ML20077L715

Submits Proposed Change to QA Program Description for Plants

ML20077L715
Person / Time
Site:	Peach Bottom
Issue date:	11/14/1994
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077L707	List: ML20077L715
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 9501110486
Download: ML20077L715 (13)

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.$ . 10CFR50.54( )(3)(i)

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PECO ENERGY 5 3,$"L, 965 Chesterbrook Boulevard { */ g.gf p Wayne. PA 19087-5691 November 14,1994 Docket Nos. 50-277 50-278 ' i License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission i

Attn: Document Control Desk Washington, DC 20555 i

Subject:

Peach Bottom Atomic Powcr Station, Units 2 and 3 ,

Request for Approval to Change the Quality Assurance l Program Description by Elimination of the independent Safety Engineering Group Composition Requirement

Reference:

Letter from G. A. Hunger, Jr. (PECO Energy) to USNRC  ;

dated November 14,1994

Dear Sir:

i This letter is submitted in accordance with 10CFR50.54(a)(3), which requires prior NRC approval for any change which reduces the commitments in a previously accepted Quality Assurance Program description (OADP). PECO Energy Company (PECO Energy) is proposing to eliminate the Independent Safety Engineering Group (ISEG) composition requirement while maintaining the independent technical review function. Individuals performing independent technical review will report to senior management of the Peach Bottom Atomic Power Station (PBAPS) Quality Division Manager (ODM) in lieu of a dedicated manager, The reviews will be performed by -

several personnel who are independent of the plant management organization. Detailed recommendations will be made directly to the affected organization with copies of the recommendations to the Senior Vice President and Chief Nuclear Officer and the Director -

Nuclear Quality Assurance (NOA) in lieu of making the recommendations to the Senior Vice President and Chief Nuclear Officer. The qualification for individuals performing the independent technical review function can be either degreed engineers as stipulated in NUREG-0737,

" Clarification of TMl Action Plan Requirements," or non-degreed individuals who have at least eight years of related experience.

NUREG-0737 specifies the staffing levels for an ISEG. The staffing requirement for five dedicated engineers is burdensome to a utility because it restricts the capability to utilize resources to their maximum advantage and does not result in an increase in the protection afforded to the health and safety of the public. The proposed change would provide flexibility to accomplish the ISEG review function. The ISEG and Quality Assessment Section currently perform their oversight assessment functions independently from one another. The proposed change would integrate the independent review function into the overall audit and review -[

function under the direction of the PBAPS ODM resulting in better uti!!zation and coordination of resources. Overs 2ght effectiveness would be enhanced by allowing greater flexibility in focusing resources on areas deemed by the ODM.

The purpose, scope and thoroughness of independent technical reviews will not be affected.

Management oversight of the Independent technical review function will not be diminished.

9501110486 950106 PDR ADOCK 05000277 P PDR

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. November 14,1994

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The changes constitute a reduction in commitment to the Quality Assurance Program Description (OADP) (included or referenced in Section 17.2 of Appendix 0 of the PBAPS UFSAR); however, the reduction in commitment does not reduce the PECO Energy commitment to quality or compliance with 10CFR50, Appendb5 B. Transferring the responsibility for the independent technical review function to the ODM will have no adverse impact on the independent technical review function. The ODM position is at a higher management level than the ISEG rnanager position and is directly responsible for the adequacy of site oversight. The ODM is already required to satisfy the minimum professional level experience requirements stipulated in ANSI N18.1-1971. Moreover, the NRC has approved a three oerson ISEG to report ~

to the site OA Manager for GPU Nudear operated plants. Thus, precedence exists for replacement of the ISEG Manager with the PBAPS ODM to satisfy the intent of NUREG.0737 with respect to supervision of personnel performing the independent technical review function.

The current PBAPS UFSAR staffing for ISEG is five dedicated full time engineers, one of which is the ISEG Manager. The ISEG Manager provides primarily a supervisory function for the four remaining ISEG engineers. The proposed change requests that the independent technical review function be performed by several (i.e., three or more) individuals reporting to the PBAPS ODM. Improvements since the ISEG was implemented at PBAPS have resulted in less need for a five person group to accomplish the independent technical review function. For example, the Operating Experience review function which includes review of NRC and INPO issuances was originally assigned to ISEG, but has been transferred to line organ!zations. The Experience Assessment Group trends events and event causes via the Performance Enhancement Program which relieves ISEG of this task ISEG now independently analyzes and uses data from the Performance Enhancement Program. Improved plant computers and the development of station performance indicators have reduced the ISEG effort needed to analyze unit performance.

