seal and advises the carrier that the shipment is ready. !

e. Review and accept carrier procedures specified by the procurement docunents covering the acceptance of radio-active waste materials for shipment.

i

f. Review and accept the designs of packaging purchased :

from an outside supplier. If packaging is to be !,

designed by GPUN, the design, fabrication and licensing i of the packaging shall be the responsibfifty of the -

1 Office of the Director - Tiil-2 through the T!11-2 staff.

f '

7.3.2 Director - Radiological and Environmental Control The Director - Radio 1cgical and Environmental Cor. trol is ,

responsible, through the THI-2 Redfological Controls Director for monitoring all radiological activities associated with the !

processing and handling of radioactive wastes and for advice on radiological matters relating to processing,providing pack- l 5

aging and shipping. I

_7.3.3 Director - Nuclear Assurance i The Director - Nuclear Assurance is responsible, thru the l -l Director - Quality Assurance to: ;

t =,

l $ a. Review and concur with procedures describing control of l ! radioactive waste.

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A000 $ 05011 - 9 2 89.0

Number GMClear RECOVERY QUAllTY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No 7.0 CONTROL OF RADI0 ACTIVE WASTE 4-00

b. Monitor, inspect and audit radioactive waste processing operations to the extent necessary to verify they are perferned in accordance with established procedures, applicable administrative controls and regulatory requirements.

7.3.4 Responsible Department Managers Each nanager shall establish the .*equirements for personnel qualification and institute training and indoctrination to satisfy these requirements. Training requirenents shall be connensurate with the importance and complexity of the activity performed.

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A0m)10$011 82 90.0

Number RECOVERY QUAL 1TY ASSURANCE

- OO!OOI PLAN 1000-PLN-7200.02 Titte Revision No.

8.0 CORRECTIVE ACTIONS AND NONCONFORMANCES 4-00

, 8.1 Policy 8.1.1 Nonconforming naterials, parts, conponents, services or activi-ties within the scope of the GPUN Quality Assurance Progran shall be identified and controlled to prevent their inadvertent utilization. Measures shall be established which ensure that conditions adverse to quality, such as failures, nalfunctions, deficiencies, deviations, defective material and equipment, and nonconformances be promptly identified and corrected. The cause of significant conditions adverse to quality shall be determined and appropriate action taken to prevent recurrence.

The identification, cause, and actions taken to correct sig-nificant conditions adverse to quality shall be documented and reported to the appropriate levels of nanagement.

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. ,

l 8.2 Requirements 8.2.1 Nonconfornances include both hardware problems involving ma- !

terials, parts, components or systems which de not com)1y with !

established requirements and non-hardware problems suc1 as j l failure to comply with the Operating License and Technical '

Specifications, proceduros regulations and/or other estab- !

lished requirements.

8.2.2 It is the responsibility of all organizations and individuals i i involved with the THI-2 reenvery operations to identify and l l I report all nonconformances that affect Important to Safety l l structures, systems, equipment, naterials, parts and !

I conponents. These nonconformances may be of a minor nature as j a result of work activities, inspections, nonitoring or re-views; or of a najor nature such as those reportable directly :

to the NRC under 10 CFR Parts 21, 50 and 71 cr the station's j

, Operating License and Technical Specifications.

l 5 8.2.3 Activities such as examinations or checks performed to assess

the condition of equipment or its operation are not considered 7 to be nonconformances until it has been determined that it does l 5 not comply with an established acceptance criteria. These activities shall, however, be documented on an appropriate form k

9 3

e A000105011 82 91.0

N M er

-(UCl88r REC 0VERY QUALIU ASSURANCE PLAN 1000-PLN-7200.02 Title Revis,on No 8.0 CORRECTIVE ACTIONS AND NONCONFORftANCES 4-00 to control the activity. Once it has been determined that a nonconformance exists the condition shall be reported as a non-conformance and the iten controlled to prevent inadvertent use prior to correction, 8.2.4 Procedures shall be established which detail and implenent the following corrective action system measures:

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

b. Corrective action documentation of significant deft-ciencies shall include identification, cause, and ac-tions taken to correct and to preclude the similar recurrence. QAD concurrence is required for corrective action disposition for all QAD identified non-conformances. Reportable Occurrences require the review of independent organizations.

c. Follow-up activities shall be conducted to verify imple-mentation of corrective actions and to close out cor- i rective actions in a timely nanner. l

d. Significant deficiencies, nonconformances and defects which are potentially reportable to the NRC shall be ,

identified to appropriate nanaaenent levels for evalu- !

ation and reporting to the NRC, as appropriate. l 1

8.2.5 Procedures shall be established which detail and implement the requirements for identification and control of nonconforming itens and activities and for the identification of the cause of .

the conditions and the actions to be taken to correct the con-ditions to prevent recurrence. These procedures shall include requirements for the following. j

a. Identification of the forn to be used for reporting the nonconformance. :

b. Description of the nonconforming item or activity and date of identification. f 5

c. Identification of the initiator of the non-confornance !

- report.

5

d. Description of the nonconformance.

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A000105011 82 92.0

GUCl68r REC 0VERY QUALITY ASSURANCE ptan jooo_ptn_7200.02 Title Revision No 8.0 CORRECTIVE ACTIONS AND NONCONFORMANCES 4-00

e. Identification of nonconforming items by appropriate means (tags, labels, etc.) and segregation, if prac-tical, untf1 disrosition of the nonconforming item has been determined.

f. Disposition of nonconformance. The disposition shall be made by the organization that established the governing requirenents or, if this is not possible, by the organi-zation with current design engineering responsibility. j QAD concurrence of material nonconfornances is required to close out all nonconformances.

g. Notification to the affected organizations of the nonconformance.

h. Verification and close out.

i. Record retention.

j. Required approval signatures of the disposition and the !

verification,

k. Evidence of review for reportability to the NRC. I 8.2.6 Reworked, repaired, and replacement items shall be reinspected :

and tested in accordance with the original inspection and test I requirements or acceptable alternatives as deterniaed by Engi- I neering and Quality Assurance. All inspection, testing, re-work, and repairs shall be by approved procedures and the results documented. .

I 8.2.7 Prior to the initiation of a preoperational test on a safety l related item all nonconformances shall be evaluated for sig- !

nificance or inpact on further testing or operation. l 1

8.2.8 Nonconformance reports c'1all be periodically analyzed to show l quality trends. Such an:Tysis will be based upon severity, !

number, frequency of ncnc.nformances, the causes of the j nonconformances and the timeliness of the reporting and resolution of nonconfornancts. The results of analyses shall .

5 be periodically reported to management for review and !

assessnent. When sigr,1ficant conditions are identified or when l actions are required by upper management to correct problens, l 5

such as a generic problen identified by the trend analysis or i repetitive failure to disposition nonconfornances, these problens shall be elevated to upper levels of management for i resolution.

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e ADOO 105011 8 2 93.0

Number RECOVERY QUAllTY ASSURANCE AUCl88r PLAN 1000-PLN-7200.02 Title Revision No.

8.0 CORRECTIVE ACTIONS AND NONCONFORMANCES 4-00 8.3 Responsibilities 8.3.1 Director - Nuclear Assurance The Director - Nuclear Assurance through the Director - Quality I Assurance is responsible for the following: l

a. Review and concurrence of all procedures for reporting i and controlling of nonconformances for compliance with ;

the requirements of this Plan. l 8.3.2 Office of the Director - THI-2 The Office of the Director - TMI-2 is responsible for ensuring that nonconformances are reported and corrected for activities l' involving recovery, defueling operation, raaintenance, repair, replacement, addition, modification, radiological control, and l environnental monitoring. Plant itens such as failures, !

malfunctions, deficiencies, deviations and defective materials, I parts or components are handled in a nanner consistent with their importance to safety and reviewed in accordance with

appropriate procedures and the Technical Specification. j 8.3.3 Responsible Department Manager 8.3.3.I Each Director / Manager is responsible for the disposition and l

corrective action of nonconformances identified as within the ;

j scope of his responsibf11 ties. In the specific case of mater- l fals, parts, components, or systens which have not been instal- ;

led or accepted as operational at the Station, the responsible Director / Manager approves and the Quality Assurance Department concurs with the resolution of nonconformances.

i -

! 8.3.3.2 Each Director / Manager is responsible for ensuring that non-conferning conditions are identified and controlled in accordance with approved procedures.

