ML20082J423
| ML20082J423 | |
| Person / Time | |
|---|---|
| Site: | Limerick |
| Issue date: | 04/06/1995 |
| From: | PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| Shared Package | |
| ML20082J403 | List: |
| References | |
| NUDOCS 9504180243 | |
| Download: ML20082J423 (25) | |
Text
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l UMERICK GENERATING STATION.
UNIT 1 AND UNIT 2 l
l Docket Nos 50-352 50-353 1
i
,1 License Nos.
. NPF-39 1
.)
CHANGES TO THE QAPD' Supplemental Pages Resulting from a NRC Request for AdditionalInformatiorf i
Independent Technical Review - 8 Pages NRB Review and Audit - 16 Pages 1
l l
9504180243 950406 PDR ADOCK 05000352 p
P.I of f LGS UFSAR AudiYs shall include verification of compliance and effectiveness of implementation of programs, procedures, regulations, and license Written reports of such audits provisions in the areas audited.
shall be transmitted for appropriate action to the Senior Vice President and Chief Nuclear Officer and management having responsibility in the areas audited within 30 days after completion of the audit'by the auditing organization.
Audits shall be performed by the Nuclear Quality Assurance Department or by specially selected groups or individuals who have no immediate responsibility for the activity they audit and do not, while performing the audit, report to a management representative who has immediate responsibility for the activity being audited.
follow-up action, including re-audit where appropriate, shall be taken when deficiencies are noted.
Timely The audit program and schedules shall be reviewed semi-annually by the NRB to ensure that the audits are being performed in accordance The audit program is described j
with the Technical Specifications.
l_ECt/^hCAL RE VIDO FUNCDOAl in Chapter 17.
13.4.5 INDEPENDENT SM4iMPY-BN95tHHHtTNG GRGUS-g N
lor to j
pendent Safety Engineering Group was established An I of plant N
initialx uel load of Unit 1 to perform independent revie operation The ISEG examines unit operating charact stics, NRC j
(issuances, 1 dustry advisories, Licensee Event Rep s, and other l
sources of u t design and operating experie e information,
/
/ including units f similar design, which may ' dicate areas for (s
1 s
[
improving unit sa y,
i The LGS ISEG is comp d of at least e dedicated, full-time engineers / scientists, in uding the S rintendent - ISEG, located f
on-site.
Each ISEG membe as a b elor's degree in engineering
(
3 two years of professional level N
or related science and a min m
experience in their respective elds.
The LGS ISEG Manager has a 1
minimum of six years of exp en in the nuclear field.
The LGS s
ISEG reports to the Dire t - Nuc' ar Quality Assurance.
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The ISEG is responn ble for mainta ng surveillance of unit activities to p
Gide independent v
ification that these l
activities are erformed correctly and at human errors are reduced as mu as practical.
The ISEG i ot responsible for lj sign-off fu tions.
/
The ISE s responsible for performing independent views of plant ndicate the ons, reviewing operating experiences which ma opera nee for improvements, recommending needed improv
- nts, and a
ising management on the overall quality and s
ety of
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The haepended Technical Review Fhnchen is descad I
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13.4-8
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- f. 2-o f 8 LGS UFSAR Th LGS ISEG makes detailed recommendations for revised procedu equi ent modifications, maintenance activities, oper ions activit' s or other means of improving unit safety Such 1
recommend ons are submitted directly to the affected l
Nu ear Quality organization with copies to the Director t
Assurance and e Senior Vice President - Nuclear l
The LGS ISEG perfo s the functions of a independent safety
[
engineering group as d cribed in Item I.B
.2 of NUREG-0737.
The average years of nuclear-lated experie e exceed the 1 to 2 years l
1 of nuclear-related experien stated section 13.4 of the SRP.
i When members of the LGS ISEG are laced, the replacements have a minimum of 2 years' experie e i their field and 1 year of nuclear-related experience.
Also, because the LGS nd PBAPS designs ar similar, many of the l
PBAPS ISEG's asses ents, particularly in t areas of design, l
training, correc e maintenanca and, to some ex nt, operations, I
l may be directl applicable to LGS and vice-versa.
e PBAPS ISEG is similar composition to and has similar respons ilities as the LGS I G.
The nager - ISEG reports to the Senior Vice President - Nu ar th ugh the Director - Nuclear Quality Assurance on matters of bo routine and a safety-related nature.
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' Apprise; the iSenior Vice President and Chief Nuclear J
Officer; the Vice President,' Station Support;=the Vice-
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President, Limerick Generating Station; and'the Nuclear.
