ML20080B537
| ML20080B537 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 11/23/1994 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9412050274 | |
| Download: ML20080B537 (11) | |
Text
Etttion Eupport DIpirtm*nt 10CFR50.54(a)(3)
PECO ENERGY ecco < erov cemo "v Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne PA 19057-5691 November 23,1994 Docket Nos. 50-277 50-278 50-352 50-353 Ucense Nos. DPR-44 DPR-56 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 Umerick Generating Station, Units 1 and 2 Request for Approval to Change the Quality Assurance Program Description by Transferring the Closure Reviews of Corrective Action Reports
Dear Sir:
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 Quaity Assurance (OA) Program description.
PECO Energy Company is proposing to transfer the review of corrective action reports (CAR) closure from the independent Nuclear Quality Assurance (NOA) organization to the line organization. This proposed change is a reduction in 4
commitment in the NRC approved Peach Bottom Atomic Power Station (PBAPS) and Umerick Generating Station (LGS) OA Program Descriptions.
However, this change does not decrease the PECO Energy Company commitment to 10CFR50, Appendix B. We are, therefore, requesting NRC approval of this change in accordance with 10CFR50.54(a)(3). These commitments are specifically described in Appendix D of the PBAPS Updated Final Safety Analysis Report (UFSAR) and Chapter 17 of the LGS UFSAR. This request is similar to our recent 50.54(a)(3) request to transfer the closure reviews of non-conformance reports (NCRs) from the NOA organization to the t
line organizations. The NCR request was submitted to the NRC on September 8,1994, and approved on October 28,1994.
9412o30274 941123 I
PDR ADoCK 05o00277 P
i November 23,1994 Pag @ 2 We have determined that assigning this leview responsibility entirely to the line organizations will result in more efficient and effective use of resources as well as ensuring that the reviews are done by those personnel who are accountable for the adequacy of decisions made in the CAR process.
Under the current CAR process, NOA reviews CARS prior to closure. This NOA
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review is redundant to the line organizations' d:sposition and review process.
Our experience at both PBAPS and LGS is that the line organizations' execution of this important element has resulted in few NOA review comments over time.
Therefore, the value added by the NOA review is low. The goal of tNs new plan is to ensure continued high quality performance by the line organizations and to eliminate the redundant review by NOA.
NOA is working closely with the line organizations to develop and implement a transition plan for assigning review responsibility entirely to the line organizations. This transition plan will ensure that the quality of CARS at final closure remains at or above the level currently provided. The line organizations will continue to review each CAR to assure the approved disposition adequately addresses the concerns and has been properly implemented, and to identify significant conditions requiring further action. The line organization review of j
quality related CARS is similar to the line organization review of 50.59 l
evaluations. Upon NRC approval, NOA will begin reviewing samples of CARS to l
confirm the adequacy of the line organizations' reviews. The controlling administrative procedures will be revised prior to implementing the change.
As part of the transition plan, training will be implemented to reinforce the line organizations' responsibilities for proper closure review for CARS. The transition plan includes the development of self-assessment criteria for use by line organizations to evaluate their performance. After the transition period, NOA will continue to periodically assess this area as part of their assessment of the OA Program.
The proposed changes to the OA Program Descriptions are provided in Attachments 1 and 2.
If you have any questions or need additional information, please contact us.
Very truly yours, 1
a G. A. Hunger, Jr.
Director - Licensing Attachments
Nov:mber 23,1994 Pcge 3 cc:
T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, USNRC Senior Resident inspector, PBAPS N. S. Perry, USNRC Senior Resident inspector, LGS M. C. Modes, Region 1, USNRC
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ATTACHMENT 1 UMERICK GENERATING STATION UPDATED FIN AL SAFETY ANALYSIS REPORT PAGES 17.2 59 17.2-64 i
1 LGB UFSAR a.
Identify the individuals or groups who shall authorize the corrective action.
b, 2.ccurc O ct the M^?_ cr;2nicction thct hcc rcepcasibility fcr the jer rarfe m e revie:' Of the plerned ccrrective cction.
b.
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Document the cause, if it can be identified.
- c. g.
Identify and document, if possible, the root cause.
- d. g.
The appropriate staff engineer shall review the corrective action and equipment history to determine equipment performance trends, to identify repetitive failures, and to adjust, if applicable, the preventive maintenance program.