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A0001050it 82 94.0

Number i gdg7 REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 I

Title Revision No 9.0 AUDITS 4-00 9.1 Policy A comprehensive and documented audit system shall be estab-lished and implemented to ensure that:

a. Policies, plans, procedures and instructions define sufficient organizational responsibilities; and, methods consistent with regulatory requirements and this Plan.

b. Policies, plans, procedures and instructions are implemented.

c. Corrective action systems and management reviews provide for timely completion of requisite action for identified defi ci en c i es /non-con formances/ occurrence s/ even ts ,

d. Corrective action systems and management reviews provide effective identification and prevention of recurrent and/or significant conditions adverse to quality.

i'

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

f. Data is provided for the continuing appraisal of the effectiveness of all elements of the GPUN Quality Assur-ance Program.

9.2 Requirements !

9.2.1 A comprehensive system of audits shall be_ established for both l internal and external functions which affect structures, sys- I tems, components, operations and activities covered by the i scope of the GPUN Quality Assurance Program. j i

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

5 a. GPUN Quality Assurance Program.

~. b. Code of Federal Regulations.

l c. Regulatory Guides, ANSI, and other codes and standards as endorsed in this Plan or other GPUN licensing based l l documents.

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A000105011 82 95.0

RECOVERY QUALITY ASSURANCE l PLAN 1000-PLN-7200.02 Revision No gg j 9.0 AUDITS 4-00

d. P,lant License and Technical Specifications.

e. Policies, plans, procedures and instructions affecting Important to Safety items and activities.

f. Contractual requirements associated with external l organizations providing Important to Safety items and services.

9.2.3 Audits shall include an objective evaluation of quality related practices, procedures and instructions including an objective review of activities, items and records which demonstrate ef-fective and proper implementation, 9.2.4 Audits shall be performed in accordance with pre-established written procedures and checklists, and shall be conducted by trainad and qualified personnel having no direct responsi-bilities in the areas being audited. The audit program shall include:

! a. Audit schedules.

I b. Procedures for preparation, performance and reporting of '

audits. ,

c. Analysis of audit data and reporting results to ap- {

propriate levels of management. l l

! d. Follow-up action to be taken based upcn individual and !

collective audit reports. l

e. Qualification of auditors. ,

l

f. Delineation of the authority, responsibility, and organ- l

! ; izational independence of those responsible for the ,

l audit program. !

l l

9.2.5 Audits shall be regularly scheduled based upon the status and l l safety importance of activities being performed and shall be >

l initiated in a timely manner to assure the effectiveness during i

design, procurement, manufacturing, construction, installation, 2 inspection, testing and as required by the Technical Specifi-Si cations. In addition, audits shall be scheduled and performed

- as required by management or the safety review groups for j special evaluations. Implementation of corrective action shall 2 be verified in a timely manner. Unscheduled audits may be ;

l :! j conducted at any time on any aspect of this Plan.

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AOOO 105011 82 96.0

Number ENuclear g,

REC 0VERY QUA TY ASSURANCE 1000-PLN-7200.02 Revision No.

9.0 AUDITS 4-00 l 9.2.6 Both GPUN and organizations providing Important to Safety items and/or services are subject to the audit requirements of this Plan.

9.2.7 Audits will be performed by the Quality Assurance Program Development and Audit Section.

9.2.8 Audited organizations shall provide sufficient support to assure the accuracy of the audit results, review and response to audit non-conformances, and effective resolution / prevention of deficiencies. The corrective actions required to resolve l audit findings and observations shall be addressed in a timely manner.

9.2.9 Audit frequencies shall be based upon the status and safety importance of activities, degree of previous experience, thoroughness of overall coverage, unique testing / operating activities, and follow-up of previous audit findings. In plan-ning and scheduling audits the areas which should be included are activities associated with: ;

I

! a. The determination of plant features and activities which l affect plant safety, including taking systems out of :

service for maintenance and modifications and turning j them back over to Operations. '

i ;

l b. Preparation, review, approval and control of procurement !

activities, j

c. Indoctrination and training.

d. Interface control among the various Divisions of GPUN l l and between GPUN and contractors / vendors. li 1

l e. Corrective action, calibration and nonconformance con- ;

i i

trol systems. j

! f. Regulatory commitments.

l

_ g. Activities associated with computer codes.

2 5 9.2.10 Sufficient record types shall be maintained to provide docu-

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mentation of audit system scope, individual audit coverage (i.e. checklists or equivalent), audit results, audit team

-l leader certifications, follow-up and verification and results of trending / analysis.

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.s A000105011 82 97.0

gUCl88r REC 0VERY QUALITY ASSURANCE ptan icoo_ptn 7200.02 ,

Title Revision No 9.0 AUDITS 4-00 9.2.11 Audits shall be performed by personnel who are trained and qualified to the requirements defined in ANSI N45.2.23. Each audit team shall be led by a qualified Audit Team Leader.

Audit team members shall be utilized as required and will be classified as either auditors or technical specialists, de-pending on their function on the audit team.

9.3 Responsibilities t

9.3.1 Director - Nuclear Assurance l The Director - Nuclear Assurance is responsible through the Director - Quality Assurance to:

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

b. Provide the auditing organizat:On which meets the re-quirements of this Plan,

c. Evaluate the effectiveness of the audit program, i

d. Ensure the development and implementation of the audit '

schedule. !

i

e. Analyze the results of audits for quality trends and j l inform the Office of the President and the affected ;

Division Director of the results. '

I 9.3.2 Division Director (s) - Audited Organization (s) i I

The Division Director (s) of the audited organization (s) are l responsible through Directors / Managers to ensure. ;

I

a. Sufficient support is given' to the audit process to !

optimize the accuracy of the audit results. l

b. Sufficient review of audit results is provided to assure

! that effective preventive measures for audit non-con-formances are defined and implemented.

2

c. Responses to audit findings are reviewed and approved by l T. their organizations prior to submittal to the auditing

? organization.

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AOOO I 05011 82 98.0

Number ENuclear Remvm gn ASSURMCE 1000-Pu -7200.02 8 Revision No 9.0 AUDITS 4-00

d. Responses to audit findings are submitted to the auditing organization in a timely manner as defined in implementing policies, plans, procedures and/or in-structions.

e. Corrective actions to resolve audit findings are taken in a timely manner.

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AGOOt0$OIt 82 99.0

Number gdg7 REC 0VERY Q M TY ASSURANCE 1000-PLN-7200.02 Title Revision No INDEX TO APPENDICES 4 00 APPENDIX A Comparison Chart of Recovery Quality Assurance Plan Requirements with those of various parts of the Code of Federal Regulations and Nuclear Industry Standards APPENDIX B QAD Management Control Requirements for "Important to Safety" Documents APPENDIX C NRC Regulatory Guide Commitments and Exceptions APPENDIX D Terms and Definitions t

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APPENDIX A cg COMPARISON CilART OF RECOVERY OUALITY ASSURANCE PLAft REQUIREMENTS wIIN iriuht. ut vARTUUS PAxi> ut i rit.