PBAPS self-assessment practices have improved significantly. This results in less ISEG effort to independently assess operational and maintenance issues. INPO has established and has a fully developed function of analyzing and highlighting industry events. This serves to reduce the ISEG effort in this area. NOA and ISEG functions include observations of line performance in this area from time-to-time. Therefore, the functions of ISEG originally performed by four dedicated engineers can now be performed by several personnel who are not dedicated to this function. Individuals performing the independent technical review function will still remain independent of the power production management organization. .

PBAPS UFSAR Section 13.8.6,

• Independent Safety Engineering Group (ISEG),* commits to more experience for PBAPS ISEG personnel than specified by NUREG-0737. This commitment was made as part of a settlement agreement between PECO Energy and the Commonwealth of Pennsylvania. All restrictions on a!!erations to this commitment terminated on February 27, 1993. Degreed individuals performing the independent technical review function will satisfy the minimum experience specified in NUREG-0737 for degreed personnel. The proposed change would also allow non-degreed personnel with at least eight years of related experience to perform the independent technical review function. Performance of the independent technical review function by non-degreed individuals has been approved at Clinton, Beaver Valley and Diablo Canyon.

The proposed changes are consistent with the recommendations contained in the NRC's Regulatory Review Group Report (Final Report, August 1993) which included an examination of PBAPS Unit 2 TS Section 6.2.3.1, ' Independent Safety Engineering Group (ISEG).* The Regulatory Review Group assessment noted that removal of this function through the TS amendment process could be pursued because an ISEG is not a regulatory requirement for Peach Bottom. A TS Change Request was transmitted by the reference letter to accomplish removal of ISEG from PBAPS TS. Additionally, on September 29,1994, TS Change Request No.

93-16 was submitted to adopt the TS in NUREG-1433, " Standard Technical Specifications General Electric Plant, BWR/4.* NUREG-1433 permits the ISEG function to be performed as a staff function under the reviews and audits program. This results in relaxation of the five-person staffing requirement and permits more flexible methods of performing the reviews.

4 November 14,1994

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In condusion, while considered a reduction in commitment in the OADP, these changes will not reduce the effectiveness of the quality assurance program.

The proposed changes to the OADP are provided,in Attachment 1. Because approval of these OADP changes would improve resource allocatlon, we request the NRC's prompt attention to approve these changes by January 3,1995. If you 6 ave any questions or need additional information, please contact us. .

Very truly yours, b.O.4 Ly .p.

G. A. Hunger, Jr.

Director - Licensing l

JLP/est Attachment cc- T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS R. R. Janati, Commonwealth of Pennsylvania M. C. Modes, Chief, Materials Section, Region I, USNRC t

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ATTACHMENT 1 b

Proposed Change to the Quality Assurance Program Description for Peach Bottom Atomic Power Station .

Units 2 and 3 j 5

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4 PBAPS l 17.2.1.2.2 Station Support ,c s

.~v The organization, duties, and responsibilities of l Station Support are-described in Section 13.

17.2.1.2.3 Nuclear Ouality Assurance - (Exhibit IV)

Nuclear Quality Assurance (NQA) is responsible for administering the overall Nuclear Quality Assurance Program of the Nuclear Generation Group.

l Nuclear Quality Assurance is headed by a Director, who reports directly to the Senior Vice President l and Chief Nuclear Officer. NQA is composed of the Peach Bottom Quality, Limer'.ck Quality, and +he Corporate Nuclear Quality Divisionse and the Perch --fL_

htter end I.ir.crici Ind;;panctJaiicty E"~incerin~ 'L-Cr2un Reste.u er's N d e.: A simila sub ; & l is bein (4:le  ?

s-The Direc rche 8 # m +k. Limartek Ge>~<I-i s+a+tm J.ehe+.

o , NQA, s e w l

responsibilities and authorities.

