ML20064H088
| ML20064H088 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Hope Creek, Limerick  |
| Issue date: | 03/09/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20064H092 | List: |
| References | |
| NUDOCS 9403170148 | |
| Download: ML20064H088 (4) | |
Text
Station Sup; ort Dtptrtmtstt e
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March 9,1994 Docket Nos. 50-277 50-278 50-355 50-353 License Nos. DPR-44 DPR-55 NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
SUBJECT:
Peach Bottom Atomic Power Station Units 2 and 3 Limerick Generating Station Units 1 and 2 Additional Information on Request for Approval to Change the Quality Assurance Program Description by Transferring the In Line Reviews of Administrative Procedures
REFERENCES:
1.
Letter from Mr. George A. Hunger, Jr. to U.S. Nuclear Regulatory Commission dated October 4,1993 2.
Acknowledgement Letter from Mr. J. P. Durr to Mr. D. M. Smith dated November 5,1993 3.
Letter from Mr. J. P. Durr to Mr. D. M. Smith dated January 14, 1994
Dear Sir:
The reference letter 3 requested additional information for PECO Energy Company's request to transfer in line review of administrative procedures from Nuclear Quality Assurance (NOA) to the line organization. Specifically, Reference 3 requested that we describe how the intent of ANSI N18.7-1976, page 16, which states " Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than the originator...", is being met and to define the qualification requirements and organizational independence of the individual performing the procedure review.
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March 9,1994 Page 2 The intent of ANSI 18.7-1976, page 16, will be met by the commitments put into new paragraphs in the Peach Bottom Atomic Power Station (PBAPS) Updated Final Safety Analysis Report (UFSAR), paragraph 17.2.5.6, and Limerick Generating Station (LGS) UFSAR, paragraph 17.2.5.11, which are contained in attachments 1 and 2 respectively. These commitments will be implemented by procedures AA-C-5 " Preparation and Control of Procedures / Guidelines" and A-C-1, " Procedures Writer's Guide".
The individuals reviewing administrative procedures will be Station Qualified Reviewers (SQR) who are described in Technical Specifications or Qualified Reviewers (QR.) selected by management and trained in quality assurance program requirements and policies. The selection of these individuals will be based on their e.xperience and area of expertise. Administrative procedures that are required to be reviewed by the Plant Operations Review Committee (PORC) will be reviewed by SORS for inclusion of quality program requirements. Off-site administrative procedures that are not reviewed by PORC will be reviewed by QRs for inclusion of quality program requirements.
The qualifications for SQR and QRs for review of administrative procedures will be the same. These qualifications will be contained in PD and LGS administrative procedures and common guidelines. The qualifications of the SQR/QRs meet the requirements of ANSI /ANS 3.1-1981 Section 4.7.2 at PBAPS and ANSI /ANS 3.1-1978 Section 4.7.2 at LGS or similar experience as allowed by Technical Specifications.
Currently, the PBAPS and LGS UFSARs require organizational independence in review of Administrative Procedures in that the review is performed by NOA.
This independence is not required by regulation. The proposed procedure review program has been developed to assure functional independence by requiring that the person who generated the procedure or revision is not also the reviewer of the procedure. The proposed procedure review process parallels the industry accepted programs for 10 CFR 50.59 cvaluations and design verification reviews.
The 10 CFR 50.59 evaluations and design verification reviews are significant reviews with a direct safety impact, and these review processes have been effectively implemented.
PECO Energy has established a transition program to ensure that the review of procedures remain at the current high quality. This transition program will require a dual review by the SQR/OR (in line) and NOA (parallel). This dual review will continue until it is established that the SQR/QR review is effective.
NOA will continue to audit the procedure revision process to assure the quality of the reviews remain high during and after the transition period.
PECO Energy recognizes that the transfer of in-line review of administrative procedures from NQA to the line organizations is a significant change and chose this strategy after extensive research and planning. This proposed change in the PECO Energy QA Program will provide greater effectiveness in the Administrative Procedure Review Program because of the following:
March 9,1994 Page 3 The SOR/OR review process is an established program which has direct involvement with PORC and line management.
The SOR/OR reviewers are required to have a high level of experience and expertise.
The SOR/OR procedure review program is subject to the self assessment process.
NOA will continue to audit the procedure review program.
The line organization (which includes SOR/ ors) shall be accountable for the inclusion of NOA program requirements in the administrative procedures.
SOR/ ors will be more effective i1 identifying trends in both technical and quality related deficiencies.
A monitoring program, the results of which will be reported to senior management, will measure the quality of administrative procedures reviews during transition from NOA to SOR/OR review (during the transitional phase, both NOA and SOR/ ors will review the administrative procedures).
SOR/ ors will be required to use criteria approved by the NCA organization in the review of administrative procedures (this criteria will be incorporated into the controlling procedures).
The additional proposed changes to the OA Program descriptions in the PBAPS UFSAR Appendix D, Rev. 11,07/93, and the LGS UFSAR, Chapter 17.2, Rev. 3, 11/93, are provided in attachments 1 and 2 respectively.
These proposed changes are scheduled to become effective upon your approval; therefore, we are requesting your prornpt review and approval, if you have any questions or need additional information, please contact George J. Siefert (610) 640-6768 of my staff.
Very truly yours, h<
George A. Hunger, Jr.f,ctor
, Dir Licensing Section Attachments
March 9,1994 Page 4 cc:
T. T. Martin, Administrator, Region I, USNRC w/ attachments W. L. Schtnidt, USNRC Senior Resident Inspector, PBAPS w/ attachments N. S. Perry, USNRC Senior Resident Inspector, LGS w/ attachments M. C. Modes, USNRC Region I, w/ attachments T
.