CODE OF FEDERAL REGULATIONS AND NUCLEAR INDUSTRY STANDARDS Rap 9

10 CFR 50, App. 8 ANSI N45.2 10 CFR 71, Subpart H ANSI N18.7 - 1976 Criterion QA Plan Paragraph QA Plan Criterion QA Plan Paragraph QA Plan Paragraph QA Plan :n I 1.0 2.0 2.0 71.103 1.0 3.1 1.0;6.0 E 11 2.0 3.0 5.2.12 3.3 o 1.0 11.105 2.0 3.2 1.0 5.2.13 5.0 $

m III 4.0 4.0 4.0 71.107 4.0 3.3 1.0;2.5

,o IV 5.1 5.0 5.1 71.109 5.1 3.4 1.0;2.4 5.2.14 8.0 $

3.1 6.0 5.2.15 3.1 o

. V 3.1 71.111 3.1 5.2.16 6.6 m c-VI 3.2 7.0 3.2 VII 5.1 8.0 5.1 71.113 71.115 3.2 5.1 4.0 1.0;2.8; 5.2.17 6.2 5N VIII 9.0 5.2.18 6.4 *Z 5.2 9.0 5.2 71.117 5.2 5.1 2.1,2.2,2.7

IX 6.4,6.11 5.2.19 6.5 1J.0 6.4;6.11 71.119 6.4;6.11 5.2.I 1.4.1.4.1,3.1 5.3.1 X 6.2 11.0 6.2 7.0 5.3.2 3.1 3.1.2 3

m XI 6.5 12.0 6.5 11.121 6.2 5.2.2 3.1.1,3.2 XII 6.6 13.0 6.6 1.0 5.3.3 3.1.1 E 5.2.3 3.1.1,3.1.2 5.3.4 3.1.1 3 XIll 6.7 14.0 6.7 71.123 6.5 5.2.4 3.1.1,3.1.2 XIV 6.U;6.10 15.0 6.8;6.10 5.3.5 3.1.1,6.11 2 7.0 5.2.5 3.1.1,3.1.2 5.3.6 3.1.1,6.13 XV 8.0 16.0 8.0 71.125 6.6 5.2.6 6.8,6.10 5.3.7 XVI 8.0 17.0 8.0 3.1.1.6.6 7.0 5.2.7 6.11 5.3.8 6.13 XVII 3.3 18.0 3.3 11.127 6.7 5.2.8 6.12 XVill 9.0 19.0 5.3.9 3.1.1 9.0 7.0 5.2.9 2.2.1.2,3.1 5.3.10 6.2,6.5;6.8 71.129 6.8;6.10 5.2.10 6.9 7.0 5.2.11 8.0,2.3.1.2 11.131 8.0 m 2 11.133 8.0 c. $ - y 11.135 3.3 11.137 9.0 6 0

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Nuclear REC 0VERY QUAllTY ASSURANCE glAN 3000.gty_,200.02 :

I Title Revision No APPENDIX B 4-00 i l

QAD Management C'ontrol Requirements for Important to Safety Documents Document Type 0A Department Management Control Requirements QA Pla~ Director Quality Assurance preparer writer evaluation of revisions; submit significant changes to the NRC.

l QA Department Approved by Director - Quality Assurance; i Procedures Concurrence of QA Section Manager affected.

l QA Corporate Procedures Approved by the Director - Quality l Assurance; Concurrence of Division Directors affected.

QA Section Procedures Approved by the QA Section Manager affected; Concurrence of QA Subsection Manager / Supervisor.

4 Unit Administrative Concurrence of Manager QA Mod /0ps. l

Procedures ;

Unit Operating Concurrence of Manager QA Mod / Ops., unless '

Procedures otherwise designated l Unit Maintenance Concurrence of Manager QA Mod / Ops. ;

Procedures !

NDE Procedures and Approved by Director-Quality Assurance or Calibration Standards applicable QA Section Manager; concurred by - i

! Level III in applicable discipline.

I i l Installation / Modification Cont.arrence of Manager QA Mod./ Ops. !

l Procedures Test Procedures Conc :rrence of Manager QA Mod / Ops.

Site Work Authorizing documents Concirrence of Manager QA Mod /0ps.

l i

5 Design Specifications Concurrence of Manager QA Mod /0ps 3 Procurement Requisitions ' Concurrence of cognizant QA representative.

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e AOOO 10'a011 82 102.0

Nuciear RECOVERY QUALITY ASSURANCE etAn 3000. gen.7200.02 :

l Title Revision No l

APPENDIX B 4-00 l l

QUALITY ASSURANCE PROGRAM NRC REGULATORY GUIDE COMMITMENTS AND EXCE'PTIONS l

This Appendix identifies those Regulatory Guides which contain Quality l Assurance Program requirements and identifies the GPUN positions rela- ;

tive to compliance. Part I of the Appendix is a tabulation of the l Regulatory Guides the corresponding ANSI Standard and Remarks. Alter-natives or clarifications are detailed in Part 2 of the Appendix.

Compliance with these Regulatory Guides will apply to all recovery activities performed after issue of this QA Plan and does not imply backfitting and/or retroactive compliance. It is also to be recognized that plant conditions will vary throughout the recovery operations and that these plant conditions may prevent or preclude the i satisfaction of all requirements of a specific Regulatory Guide. When !

! this occurs these conditions will be documented and, along with the !

I justification, will be approved by the Director - Quality Assurance. li t

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AOM105011 82 l

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A APPENDIX C, PART I 5 Q

CulttilTHENT TO QUALITY ASSURANCE REGULATORY GUIDES o g

REG. GUIDE ANSI STD.

DEGREE 07 CGI4PLTANCE REllARKS D

amma 1.8 9/15, Rev. 1-R Personnel Selection and Training N13.1 1971 Modified See attached cosmaents.

1.26 2/76, Rev. 3 ,

QA Classifications and Standards Hodified for Water Stream and Radioactive See attached corsnents.

Waste Containing Components of Nuclear Power Plants ,

1.28 2/79, Rev. 2 Quality Assurance Program n Requirements (Design and N45.2 197/ Ilodified See attached comments. E S Constructfon) 9

'o '

1.29 9/78, Rev. 3 Seismic Design Classification g Modified See attached corsnents. EE 1.30 8/11/72 QA Requirements for the Install- N45.2.4 EC 1972 Modified See attached coimaents.

ation, Inspection and Testing Q of Instrumentation and Electrical ,

Equipment m 1.31 4/73, Rev. 3 Control of Ferrite Content in N Full Comply with Regulatory Stainless Steel Weld M!tal 2 Position. m 1.33 2/78, Rev. 2 Quality Assurance Program NI8.1 1976 liodified Requirements (Operation) See attached conaents.

1.37 3/16/13 QA Hequireacnts for Cleaning of N45.2.I Fluid Systems and Associated 19/3 Modified See attached coanents.

Components of Water Cooled Nuclear Power Plants I.38 5/77. Rev. 2 QA I;equirements for Packaging, N45.2.2 1972 Modified See attached cot:eneelts.

Shipping, Receiving, Storage and Handling of items for Water

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4 r-Coolad Nuclear Power Plants

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APPEt4 DIX C, PAPT 1 n E

_ REG. GUIDE DEGREE OF C

ANSI STD. GMPLIANCE REMARKS 1.39 9/77, Rev. 2 Housekeeping Requirements for (145.2.3 1973 Modified Water Cooled Nuclear Power See attached coctaents, nur Plants 9 1,54 6/73 QA Requirements for Protective 101.4 1972 Hodified Coatings Applied to Water See attached cossaents.