1. Formulate, develop, and establish Nuclear Quality Assurance policy in areas such as, Operations, Maintenance, Modifications, In-Service Inspection / Testing, Surveillance --

Testing, Fuel Handling, Health Physics, _ , ,

Chemistry, Radiological and Environmental Monitoring, Fire Protection, Physical Security, Emergency Preparedness, Radioactive Waste and Material, Training, Procurement, l Assessments, Records, Nonconformances, and .

Corrective Action.

2. Administer and coordinate the Nuclear Quality Assurance Program (NQA Program).

3. Furnish overall direction for implementing the NQA Program.

4. Provide recommendations for correcting program deficiencies or improving the implementation of the NQA Program, as appropriate.

5. Require tracking and verification of corrective action and problem resolution for all QA-identified Corrective Action Requests l (level 2 & 3 CAR issues). Require that deviations be tracked in accordance with Administrative Procedures. _,

6. Direct cessation of work when such work is --

l l considered by the Director, NQA, to be a D.11-2 Rev. 12 7/94

PBAPS

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serious quality degradation. This stop work authority shall be delineated in applicable procedures.

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7. Determine the on-goi_ng status and adequacy of the QA Program through regular review of QA Assessments, Surveillances and Verifications, identification and investigation of problem areas, determination of timely and effective steps taken to correct deficiencies, and the evaluation of general plant QA/QV performance through such other inputs as are available or arc deemed necessary to make a reasonably objective and confident judgement.

8. Apprise the Senior Vice President and Chief Nuclear Officer; the Vice President, Station support, the Vice President, Peach Bottom Atomic Power Station; and the Nuclear Review Board periodically of the status of the Quality Assurance aspects of Peach Bottom Atomic Power Station operations, and immediately of significant problems affecting quality.

9. Ensure that personnel involved in implementing l the QA procedures are trained and/or qualified, as appropriate.

10. Contract for QA/QV consulting services as l necessary.

11. Provide support for QA/QV training and l

qualification programs, as required, for implementation and execution of the QA Program. l

12. Establish and maintain the Evaluated Vendors l List (EVL) of quality and evaluated suppliers in accordance with administrative procedures.

13. Perform assessments /surveillances of vendor l activities as appropriate.

14. Establish, administer, and coordinate the l Nuclear Quality Assurance Program associated with modifications, and capital equipment installation or renewal.

15. Assess and verify the adequacy and l effectiveness of activities covered by the QA  !

program. l 4.s.

17.2.1.2.3.1 Peach Bottom __Ouality Division ,

D.11-3 Rev. 12 7/94 j

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, PBAPS The Peach Bottom Quality Division is under the supervision of a Manager, who reports to the j Director, Nuclear Quality Assurance. The Division is. composed of three sections: Assessment, Quality verification, and Quality Support. The Manager is responsible for:

1. Providing technical and administrative direction to the Division;

2. Providing single point accountability for all site quality activities,

3. Reviewing and approving site generated Administrative Procedures, or.J L,uhtpri,ded ~7sel,,,;at Review l 4. Formulating the Site AssessmentA Programp

5. Conducting on-site assessments, surveillances and verifications.

6. Identifying specific and programmatic deficiencies and tracking these items until they are fully resolved, in accordance with Administrative Procedures.

7. Performing trend analysis; b x.

l 8. Providing periodic reports to the Director,

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NQA, on the status and adequacy of the Nuclear Quality Assurance Program and advising of any problems requiring special attention; /,

9. Approving Stop Work Directives.

10. Providing and maintaining a qualified and suitably trained quality assurance staff to carry out required project and staff

. functions.

l 17.2.1.2.3.1.1 Assessment Section The Assessment Section is under the supervision of the site Quality Division Manger. The Manager has the following responsibilities:

1. Provide administrative supervision of the activities of the section.

2. Direct the scheduling, planning, and performance of assessments and surveillances, in accordance with written procedures to assure compliance with the QA Program and l

Technical Specifications.

D.11-4 Rev. 12 7/94

PBAPS

9. Maintenance of NQA personnel qualification l

.a records.

m 2.2_2.9 9 Q ach Bottom Indenandar.t C;fetV "neineer.ind7 roup each Bottom Aud p;r.3^"* Safety Engineering Group (ISEG) composition and re's'fohnililtTH-itiac o Q described in Section 13.8.6 17.2.1.2.3.3 Coroorate Nuclear Ouality Division The Corporate Nuclear Quality Division is under the supervision of a Manager who reports to the Directer, Nuclear Quality Assurance. The Division consists of two sections: Assessment and Administration.