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- Review Board periodically of the status of'the Quality Assurance, aspects -of Limerick.. Generation Station's
- operations,..and 'immediately of.~significant problems-affecting quality.
1.
control' contents and revisions of the. Quality-Assurance l
Program Description.
d.
Ensure that personnel involved in~ implementing the'NQA procedures are trained and/or qualified, as appropriate..
k.
contract'for QA/QV consulting services'asLnecessary.,
1.
Provida support' for QA/QV-training and-~ qualification programs, as required, for implementation'and execution-of the NQA' Program.
Establish and maintain the Evaluated Vendors List--(EVL)=
- m. -
of evaluated -and qualified - vendors in accordance with administrative procedures.
Perform assessment / surveillance.of vendor activities as.-
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appropriate.
b
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Establish, administer, and coordinate the Nuclear Quality Assurance Program associated with-modifications, and capital equipment installation or renewal.
p.
- Assess, through 'NQA Assessments,. Surve'illances, 'and l
Quality Verifications, the adequacy and effectiveness of activities covered by the NQA program.
17.2.1.2.3.1 Limerick Quality Division The Limerick Quality Division -is under' the> supervision of a Manager who reports to the Director, > Nuclear Quality Assurance.
The Division is composed of three sections:
Assessment, Quality Verification, and Quality Support.
The' Manager, who_ meets the requirements of ANSI /ANS-3.1-1978,-'is responsible for:
a.
Providing technical and administrative direction to the Division.
b.
Providing single point accountability'for all site quality activities.
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Reviewing _ and approving site-generated-
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administrative procedures.
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Formulating the site Assessment rograms.
Mel f6WCW Conducting assessments, surveillances,. and l
-verifications.
e.
f.
Identifying specific and.
programmatic deficiencies, and tracking,these items.until they are fully' resolved, in accordance with Administrative Procedures..
j Performing trend analysis.
g.
Providing periodic reports to the Director, i
h.
NQA, on the status and adequacy of the nuclear' facility
-Quality Assurance Program and advising of any problems requiring special attention.
i.
~ Approving Stop Work directives.
l qualified and.
j.
-Providing and maintaining a-
. suitably trained quality assurance staff. to carry out required project and staff functions.
- ~
17.2.1.2.3.1.1 Assessment Section The Assessment section is under the supervision of the site Quality Division Manager. The Manager has the following responsibilities:
Provide administrative supervision of the activities of-a.
l the section.
Direct the scheduling,
- planning, and' performance of.
b.
assessments and surveillances in accordance'with written j
procedures to ensure compliance with the NQA Program and Technical Specifications.
Oversee the preparation of NQA assessment checklists.
j c.
i d.
Review and approve results of assessments and-surveillances.
l e.
Ensure that items requiring corrective action are n-properly identified and documented in accordance with NQA proceduras.
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Ec e, L94-Io8or po S~ of B LGS UFSAR 17.2.1.2.3.2 Independent Safety Engineer rent The Limerick Indepen ng ne oup (ISEG) composition les are described in Section 1 and 1
17.2.1.2.3.3 Corporate Nuclear Quality Division f.}
The Corporate Nuclear Quality Division is under the supervision of a The Manager who reports to the Director, Nuclear Quality Assurance.
Division consists of two sections:
Assessment, and Administration.
The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities.
This includes:
a.
Manuals and procedures.
l b.
Vendor assessments and surveillances.
j c.
Training.
d.
Oversight of the quality activities of the Station Support Department.
Identification of specific and programmatic deficiencies
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e.
and tracking of these items until they are fully resolved.
l f.
Performing trend analysis.
Conducting internal assessments at the corporate offices.
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17.2-12
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17,Z. l. Z.,3,2.
N EPENDENT TECHNICAL REVIEW PROGRAM An Independent Technical Review Program shall be established to satisfy the following:
17 2.1.2.3.2.1 The Independent Technical Review Program ' responsibilities shall encompass:
NRC issuances, industry advisories, Licensee Event Reports, and a.
other sources that may indicate areas for improving plant safety; b.
Internal and external operating experience information that may-indicate areas for improving plant safety;
.i Plant operating characteristics, plant operations, modifications, c.
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 senior management of the affected organizations, with. copies to the Director-Nuclear Quality Assurance and the Senior Vice President and Chief Nuclear Officer for revising procedures, equipment modifications or other means of improving nuclear safety and plant reliability.