Cooled Nuclear Power Plants o 1.58 9/80, Rev. 1 E o

Qualifications of Nuclear Power N45.2.6 1918 Hodified Plant Inspection, Examination See attached cosaaents. N and Testing Personnel o"

1.64 6/76. Rev. 2 o

. Quality Assurance Requirements N45.2.ll 1974 Hodified TC for the Design of Nuc. ear See attached couaents. EN Power Plants **

1.74 2/74 Quality Assurance Terms and N45.2.10 1973 Full >

Definitions Comply with Regulatory Position. $

1.88 10/76 Rev. 2 55 Collection Storage and Main- N45.2.9 1974 Modified See attached cosaents, E tenance of Nuclear Power Plant g Quality Assurance Records 1.94 4/76, Rev. 1 QA Requirements for Instal- N45.2.5 1974 Modified lation, inspection and Testing of See attached corroents, Structural Concrete & Steel during fluclear Power Plant Construction E 2 1.116 5/77. Rev. 0-R QA Requirements for Installa- N45.2.8 a 5 1975 Hodified -

3 tion, Inspection and Testing of Hechanical Equipment and Systems See attached conssents. 6E o 3 8g O '

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0 APPENDIX C PART I DEGREE OF REG. GUIDE ANSI STD. COTFLTANCE REMARKS 1.123 7/77. Rev.1 QA Requirements for Control of N45.2.13 1976 Modified See attached coimaents.

Procurement of Iteus and Serv- :o ices for Nuclear Power Plants p O

1.142 10/81, Rev. 1 Safety-Related Concrete Struc- N45.2.5 1974 Hodified N

See attached comaents. E tures for Nuclear Power Plants ANS6.4 1971 8 (Other than Reactor Vessels ACl3I8 1977 yg a

o and Containments) gg 1.144 1/79 Requirements for Auditing of N45.2.12 1977 Modified See attached connents.

Quality Assurance Programs for Nuclear Power Plants g 1.146 8/80 Qualification of Quality N45.2.23 1978 E

full Couply with Regulatory Position. E Assurance Program Auditors for Nuclear Power Plants g 1.143, 1979 Rev. 1 Design Guidance for Radio- -

- Modified Same as Regelatory Guide 1.29.

active Waste Management Systems I E P i 5 P, 88 8

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Number gdg7 REC 0VERY Q TY ASSURANCE 1000-PLN-7200.02 Title Revision No APPENDIX C 4-00

, PART 2 NRC Regulatory Guide 1.8, Rev.1, September 1975 Personnel Selection and Training. Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI-N 18.1 of 1971 for comparable positions unless otherwise noted in the Technical Specifications.

NRC Regulatory Guide 1.26, Rev. 3, February 1976 Quality Group Classification and Standard for Water, Steam and Radioactive Waste Containing Components of Nuclear Power Plants

" Modifications to the existing plant which are intended to remain after plant startup will be classified in accordance with this Regulatory Guide. The classification criteria of this guide will be used on a case by case basis for recovery modifications to existing plant systems; (i.e., changes which shall be removed prior to restart of the plant) to insure they will perform their intended recovery functions."

NRC Regulatory Guide 1.28, Rev. 2, February, 1979 Quality Assurance Program Requirements (Design and Construction)

GPUN complies with the regulatory position of this guide with the exception of the following:

! A Code Quality Assurance Program could be extended to cover !

functional operability in lieu of involving ANSI N45.2, provided that the program is evaluated to determine it it includes the additional elements necessary to cover functionability and oper-ability. !

NRC Regulatory Guide 1.29, Rev. 3, September 1978 Seismic Design Classification Modifications to the existing plant which are intended to remain af ter plant startup will comply with this Regulatory Guide. Temporary Re-covery modifications (i.e., changes which shall be removed prior to re-z= start of the plant) will not have as design basis severe natural pheno-mena such as safe shutdown earthquake, tornado and tornado missile, or E maximum flood. These items will be designed for probable natural

.: phenomena as required by local building codes.

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1 A000105011 82 107.0

NumbIr gggy REC 0VERY QU L TY ASSURANCE 1000-PLN-7200.02 i Title Revision No APPENDIX C 4-00 l

NRC Regulatory Guide 1.30, August 1972 Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment GPUN shall 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 l requirements associated with maintenance and modifications shall be the I original technical requirements or better (e.g., code requirements, { f material properties, design margins, manufacturing processes, and I inspection requirements). I I Sections 5.2 and 6.2 of ANSI N45.2.4 list tests which are to be con-ducted during the constructica phase. In lieu of this, GPUN utilizes its Engineering and/or Maintenance organizations to establish the need for specific tests or test precedures during the operational phase.

NRC Regulatory Guide 1.33, Rev. 2, February 1978 Ouality Assurance Program Requirements (Operation)

The GPUN QA Program complies with the regulatory position of this guide '

with the following clarifications:

i l 1. Paragraph C.4.a is interpreted to mean audits will be made once i i each 6 months to verify the nonconformances and corrective action !

program is properly implemented and documented, particularly as l related to actions taken to correct deficiencies that affect items important to safety. I

! 2. Paragraph 5.2.8 of ANSI N18.7 - 1976 titled " Surveillance Testing l

! and Inspection" '

l l In lieu of a " master surveillance" schedule, a technical speci- l' fication surveillance testing schedule shall be established reflecting the status of all inplant surveillance tests and inspections. t 5 3. Paragraph 5.2.15 of ANSI N18.7 - 1976 titled " Review, Approval

and Control of Procedures" ,

~. l 3 The third sentence of the third paragraph is interpreted to mean 4 2, applicable procedures shall be reviewed following a reportable l -; incident such as an accident, an unexpected transient, signi-l j! ,

ficant operator error, or equipment malfunction.

! 4. Paragraph 5.2.17 of ANSI N18.7 - 1976 titled " Inspections" 2

5 AdOO105011 til 108.0

Number gdg7 REC 0VERY Q ITY ASSURANCE Revision No APPENDIX C 4-00 Not all inspections will require a separate inspection report.

Inspection requirements may be integrated into appropr late pro-cedures or other documents with the procedures or documents serving as the record; however, records of inspections will be identified and retrievable.

5. ANSI N 18.7-1976 in Section 5.2.2. Procedure Adherence requires for temporary changes that at least one approval shall be by an SRO. The Technical Specifications for TMI-2 do not require an SRO for temporary changes that do not affect the operational status of unit systems or equipment, but do require the approval of a manager within the Department having cognizance of the procedure being changed.

NRC Regulatory Guide 1.37, March 16,1973 Quality Assurance Requirements for Cleaning Fluids Systems and Associated Components of Water Cooled Nuclear Power Plants The GPUN Quality Assurance Program complies with the regulatory position of this guide with the following clarifications:

1. The second sentence of paragraph C.3 should be amended to read:

"The water quality for final flushes of fluid systems and asso-ciated components shall be at least equivalent to the quality required for normal operation. This requirement does not apply to disolved oxygen or nitrogen limits nor does it infer that chromates or other additives normally in the system water will be added to the flush water."

l 2. Paragraph C.4 should be amended to add:

l Material such as inks, temperature indicating crayons, labels, !

I wrapping materials (other than polyethylene), water soluble l materials, lubricants, NDT penetrant materials and couplants, which contact stainless steel or nickle alloy material surfaces shall contain no more than trace elements of lead, zinc, copper, j mercury or other low melting alloys or compounds. Maximum l _

allowable levels of water leachable chloride ions, total halogens 2 and sulfur compounds shall be defined and imposed on the afore-mentioned materials.

jj

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3. Section 2.1 of ANSI N45.2.1 states that required planning is frequently performed on a generic basis for application to many I

j installations on one or more projects. This results in stindard g; . procedures or plans for installation and inspection and testing a which meet the requirements of the Standard. Individual plans

! for each item or system are not normally prepared unless the work 2

5 A000105011 82 109.0

gggy REC 0VERY QUALITY ASSURANCE-PLAN 1000-PLN-7200.02, Title Revision No APPENDIX C 4-00 operations are unique. However, standard procedures or plans will be reviewed for applicability in each case. Installation plans or procedures are also limited in scope to those actions or activities which are essential to maintain or achieve required quality. This is consistent with Section 11 Paragcaphs 2 and 3 of ANSI N45.2-1977 which provides for examination, measurement or testing to assure quality or indirect control by monitoring of processing methods. However, final cleaning or flushing activities will be performed in accordance with procedures specific to the system.