The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities. This includes:

1. Manuals and procedures,

2. Vendor assessments and surveillances

3. Training, l I

4. Oversight of the quality activities of Nuclear Support

5. Identification of specific and programmatic l deficiencies and tracking of these items until '

they are fully resolved,

6. Performing trend analysis, l

7. Conducting internal assessments and l  ;

surveillances at the corporate offices, l

8. Single point of accountability for all l Corporate Nuclear Quality (CNQ). ,

17.2.1.2.3.3.1 Assessment Section The Assessment Section is under the supervision of the Manager, Corporate Nuclear Quality Division.

The Manager's responsibilities include:

1. Providing administrative supervision and technical direction of the activities of the l section. l 1

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." i D.11-7 Rev. 12 7/94 j

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17.2.2.9 The PBAPS QA program is documented by written policies, procedures and instructions and shall be .

carried out throughout the life of the plant.

17.2.2.9.1 Th'e Corporate Nuclear 6uality Division Manager reviews and approves all"non-site generated Administrative Procedures that implement the QA ,

Program.

17.2.2.9.2 The administrative and implementing procedures and instructions pertaining to quality-related activities are written to accomplish those activities with appropriate equipment under suitable environmental conditions.

Q;4y Division 40 ens.ww -+he ZsJpJe# Te4;wf RsJew f% yam l 17.2.2.10 TheAManager u Tndep^

is responsible fer[f.dcat Safctyplant reviewing Euwinaerint operatinge-mup ,

characteristics, NRC issuances, and other appropriate resources of plant design and operating experience information that may indicate areas for improving plant safety, and for inputting and closure of -Ises recommendations in the Plant Information S.-o,n +he.se.

Management raiews. ~rke L.dependeaf Te gstem (PIMS)pt re.s u l +-

ical Runsw Po 9,om :s 17.2.2.11 hdNatYn[p$YdNn"nei*s3'ectionandtraining complies with PBAPS Technical Specifications and -

is in accordance with ANSI N18.1 - 1971.

17.2.2.11.1 The training program assures competent material selection and instruction. The retraining program is designed to maintain current operator competence and uses current NRC recertification.

proposals as c guide. Training aids and materials are utilized. Formal classroom and individual study periods are scheduled. Evaluation of trainee's progress is documented.

17.2.2.11.2 The training program also includes provisions for non-licensed personnel and general employee indoctrination. General Employee Training includes: quality-related plans and procedures appropriate to the specific job related activities; radiological health and safety (ALARA Program), industrial safety; plant controlled access areas and security; and the use of protective clothing and respiratory equipment.

Personnel performing quality-related activities are trained and qualified in the principles and techniques of the activities being performed.

These areas include technical training, on-shift training, qualification or certification requirements, and qualifying tests as appropriate for the job position. Administrative procedures -

delineate the scope, objectives and methods D.11-14 Rev. 12 7/94

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I I LNERICK F.ACH BOROM CORPORATE OUALITY OUAUTY NUCLEAR OUALITY DMS10N OMS 10N OM90N ,

MANAGER MANAGER MANAGER 5

ASSESSMENT ASSESSMENT ASSESSMENT

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SUPERWTENDENT [ MANAGER SUPERNTENDENT SurronT SECnow -

SurrORT SECnow ,

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ORGANIZATION CHART NUCLEAR QUALITY ASSURANCE PECO Energy Company EXHIBIT N a n m.

- - . - - . -. .. . . . - . ... - .- -. - .. -- .._.. -- . . - . - - - . - . . - . _ _ - . . . . = _ - - - . _ , . _ . . . . . . . - _ . _ .

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4 PBAPS also processed by the OEAP. Experience items are evaluated and corrective actions initiated as appropriate. Such

's, actions are entered into the Commitment Tracking Program to jy ensure proper closure. .The status of all operating

/ experience information being reviewed, as well as actions being taken to address evaluated items, are reported to management frequently. __

13.8.6 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)/

Independent Safety Engineering Group (ISE performs in ependent reviews of plant operations. The IS examines uni operating characteristics, NRC. issuan s, industry advis les, Licensee Event Reports, and ot r sources of l unit ign and operating experience l'hfo ation, including imilar design, which may, dicate areas for l plants ofimproving

• t u safety.

