ML20062F933
| ML20062F933 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/16/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9011280268 | |
| Download: ML20062F933 (2) | |
Text
.
10 CPR 50.90 j
PHILADELPHIA ELECTRIC COMPANY
\\
NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.
WAYNE. PA 19087 5691-
'(as s) eso sooo November 16,11990 i
Docket Nos. 50-277 30-278 Licanoe Nos. DPR-44 DPR-56 C
U.S. Nuclear Regulatory Commi sion Attna Document Cor. trol' Desk h
Washington, DC 20555 l
l
SUBJECT:
Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Regarding Technical Specification Change Request for Audit Report: Distribution
REFERENCE:
(1)
Letter from G. A. Hunger, Jr.1(PECo) to USNRC dated July 11, 1989 (2)
Letter from G. Y. Suh (NRC) to-G. A. Hunger, Jr. (PECo)-
dated September 11, 1990
Dear Sir:
In Reference (1), Philadelphia Electric Company:(PECo)-
submitted Technical ~ Specification Change Request (TSCR) 88-06 which requested a revision to specification 6.5.2 10.c.
In Referenco (2),:
the NRC requested Edditional information.related to'the proposed change.
The purpose of.this letter is to provide the. requested.
information.
Specification 6.5~.2.10.c currently requires that' Nuclear Review Board (NRB) audit reports be forwarded to the " Executive Vice President-Nuclear and the management positions responsible for the areas audited."
PEco proposed that the specification be revisedoto require the audit reports forwarded to the " Corporate Officer (s) and the management positions responsible for'the areas audited."
In Reference (2), the NRC states that the proposed change is not consistent with Standard Technical Specifications (STS).
Our review of NUREG-0123, Revision 3 does not identify an inconsistency with our proposed specification.
Specification 6.5.2.10.c of the
~STS requires audit reports to be forwarded,to the "(Vice President ;
f Operations) and to the management positions 1 responsible for the I g(
b 9011280268 901116 l
PDR ADOCK 0S000277 l0 P
_. - ~
- U.S. Nuclear Ragulatory Commission Novstbar 16, 1990 i
Pago 2 areas audited."
Our Nuclear Group organization includes a Vice President, Peach Bottom Atomic Power Station (PBAPS), a Vice
]
j President, Nuclear Engineering and Services Department and a Vice President, Limerick Generating Station (LGS).
All three report to the Senior Vice President-Nuclear.
(This title was changed from the Executive Vice President-Nuclear.)
Each of these positions is a Corporate Officer.
The "(Vice President-Operations)" referred to in the STS corresponds to the Vice President, PBAPS.
Because the NRB audit reports may encompass areas under more than ene Vice President, the reference to " Corporate Officer (s)" was proposed.
This allows both consistency with the STS and reflects the PECo organization.
In Reference (2), the NRC notes that the currently approved specification does not prohibit:the audit reports from being forwarded to the appropriate Corporate Officers.
Although this is correct, the proposed specification served two purposes: 1) to require that the appropriate Corporate Officer receives audit-reports and 2) to eliminate the requirement for the Senior Vice President-Nuclear to receive audit reports.
Our Nuclear. Quality Assurance procedures require that the Senior Vice' President-Nuclear receive the Executive Summary of the audit reports.
Each Executive Summary contcins a brief description of the audit and all conditions adverse to quality identified in the audit.
In addition, all management corrective action requests (MCARs), which are significant audit findings, are distributed to the Senior Vice President-Nuclear.
Further, conditions adverse to-quality identified in audit reports which are not satisfactorily addressed by the appropriate Corporate Off}a'r, will be forwarded to the Senior Vice President-Nuclear for rec lution.
These measures ensure that the appropriate level of. detail is provided to the Senior Vice President-Nuclear, while also ensuring that the attention of the Senior Vice President-Nuclear is not diluted because of receipt of the entire population of audit reports.
Therefore, in response to the NRC's concern whether information on unsatisfactorily addressed audit findings would provide an equivalent level of awareness as information provided in the audit report itself, we believe that the proposed change will result in greater awareness and involvement by the Senior Vice President-Nuclear.
If you have any questions, please do not hesitate to call.
Very truly yours, N
G. A. Bunger, Jr.
1 Manager, Licensing Nuclear Engineering & Services cc:
T. T. Martin, Administrator, Region I, USNRC J.J. Lyash, USNRC Senior Resident Inspector
....