4. Section 3.1.2.1 of ANSI N45.2.1 states that surfaces shall be examined without magnification under a lighting level (background plus supplementary lighting) of at least 100 foot candles. GPUN intends to permit the use of 18% neutral gray card for determin-ing acceptability of illumination in lieu of the 100 foot candles.

5. Section 4.0 of ANSI N45.2.1 states that items are not to be delivered to the point of installation sooner than necessary i unless the installation location is considered a better storage

! area. The strategy for the storage of items is based on many factors, one of which is to not adversely affect the items ,

acceptability while in storage. 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. As an alternate to this requirement, items may be delivered to the installation site sooner than absolutely necessary when deter-mined to be advantageous for other considerations. Example - ,

reduced handling or easier access, thereby reducing suscepti- :

bility to handling damage. In all such cases, equipment stored j in place will be protected in accordance with Section 5 of ANSI -

N45 . 2.1. j i

6. Section 6.0 of ANSI N45.2.1 states that where environmental con- !

tamination causes degradation of quality, seals are installed and i the item is tagged with identifications and instructions for seal removal. GPUN utilizes procedural controls which specify the authorization requirements for seal removal. " Tags" are not 5 normally utilized.

NRC degulatory Guide 1.38, Rev. 2, May 1977 5

5 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage ,

, and Handling of Items for Water Cooled Nuclear Power Plants 1 i . 1 9 I i

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e AOOO 105011 82 110.0

Number ENuclear REC 0VERY Q TY ASSURANCE 1000-PLN-7200.02 Revision No.

Title APPENDIX C 4-00 The GPUN Quality, Assurance Program complies with the regulatory position of this guide with the following modifications or clarifications to ANSI N45.2.2-1972:

1. Section 2.7, Classification of Items. The four-level classifi-cation system for storage of items will be followed, however, the designated classification level may not be explicitly identified on the item. The classification level will, however, be traceable through the procurement documents. Classification differing from Section 2.7 will be 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.

2. Section 3.2, Levels of Packaging. The four level classification system for packaging of items may not be used explicitly. For commercial grade items standard commercial grade packaging requirements may be specified.

3. Section 3.6 concerns prevention of halogenated materials from contacting stainless steel or nickel alloy materials. The

- clarifications applicable to Regulatory Guide 1.37, identified previously, also apply to this section of ANSI N45.2.2. 9 l

4 ' ection 3.7.1

> Cleated, sheathed boxes will be used up to 1000 i ibs. rather than 500 lbs. as specified. This type of box is safe l for, and has been tested for, loads 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.

l S. Section 5.5, Correction of Nonconformances. This section pro- l vides for " rework" and "use as is" dispusitions for nonconforming l items. As an alternate, the " repair" disposition (as defined in l ANSI N45.2.10-1973) will also be used.

6. Section 6.2.1 For storage of level D items. access will be con-trolled and limited by posting. Other positive controls such as fencing or posting of guards will be provided for higher storage levels.

5 E 7. Section 7.4 states that a system should be established to indi-

" cate acceptability of all equipment and rigging after each in-j spection, specify control of nonconforming lifting equipment, and supplement periodic inspections with special visual and non-

destructive examinations and dynamic load tests. In lieu of i .

this, GPUN does perform dynamic load tests on new equipment,

preventive maintenance on cranes, nondestructive examination of I lifting hooks annually, and a visual inspection of lifting equip-g ment prior to use.

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f Number

-(UCl687 REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Title Revision No.

APPENDIX C 4-00

8. Appendix A.3.4.1 The last sentence of A.3.4.1(4) and (5) shou'd be corrected as follows:

(4) "However, preservatives for inaccessible inside surfaces of pumps, valves and pipe systems containing, reactor coolant water shall be the water flushable type."

(5) "The name of the preservative used shall be indicated to facilitate touch up."

9. Appendix A 3.4.2, Inert Gas Blankets. There may be cases involving large or complex shapes for which an inert or dry air purge flow is provided rather than static gas blanket in order to provide adequate protection due to difficulty of providing a leak proof barrier. In these cases a positive pressure purge flow may be utilized as an aitcrnate to leak proof barrier.

10. Appendix A.3.5.2 Tapes will meet a sulphur limit of 0.30% by weight instead of 0.10% as specified in A.3.5.2(1)(a).

This limit is reasonable based upon the chemical content of com .

mercially available tapes. Tapes will be of a contrasting color rather than " Brightly Colored" as required by A.3.5.l(3).

11. Appendix A.3.7.1 In lieu of A.3.7.l(3) and (4), the following !

will be imposed: Fiberboard boxes shall be securely closed l'

! either with a water resistant adhesive applied to the entire area l of contact between the flaps, or all seams and joints shall be sealed with not less than 2-inch wide, water resistant tape.

NRC Regulatory Guide 1.39, Rev. 2, September 1977 l Housekeeping Reauirements for Water Cooled Nuclear Power Plants Endorses ANSI N45.2.3 - 1973 The GPUN Quality Assurance Program complies with this guide with the following clarification to ANSI N45.2.3-1973.

1. Sections 2.1 and 3.2; TMI-2 will not utilize the five level zone designation system referenced in ANSI N45.2.3, but will utilize 2 standard janitorial and work practices to maintain a level of E cleanliness commensurate with company policy in the areas of housekeeping, plant and personnel safety, and fire protection.

E. Cleanliness will be maintained, consistent with the work being

~; performed, so as to prevent the entry of foreign material into y .

systems considered important to safety. This will include as a a

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!APPENDIXC 4-00 l

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minimum documented cleanliness inspections which will be per-formed immediately prior to system closure. Control of per-sonnel, tools, equipment,, 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 l required for control of radioactive contamination. ;

2. Section 3.2.3 discusses fire protection. Except for the quality assurance aspects of fire protection, no specific commitments are made in this Plan. As part of other activities, GPUN has established positions or commitments relating to fire safety or protection.

NRC Regulatory Guide 1.54, June 1973 l

Quality Assurance Requirements for Protective Coatings Applied to Water !

Cooled Nuclear Power Plants l l The GPUN Quality Assurance Program complies with this guide with the following clarification: i

1. GPUN will comply with the Regulatory Position established in this Regulatory Guide in that QA programmatic / administrative require- i i ments included therein shall apply to maintenance and modifica- ;

j tion activities even though such requirements were not in effect .

originally. Technical requirements associated with maintenance and modifications (e.g., code requirements, material properties, l I design margins, manufacturing processes, and inspection require-

! ments) shall be the original requirements or better. l l .

l 2. The quality assurance program for protective coatings includes '

the planned and systematic actions necessary to provide adequate confidence that shop or field coating work for nuclear facilities I

will perform satisfactorily in service. ,

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(UClear REC 0VERY QUALITY ASSURANCE ptan jooo_etN-7200.02 Title Revision No APPENDIX C 4-00 All prctective coatings, except those noted in 3.0 below, applied to surfaces within containment are tested to demonstrate that they can withstand LOCA conditions. These tests are performed in accordance with Section 4 of ANSI N101.2, Protective Coatings (Paints) for Light Water Nuclear Reactor Containment Facilities, under LOCA conditions which equal or exceed those described in the FSAR.

The quality assurance program is applied for Protective Coatings '

consistent with the nature and scope of work specified in the technical specifications. The following elements are included:

(a) Preparation of coatings specificatinn and procedures for generic coating materials / systems.