The PBAPS ISEG 1 composed of at 1 st five dedicated, full-time engineers inc ding the IS Superintendent, located onsite. Each has bachelo 's degree in engineering or related science. The perin endent shall have at least 6 years of full-time rcial nuclear experience. The engineers in the PBAPS IS ach have a minimum of 2 years of full-time commerci nuc ar experience. Not more than one of the members sha have le than 3 years of full-time commercial nuclear perience. luding the experience of the Superintendent, he members coll tively shall have at least 16 years of ull-time commercial uclear experience.

The PBAPS IS reports to the General anager - Nuclear Quality Assur tee.

The ISEG is responsible for maintaining surveill ce of unit activitie to provide independent verification t at these activiti a are performed correctly and that htman e ors are reduced as much as practical. The ISEG is not res nsible for si n-off functions.

L The ISEG is responsible for performing independent rev ews 1 I of lant operations, reviewing operating experiences wh ch mj indicate the need for improvements, recommending need '

provements, and advising management on the overall qualit and safety of operations.

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13.8-9 Rev. 9 l 01/91

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PBAPS ,

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I l e ISEG makes detailed recommendations for revised  !

pr dures, equipment modifications, maintenance activit ,

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operat activities .or other means of imps ovi unit

. safety. recommendations shall be submitted ,

ough the General Mana -

Nuclear Quality- Assurance ,

o the Senior '

Vice. President - clear. '

Also, because the Pe Bottom a imerick plant designs l are similar, many of t L rick ISEG's assessments, i particularly in the areas esign, training, corrective maintenance and, to some ent, o ations, may be directly applicable to Peach ottom and vi versa. The Limerick ISEG is similar n composition to has responsibiliti similar i.

as the Peach Bottom ISEG.  :

l The IS Superintendent reports to the General M er -

\ Nucl Quality Assurance on matters of both a routine a a s ty-related nature. i l

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ATTACHMENT 1 t 13.8.6 INDEPENDENT TECHNICAL EtEVIEW PROGRAM  ;

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An Independent Technical Review Program shall be established to satisfy the following: j 13.8.6.1 The independent Technical Review Program responsibilities shall encompass:

a. NRC issuances, industry advisories, Ucensee Event Reports, and l other sources that may indicate areas for improving plant safety, t

b. Internal and external operating experience information that may indicate areas for improving plant safety;  ;

c. Plant operating characteristics, plant operations, modifications, ,

maintenance, and surveillance to verify independently that these  !

activities are performed safely and correctly and that human errors  !

are reduced as much as practical; and  ;

d. Making detailed recommendations to the Directors of the affected  :

organizations, with copies t6 the Director-Nuclear Quality Assurance ,

and the Senior Vice President and Chief Nuclear Officer for revising i procedures, equipment modifications or other means of improving  :

nuclear safety and plant reliability. l

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13.8.6.2 The Independent Technical Review Program shall utilize several on-site  ;

personnel who are independent of the plant management chain to perform  ;

the reviews. These individuals shall report to the PBAPS Site Quality  ;

Division Manager. The PBAPS Site Quality Division Manager is responsible to ensure the Independent Technical Review Program is implemented as  :

indicated in section 13.8.6.1. The Site Quality Division Manager shall utilize l information obtained as part of this program as input to advise management  !

on the overall quality and safety of operations.

l 13.8.6.3 The written record of technical reviews shall be reported to, at a minimum,  :

the Senior Vice President and Chief Nuclear Officer, the PBAPS Station Vice President, the Nuclear Review Board, and the Director-Nuclear Quality Assurance. Records of the activities of the independent Technical Review  !

Program shall be prepared and forwarded each calendar month to the Director-Nuclear Quality Assurance.

13.8.6.4 Personnel performing reviews pursuant to section 13.8.6.1 shall have at ,

least 3 years of related experience and a bachelor's degree in engineering or a related field; or shall have at least 8 years of related experience. The PBAPS Quality Division Manager shall meet the requirements of ANSI N 18.1-1971.

g.13.8-9