17.2.16.4 NQA may identify conditions which require corrective action.
Such conditions shall be reported to responsible management for corrective action in accordance with applicable procedures.
t, ens or9a.na ssMon for significanct
- "*3**
17.2.16.4.1 theS Dependent on factor., such as the " " - of the defic liency, the
- cause, and the c
rective action
- taken, NQA chcIl" fc11c: -up corrective action deficiencies identified by NQA to determine the adequacy and effectiveness of such action.
The felle:-up revicirc to verify proper implencntetier of reported-ccrrective cctienc ch:11 he docuncnted. Dependent upon -the same fa.c+ ors, NG A shall also verify %c effec +wene55 of these correc+ive actions +hrough subsequent assess mgnts or-17.2.16.4.2 surveillan ce 5.
Written procedures shall establish methods for monitoring the prompt resolution and close-out for each of the mechanisms used to report conditions adverse to quality.
17.2.16.4.3 The status of conditions adverse to quality identified by verification, assessments, or surveillances shall be reported to the Senior Vice President and Chief Nuclear Officer; the responsible Vice President; and the appropriate supervision.
17.2.16.5 Corrective action performed in response to an item identified by NQA shall have the documented concurrence of NEM for the adequacy of the corrective action.
h ne organizatim managernad 17.2-59 Rev. 4 Nov./94 l
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ISI/IST i.
Maintenance /I&C j.
Procurement k.
Modifications 1
1.
Radioactive Waste Material m.
Plans - Includes:
Fire Protection Plan Emergency Plan (assessed annually)
Physical Security Plan (assessed annually) radiological Environmental Monitoring Program (assessed annually) n.
Nuclear Engineering l
Other areas that shall be subject to scheduled assessments include preparation,
- review, approval, and control of specifications, procurement documents, instructions, procedures, and drawings; receiving and installation inspections; and vendor activities.
Regularly scheduled assessments may be supplemented by unannounced or unscheduled assessments or surveillances as determined by NQA.
17.2.18.7 l
Assessment and surveillance procedures shall require that nonconformances which are identified be documented in sufficient detail to assure that required corrective action can be effectively j
carried out by the assessed organization. Corrective action may be recommended, as appropriate, by NQA.
17.2.18.8 Responsible management shall ttke the necessary action to correct any identified deficiencies and to report the cause of the deficiency and the corrective action to NQA.
Unless justified in writing as not appropriate, corrective action intended to prevent recurrence shall also be taken and reported.
17.2.18.9 i
When corrective 2.cticr mcacurec cre indiccted, fc11c,; up3 or rc-ccccccmentc of cppliccble crecc chcIl bc conducted, tv oaaum l
impicmenteticr end effectivenecc cf corrcctive cctionm,
- n. pen dent upon factors such as ike c'.sd.fi c8 occ-of de R c. e,,cles *.ded. h ed "Ch n 5S
$m8^ $
N Q C2 A ' % cut.c G^d C 8 ff' O C
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' amp eMn surve.H a nce cf 8PP,.***9;a area $ Shall be cond,3c4ed +o assa e r
a nd eMect's ve n e sS of cor r e cke, d. ans.
17.2-64 Rev. 4 Nov./S4
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ATTACHMENT 2 PEACH BOTTOM ATOMIC POWER STATION UPDATED FINAL SAFETY ANALYSIS REPORT i
PAGES D.11-34 l
D.11-36 f
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PBAPS l 17.'2.16.3 NQA through its activities may identify conditions which require corrective action and shall report these conditions to Station Management for corrective action in accordance with applicable procedures.
17.2.16.4 The status of noncompliances and significant nonconformances identified by NQA shall be reported to the Senior Vice President and Chief Nuclear Officer; the responsible Vice President; and the appropriate supervision.
17.2.16.4.1 The assessed organization shall address corrective j
action and corrective action to prevent recurrence and provide a scheduled completion date for corrective action and corrective action to prevent recurrence.
17.2.16.4.2 The assessed organization shall complete corrective actions by the committed completion date end nctify NOA cf completier.
Qeet.sch *'*
17.2.16.5 NOA fellcW3-up corrective action to verify)b "
completion cnd determine the adequacy snd cffectivenese of cuch oction.
J 17.2.16.6 Corrective action taken in response to an item identified by NQA personnel reported in accordance with Section 17.2.15.4 of this Program is reviewed or approved by NQA.