(b) Review and evaluation of coating manufacturers' demonstra-tion test data and quality assurance measures for control of manufacture, identification, and performance verification of applied coating systems. ,

(c) Review and evaluation of supplier quality assurance measurn to control storage and handling, surface preparation, appl 1-cation, touch-up, repair, curing and inspection of the coating systems.

(d) Training and qualification of inspection personnel in coatings inspection requirements. !

(e) Supplier surveillance inspection.

The coatings qualification program and the associated quality l assurance requirements are necessary only for coatings whose j failure or failure mechanism would have a significant effect on safety.

l

3. Regulatory Guide 1.54 is not imposed for: i I

(a) Surfaces to be insulated.

(b) Surfaces " contained" within a cabinet or enclosure (for j example, the interior surfaces of ducts).

h. (c) Field repair on any Q-class coated item less than 30 square

inches of surface area such as

5 2 . Cut ends or otherwise damaged galvanizing.

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. Bolt heads, nuts, and miscellaneous fasteners.

. Damage resulting from spot, tack, or stud welding.

Field touch-up and repair of larger areas shall be in accordance with item (1).

(d) Small " production line" items such as small motors, hand- j wheels, electrical cabinets, control panels, loudspeakers, I etc. where special painting requirements would be impracti- I cable.

(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 i' documents listed in Section 7.4 through 7.8 of ANSI N101.4 but will be evaluated to assure that they provide at least the same degree 'of documentation as required by this standard. :

NRC Regulatory Guide 1.58, Rev.1, September 1980 l l

Qualifications of Nuclear Power Plant Inspection, Examination, and Testing i l Personnel i The GPUN Quality Assurance Program complies with this guide with the !

following clarification.

1

1. The guidance of Regulatory Guide 1.58 shall be followed as it I 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 j 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 III personnel shall be l recertified at an interval of every 5 years as noted by ASME Code ,

2 Cases N-341 and N-356, rather than the 3 year interval !

recommended by ASNT-SNT-TC-1A 1980. !

j 2. Not all personnel who:

Review and approve inspection and testing procedures,

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A.

3 B. Evaluate the adeauacy of activities to accomplish the

! inspection and test objectives, 3

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Nuclear REC 0VERY QUALITY ASSURANCE etAN icoo.gtN.7200.02 Title Revision No.

APPENDIX C 4-00 C. Evaluate the adequacy of specific programs used to train and test inspection and test personnel, D. Certify Level III individuals in specific categories or classes, Will be certified as meeting the Level III capability require-ments of ANSI N45.2.6 - 1978.

Rather these personnel will be determined by management through evaluation of their education, experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented.

NRC Regulatory GJida 1.64, Rev. 2, June 1976 Quality Assurance Requirements for the Design of Nuclear Power Plants GPUN will comply with the Reguletory Position established in this Regulatory Guide in that QA programmatic / administrative requirements j 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) asso-ciated with maintenance and modifications shall be the original require-I ments or better.

l l The Quality Assurance Program complies with this guide with the following clarification to paragraph C.2(1): If the designer's imediate 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, j i and (b) the justification is individually documented and approved in !

advance by the Supervisor's management, and (c) quality assurance audits l cover frequency and effectiveness of use of Supervisors as design verifiers to guard against abuse.

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 requirements of ANSI /ASME NQA-1-1979, Supplement 17S-1 and Appendix 17A-1, including Addendum 17-1 NQA-la-1981.

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NRC Regulatory Guide 1.94, Rev.1, April 1976 Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel during the Construction Phase of Nuclear Power Plants The GPUN Quality Assurance Program complies with this guide with the following clarification:

For Important to Safety, but not Safety Related, the Regulatory Guide will be used as guidance, but is not mandatory. The requirements and the specific application will be determined commensurate with the importance to safety of the item.

QA programmatic / administrative requirements included in the Regulatory Guide shall apply to maintenance and modification activities even though such requirements were not in effect originally. Technical requirements associated with maintenance and modifications shall be the original requirements or better (e.g., code requirements, material properties, design margins, ,

I manufacturing processes, and inspection requirements).

NRC Regulatory Guide 1.116, Rev. 0-R, May 1977 ;

i Quality Assurance Requirements for Installation, Inspection and Testing of l Mechanical Equipment and Systems l t

I 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 l I such requirements were not in effect originally. Technical requirements i associated with maintenance and modifications, shall be the original l 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 Main-5 tenance organizations to establish the need for specific tests or test procedures during the operational phase.

5 NRC Regulatory Guide 1.123, Rev. 1, July 1977 2

2 Quality Assurance Requirements for Control of Procurement of Items and 3

Services for Nuclear Power Plants N

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, ENuclear rec 0vERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 Revision No Title APPENDIX C 4-00 The GPUN Quality Assurance Program complies with this guide with 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 Sc: tion 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.a of ANSI N45.2.13-1976 - When evaluation of a sup-plier is based solely on historical supplier data, these data will primarily include records that have been accumulated in connection with previous procurement actions. Data that includes experience of users of identical or similar products of the prospective supplier and product operating experience will be ,

used if available. r

4. Section 4.2 of ANSI N45.2.13-1976. In the special case of j

" commercial grade items" the supplier does not have to be evaluated by one of the methods identified; however, the pro- l curement documents shall contain requirements specific to the i l item being procured. ;

5. Section 10.2.d of ANSI N45.2.13-1976. The requirements of this section are interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of !

I the supplier and shall be identified by the supplier. .

I

6. Section 10.2.1, Verificaticn of the Validity of Supplier Certi- !

ficates and the Effectiveness of the Certification System, is as i follows: The verification of the validity of supplier certi- I ficates and the effectiveness of the certification system are !

accomplished as an integral part of the total supplier control I and product acceptance program, and no separate GPUN system exists that addresses itself solely to such verification. The 5 degree of verification required will depend upon the type of item

or service and their safety importance. The means of veri- l

~. fication may include source witness / hold points, source audits, E and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such as

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APPENDIX C 4-00 concrete components; and tests after installation on selected components' and systems. All of these means verify whether or not a supplier has fulfilled procurement document requirements and whether or not a certification system is effective.

NRC Regulatory Guide 1.142, October 1981 Rev.1 l Safety-Related Concrete Structuras for Nuclear Power olants (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 ITS structures and additions to existing ITS structures. Inspectors will be qualified according to either ANSI N45.2.6 or Appendix VII of Section III, Divi-sion 2, of the ASME Boiler and Pressure Vessel Code.

NRC Regulatory Guide 1.144, January 1979 Auditing of Quality Assurance Programs for Nuclear Power Plants GPUN is in basic agreement with the position set forth in the Regulatory

! Guide subject to the following comments:

1. Section C.3.a(2) l l

The proposed scheduling requirement for internal audits appears i l to change the basis for having a rational, programmatic approach !

l to auditing. In its place, the new Regulatory Guide recuires I mandatory auditing of all program elements on a yearly basis.

The latter would require that all elements obtain the same atten-tion regardless of importance, past performance, or to what ex- !

tent other aspects of quality assurance measuring and evaluating j techniques are used; as an example, the extent to which sur-l veillance and process monitoring is used. Accordingly, minimum ;

schedule frequency will be as defined in Regulatory Guide 1.33. i i

2. Sectic,C.3.b(1) Source inspection provides a controlled basis I for replacing the need for external audits. The use of quality assurance program surveillance will also be used as another alternative.

a

[ 3. Section C.3.b(2) d While the licensee is responsible for procurement control, this R can be exercised through an annual evaluation of the contractor's

, performance using pertinent results from manufacturing sur-gl ,

veillance, source inspection, receivug inspection, and other 3

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Number ENuclear RECOVERY QUA TY ASSURANCE 1000-Pt.N-7200.02 Revision No_

l Istle APPENDIX C 4-00 applicable. factors. The evaluation would include a recommenda-tion as to the need for a scheduled program or problem area audit. Hence, auditing, like surveillance and inspection, will be treated as a quality assurance tool used for evaluation.

Furthermore, the recommendation to audit will include provisions for reviewing the importance and impact of the particular con-tractor's scope and status, i

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Nun er ENuclear REC 0VERY QUALITY ASSURANCE PLAN 1000-PLN-7200.02 ,f Revision No Title APPENDIX D 4-00 i Terms and Definitions l This Appendix contains certain terms and their definitions that are important to a uniform understanding of the requirements of the GPUN Oper-ational Quality Assurance Program. ANSI N45.2.10-1973, as endorsed by Regulatory Guide 1.74, and NQA-la-1981 contain terms and definitions applicable to the nuclear industry. The terms and definitions found in these documents are applicable to the GPUN Operational Quality Assurance !

Program and, for convenience, are included, in part, herein. Those terms i and definitions which are the same as listed in ANSI N45.2.10-1973 or i NQA-la-1981 are identified by footnote (1). Certain exceptions to the terms I and definitions found in ANSI N45.2.10-1973 and NQA-la-1981 have also been taken. These exceptions are identified by footnote (2).

l ACCEPTANCE (as used in relation to acceptance of a document):

Generally approved, believed or recognized. Does not require signature of person accepting. l ACCEPTANCE CRITERIA: Specified limits placed on characteristics of an item, !

process, or service defined in codes, standards, or other documents. (1) l' l

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.

l ARCHITECT / ENGINEERING (A/E): A firm under contract to provide engineering ;

l or design services. i APPROVAL: An act of endorsing and adding positive authorization (signature) !

to a document by the person (s) responsible for the document. (2) l

! AS-BUILT DATA: Documented data that describes the condition actually ,

! achieved in a product. (1) I COMMERCIAL GRADE ITEM: An item that meets all of the following conditions:

- Is used in applications other than nuclear power plant facilities or l activities, 5 - Is not subject to design or specification requirements unique to NRC l requirements for nuclear power plants; !

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APPENDIX 0 4-00 <

I i I

- May be ordered from the manufacturer / supplier on the basis of speci- l fications set forth in the manufacturer's published product de- i scription (e.g., a catalog). I Note: The specification set forth in the published product de-scription must match the requirements needed to satisfy the design function of the item. ,

i CONCURRENCE: Written agreement that the provisions in a document for which i review has been requested are acceptable for implementation within, or from !

the standpoint of, the signer's area of responsibility.

I CONDITION ADVERSE TO QUALITY: An all inclusive term used in reference to any of the following: failures, malfunctions, deficiencies, defective l items, and nonconformances. A significant condition adverse to quality is one which, if uncorrected, could have a serious effect on safety or oper-ability.

CONFIDENTIAL-SECURITY: Information, the disclosure of which could provide the intelligence required to defeat plant security systems. ,

i i CONTRACTOR: Any organization under contract for furnishing items or services. It includes the term Vendor, Supplier, Subcontractor, Fabricator and subcontractor levels, where appropriate. (1) j CONTROLLED DOCUMENT: A document which is assigned and distributed to an i

individual or organization and requires that individual or organization to ,

be accountable for the document and to acknowledge ' receipt of the document l

l in writing. The distributing agent is responsible for providing the re- ,

I cipients with current revisions to the document and for maintenance of the l return acknowledgment receipts.

CORRECTIVE ACTION: Measures taken to rectify conditions adverse to quality l

and, where necessary, to preclude repetition. (1) '

DESIGN CHANGE NOTICE (DCN): A formal document for authorizing (by ap- l i propriate engineering authority) changes to be incorporated into drawings, :

specifications, system design descriptions, or project design criteria docu- l men ts. Demonstrates and applies change controls responsive to regulatory, ;

policy, and operating requirements.

E DOCUMENT: Any written or pictorial information describing, defining, speci-fiying, reporting, or certifying activities, requirements, procedures or l 1 results. A document is not considered to be a QA Record until it is com- j

~. ; pleted and contains the required signatures. (2) ,

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j ENGINEERING (Engineer): This term refers to the technical responsibilities .

of Recovery Programs, Plant Engineering or A/E's.

l EXTERNAL ORGANIZATIONS: Any organization participating in the project which !

is not a part of GPUN or the TMI-2 on site organization. This term includes !

vendors, A/E's and contractors. I FIELO CHANGE REQUEST: A document which is ge1erated in the field requesting ;

engineering approval of a drawing, specification or procedure change. !

GENERAL OFFICE REVIEW BOARD (G0RB): An advisory board which reports to and f'

gets general direction from the Office of the President and is responsible to provide independent review of major safety issues, foresee potentially l significant nuclear and radiation safety problems and advise the Office of the President on these matters.

IMPORTANT TO SAFETY (ITS): A special classification or category of those !

structures, systems, components and activities that provide reasonable as-surance that the facility can be operated without undue risk to the health and safety of the public. It encompasses the broad class of plant features ,

' covered (not necessarily explicitly) in the General Design Criteria, '

(10CFR50 Appendix A) that cc.itributes in important ways to the safe operation and protection of the public in all phases and aspects of facility l-l operation (i.e., normal operation and transient control as well as accident

! mitigation). It includes " Safety-Related" as a subset. i l

l LICENSEE EVENT REPORT (LER): A report made to the NRC of events and oc- t currences defined in the technical specification which can be generally '

classified as failures of safety-related equipment or events that affect '

nuclear safety. '

i MONITORING / SURVEILLANCE: An act of assuring compliance of activities to i

program requirements by direct observation or record review. Generally, monitoring is performed on site and surveillance is performed at a vendor's '

facility.

PROCUREMENT DOCUMENT: Purchase requisitions, purchase orders, drawings, contracts, specifications or instructions used to' define requirements for purchase.(1) i QA PLAN (Plan): The basic document which describes the method and extent of !

compliance of the QA Program to the applicable regulatory and GPUN require- l E' men ts .

h

-i l QA PROGRAM (Program); The planned and systematic actions which constitute

!! compliance with regulatory quality assurance requirements and the controlled j' documents which describe and prescribe those actions.

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APPENDIX D 4-00 QA RECORD: A completed document that furnishes evidence of the quality of items and/or activities affecting quality. (1)

QUALIFICATION (Personnel): The characteristics or abilities gained through education, training, or experience, as measured against established require-ments, such as standards, or tests, that qualify an individual to perform a required function. (1)

QUALIFICATION (Procedures): An approved procedure that has been demon-strated to meet the specified requirements for its intended purpose. (1) ,

QUALITY CLASSIFICATION LIST (QCL): The controlled document used to record the identification of systems and major components subject to the require-ments of the Recovery Quality Assurance Plan.

SAFETY RELATED: As used in 10 CFR 100, Appendix A, this term refers to those structures, systems or components designed to remain functional for the Safe Shutdown Earthquake (SSE) necessary to assure required safety fun-ctions, i .e.:

1 (1) the integrity of the reactor coolant pressure boundary i (2) the capability to shut down the reactor and maintain it in a l safe shutdown condition; or !

(3) the capability to prevent or mitigate the consequences of I accidents which could result in potential off-site exposures comparable to the guideline exposures of 10CFR. l Safety related is a sub-set of Important to Safety.

SAFETY GRADE: Applies to those structures, systems and components which are readired for the critical accident prevention, safe shutdown, and accident -

l consequence mitigation safety functions defined in Appendix A to 10 CFR Part !