17.2.17 Ouality Assurance Records 17.2.17.1 Sufficient records shall be maintained in accordance with the administrative and implementing procedures to provide documentary evidence that activities affecting quality are performed adequately and in compliance with the PBAPS QA program.
The requirements shall include collection, filing, storing, maintenance and l
disposition of records that are required by codes, standards, specifications, or regulatory requirements.
PBAPS QA records shall include operating logs, maintenance and modification procedures, and related inspection results, reportable occurrences, and other records required by the PBAPS Technical Specifications.
The l
procedures to be employed to perform the required l
activities shall be planned and documented.
17.2.17.2 The significance of the event covered by a record type and the contribution of the record to the l
ability to reconstruct significant events shall be i
considered in establishing retention periods.
l D.11-34 Rev. 12 l
7/94
e INSERT A 17.2.16.5a Corrective action performed in response to an item identified by NQA shall have the documented concurrence of line organization management for the adequacy of the corrective action.
17.2.16.5b Dependent upon factors such as the significance of the deficiency, the cause and the corrective action taken, line organization management shall review the corrective action for the deficiencies identified by NQA to determine the effectiveness of such action. Dependent upon the same factors, NOA shall also verify the effectiveness of these corrective actions through subsequent assessments or surveillances.
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l PBAPS Physical Security, Emergency Plan, Procurement, Health Physics, Chemistry, Radioactive Waste / Material, and In-Service Inspection Activities are assured through a program of l
l planned and periodic assessments, surveillances, l
and corrective action as required by findings.
17.2.18.1.1 Assessment, as implemented by of this Quality Assurance Program, complies with the guidance provided in ANSI N45.2.12 - 1977 as described in Appendix 17.2A.
l l 17.2.18.1.2 The Assessment Program will involve compliance-i based, performance-based and/or technical-based l
assessments or a combination there of as appropriate.
Where it is practical and i
appropriate (e.g., operational assessments), the I
assessments will be'primarily performance-based and/or technical-based assessments.
l l 17.2.18.2 Assessments and surveillances are performed by personnel from Nuclear Quality Assurance.
NQA may request assistance of personnel from other disciplines or technical specialists who are l
independent of areas being assessed.
17.2.18.2.1 These personnel are trained and indoctrinated in quality assurance policy and implementing l
assessment procedures and forms.
l 17.2.18.3 Assessments and surveillances are performed on the l
basis of the status and importance to safety and in accordance with written procedures to confirm' by objective evaluation of werk areas, activities, processes, items, reviews, approvals and records, that the PBAPS QA Program is implemented in accordance with instructions, procedures and drawings.
17.2.18.4 The results of these assessments and surveillances shall be documented by the Director, NQA, or an appointed designee and reviewed by management j
having responsibility in the area assessed, and distributed to appropriate Nuclear management and other concerned supervision.
l 17.2.18.5 The Director, NQA, or an appointed designee, is responsible to identify overdue corrective action of noncompliance to the appropriate responsible management.
17.2.18.6 L'hcn correcti'>c Octicn meccurcc Orc indicated, l
reacccccrentc cr verificat4en -Of appbicabic arcas>
see West RA4e D.11-36 Rev. 12 7/94
-ir conducted to accure implementation and effectivenesc of corrective cctions, 17.2.18.7 Surveillance is provided, as directed by the Director, NQA, or an appointed designee, to assure l
quality during the work activity.
17.2.18.8 In addition to the surveillance of quality-related activities, formal assessments are conducted on l
the basis of status and importance to safety.
The frequency and scope of assessments are in l
accordance with the NQA Procedures.
17.2.18.9 The Director, NQA, is responsible for the l
performance of assessments and surveillances of the activities to determine the adequacy and effectiveness of the QA Program.
17.2.18.10 Assessments required by the PBAPS Technical l
Specifications are conducted ursder the cognizance of the Nuclear Review Board.
17.2.18.11 Elements of NQA shall be assessed annually by an independent assessment organization.
17.2.18.12 The NDE program shall be assessed by NQA to assure the independence of the personnel performing the l
activity.
17.2.18.13 NQA shall assess the Software Quality Assurance l
Program to assure adequacy of implementation.
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1 D.11-37 Rev. 12 7/94 l
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