100. l l

SAFETY REVIEW GROUP (SRG): A full time group of engineers, reporting to the Licensing and Nuclear Safety Director who are responsible for performing l independent evaluations and assessments of procedures and activities which i have a direct effect on the safety of the plant.

SPECIAL PROCESS: A process, the results of which are highly dependent on 5 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) 5 SUPPLIER QUALITY CLASSIFICATION LIST (SQCL): A list of Suppliers who have been evaluated by the GPUN Quality Assurance Department for their capa-l bilities to produce or provide items, equipment or services Important to

Safety for nuclear power plants.

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Title APPENDIX D 4-00 TRACEABILITY: The ability to trace the history, application, or location of an item and like items or activities by means of recorded information. (1)

TREND ANALYSIS: A quantitative method of collecting and analyzing non-conformance/ deviation events with the goal of systematically determining progamatic/ procedural weaknesses.

VENDOR: A firm which manufacturers items at an off-site facility and oper-ates 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 requirements. (1) l I

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ATTACHMENT 2 4410-85-L-0176 TEXT CHANGED IN 1000-PLN-7200.02 REV. 4-00 GPUNC Recovery Quality Assurance Plan for Three Mile island Unit 2 PAGE PARAGRAPH CHANGE i Added "GPU Nuclear is responsible for the recovery of TM1 Unit 2."

11 Deleted " Statement of Policy and Authority" Added " LIST OF EFFECTIVE PAGES/REGUHD OF REVISIONS" Changed "Vice President" to " Director" v Paged added 1.0 1.1 Cnanged "Vice President" to " Director" 2.0 1.4 Changed to reflect GPUNC Organization Plan responsibilities 3.0 1.4 Changed " Licensing and Nuclear Safety Director" to

" Director Licensing and Nuclear Safety" 5.0 1.4.3 Changed " Licensing and Nuclear Safety Director" to

" Director Licensing and Nuclear Safety" 6.0 1.4.3(g) Capitilized " Review Significant" 8.0 1.4.6(d) Revised for clarity 1.5 Changed "Vice President" to " Director" 1.6 Changed "Vice President" to " Director" and to reflect GPUNC Organization Plan responsibilities 9.0 1.6.1 Cnanged "Vice President" to " Director" 11.0 1.6.l(j) Changed "Vice President" to " Director" 12.0 1.6.l(m) Added " Quality Assurance" Changed " Audits" to " Audit" 13.0 1.6.1.3 Added " Quality Assurance" Changed " Audits" to " Audit" 14.0 1.6.1.3(e) Added " Quality Assurance" Changed " Audits" to " Audit" 1.6.1.4(a) Changed " weld" to " welding" 1.6.1.4 Former para (b) deleted Former para (e) deleted 15.0 1.6.1.4 Former para (h) deleted Former para (k) deleted Former para (1) deleted Last paragraph added 1.6.1.5 Former para deleted 1.6.1.5 Renumbered from 1.6.1.6

ATTACHMENT 2 4410-d>-L-0176 PAGE PARAGRAPH CHANGE 16.0 1.6.2 Changed "Vice President" to " Director" i

17.0 1.6.4 Cnanged to " Director Licensing and Nuclear Safety" 1.7 Changed "Vice President" to " Director" and to reflect GPUNC Organization Plan responsibilities 18.0 1.7 Changed "Vice President" to " Director" and to reflect GPUNC Organization Plan responsibilities Cnanged to " Director Security" Added " Manager information Management Centers" 19.0 1.7.2 Revised for clarity 20.0 1.7.3 Paragraph added 1.8 Changed "Vice President" to " Director" and to reflect GPUNC Organization Plan responsibilities 21.0 1.8 Changed to " Safety and Environmental Controls Director" Added " Medical Director" 22.0 1.8.1 Changed to " Safety and Environmental Controls Director" Changed to " environmental, and industrial safety and health matters..."

Changed to " System permits, OSHA, NIOSH and..."

Cnanged to " Safety and Environmental Controls Department..."

1.8.l(g) Paragraph added 24.0 1.8.4 Paragraph added 25.0 Figure 1 Revised to reflect current organizations 26.0 Figure 2 Revised to reflect current organizations 27.0 Figure 3 Revised to reflect current organizations 2.2.1.b Added reference to Appendix C 33.0 2.3.2.1 Changed "Vice President" to " Director" 2.3.2.2 Changed to " Director Licensing and Nuclear Safety" Changed "Vice President" to " Director" 4

34.0 2.4 Cnanged "Vice President" to " Director" 37.0 2.8.1.2 Changed "Ljcensing and Nuclear Safety Director" to

" Director Licensing and Nuclear Safety"

, Added ","

4 2.8.1.3 Missing paragraph number 2.8.1.3 added i

Changed " Licensing and Nuclear Safety Director" to

" Director Licensing and Nuclear Safety" 38.0 2.9.2 Changed "Vjce President" to " Director" I

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.- . . _ _ _ ___ _. _ . _ . _ _ _ _ ._ ____m _ _ _.

i j.1 ATTACFNENT 2 4410-65-L-0176 ]

PAGE PARAGRAPH CHANGE j 39.0 2.9.3 Changed "Vice President" to " Director" '

2.9.4 Changed " Licensing and Nuclear Safety Director to 5 l " Director Licensing and Nuclear Safety" ;

1 :

t 40.0 2.9.7 Paragrapn added 1

41.0 3.1.2(b) Paragraph added !

3.1.2(f) Paragraph added i

l 42.0 3.1.2(g) Paragrapn added j 3.1.2(h) Paragraph added i 1 1 44.0 3.2.3.1 Revised for clarity f

t 45.0 3.2.3.1 Cnanged "Vice President" to " Director" l 3.2.3.2 Changed "Vice President" to " Director" l i 47.0 3.3.3.1 Cnanged'"Vice President" to " Director" l l

{ 48.0 3.3.3.2 Changed "Vice President" to " Director" l

3.3.3.3 Cnanged "Vice President" to " Director" i i !

j 53.0 4.3.1.2(b) Changed to " Assure the review and approval of l i

baseline..."

4.3.2 Cnanged "Vice President" to " Director" i 1 i j 58.0 5.1.2.3(g)($) Revised for clarity t i

j 5.1.3.1 Changed "Vice President" to " Director" '

5.1.3.l(a) Added " contracting" i

j 59.0 5.1.3.l(b)

Revised for clarity (

! 5.1.3.l(c) Revised for clarity !

l 5.1.3.2 Changed "Vice President" to " Director" }

i e 61.0 5.2.5.3 (

j Changed "Vice President" to " Director" t I !

, 65.0 6.2.2.2 Changed "Vice Presideit" to " Director" 1 f 67.0 6.3.2.1 Changed "Vice President" to " Director" 1

t

{ 75.0 6.7.2.2 Changed "Vice President" to " Director" i

. 78.0 6.9.2.2 Changed "Vice President" to " Director" i

k j 83.0 6.11.2.2 Cnanged "Vice Pres.' dent" to " Director" i i

} 86.0 6.13.2.2 Changed "Vice President" to " Director" i

k l !

t t

E 5

5

i ATTACHtENT 2 4418.'-85L-U176 PAM PARAGRAPH CHANT 89.0 7.3.2 Changed "Vice President" to " Director" 7.3.3 Changed "Vice President" to " Director" 94.0 8.3.1 Changed "Vice President" to " Director" 96.0 9.2.2( f) Typo " contractual" 97.0 9.2.7 Typo " Audit" 98.0 9.3.1 Changed "Vice President" to " Director" 9.3.2 Changed "Vice President" to " Director" 102.0 Revised for clarity 113.0 R.G. 1.3.9 Former para 3 deleted 115.0 R.G. 1.58(1) tievised for clarity ,

122.0 Changed ";" to "."

123.0 Important to Typo " contributes" Safety 4

l i

f

ML20133K560

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