The Independent Technical Review Program shall utilize several on-site
( 7, 2. l, 2,3,2. 2 personnel who are independent of the plant management chain to perform the reviews. These individuals shall report to the LGS Site Quality Division Manager. The LGS Site Quality Division Manager is responsible to ensure the Independent Technical Review Program is implemented as indicated in section 13.4.5.1. The Site Quality Division Manager shall utilize information obtained as part of this program as input to advise management on the overall quality and safety of operations. '
17, 2.1. 2. J. 2.3 The written record of technical reviews shall be reported to, at a minimum, 4
the Senior Vice President and Chief Nuclear Officer, the LGS Station Vice President, the Nuclear Review Board, and the Director-Nuclear Quality 2
Assurance. Records of the activities of the IndependentTechnical Review Program shall be prepared and forwarded each calendar month to the Director-Nuclear Quality Assurance.
e I7. 2,I, Z.,.7. 2. I t 1. 2 1, 2. 7,2. 4 Personnel performing reviews pursuant to section r shall have at least 3 years of related experience and a bachelor's degree in engineering or a related W; or shall have at least 8 years of related experience. The LGS Quality Division Manager shall meet the requirements of ANSI /ANS-3.1-1978.
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f of 8 LGS UFSAR 17.2.2.12 concerning plant conditions and status will be made Information available to NQA personnel to enable responsible NQA supervision to determine when assessments, surveillances, or verifications should be performed.
This information may be in the form of communications with plant management or staff personnel through daily or periodic meetings.
In addition, NQA personnel shall periodically review operating logs, maintenance work schedules, fuel handling operations schedule, ISI/IST inspection program, and modification proposals, to ensure that NQA personnel are involved in day-to-day activities that are important to the safe operation of LGS.
17.2.2.13 Personnel performing or verifying quality-related activities shall be:
a.
Trained in the purpose,
- scope, and implementation of quality-related manuals, instructions, and procedures.
b.
Trained and certified in the principles, techniques, and requirements of the performed activity and such certification shall delineate the specific area of expertise and criteria used.
17.2.2.14 The training / certification program shall include documentation of the objective, content, enrolled attendees, date of attendance, and examinations given.
17.2.2.15 The training / certification program shall previde for retraining, re-examination, and/or recertification-.as-appropriate. -
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l The Manager._ /Tndapanda".t Cafety Zuylueering Gicup (IO W is responsible 4f-or revicuing plant operating characteristics, NRC issuances, and other appropriate resources of plant design and operating experience information that may indicate areas for o improving plant
- safety, and for input and closure of we recommendations in the PIMS databas, V pra result Pccm these reves.
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LGS UFSAR Review of the security plan and implementing procedu.res i.
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and submittal of recommended changes to the NRB.
Review of the emergency plan and implementing procedures k.
and submittal of recommended changes to the NRB.
Review of every unplanned onsite release of radioactive material to the environs including the preparation and 1.
i forwarding of reports covering evaluation, recommendations and disposition of the corrective action Plant to prevent recurrence to the Vice President, LGS, Manager, and to the NRB.
Review of changes to the process control prcgram, offsite dose calculation manual, and radwaste treatment systems.
n.
The PORC shall:
Recommend in writing to the Plant Manager approval or disapproval of items considered under the first four a.
areas described above.
Render determinations in writing with regard to whether or not each item considered under areas b., c., d., and b.
f.
described above const.itutes an unreviewed safety question.
~ ~ -
Provide immediate written notification to the Vice
~
President - LGS and the NRB of disagreement between the c.
The Plant Manager shall have PORC and the Plant Manager.
the responsibility for resolution of such disagreements.
The PORC shall. maintain written minutes of each meeting and copies Plant Manager, and shall be provided to the Vice President - LGS, N44de M ktwtop gart</ cs y,r,,,y, g
j to the NRB.
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- g activities related to the' safe operat:[on of the sta m.4_..
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audit, and evaluate both technical and n
is to review, tters pertaining to safe operation of the station.
Its purp orgahiz.ationa blished in a written charter that includes The NRB shall be s, reporting requirements, areas to be membership,'responsibi ed for the operation of theiNRB.
reviewed, and oth'er.; aspects f's"Ch,irman an least five members who a
The FRB shall consist de members who are are IECO Energy employees and at-least two with no more than nority being u
not PEco Energy employees, The NRC shall b m osed of l members of the plant operating staff.
no less than eight members and no more than twelve (12) ne
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.._2 quired to review plant operations, nuclear engineering, chemistry nondestructive
- testing, radiochemistry, metallurgy, ical safety, mechanical and en radiolog mentation and control, ical engineering, administrative controls, quality assurance ins emergency planning, maintenance, training and other olGc The NRB can call upon pract es,at may. affect. nuclear safety.
partments within PEco for technical' assistance and shall crsas i
as determined by the Chairman, to provide various utilize nsultants, All Alternates to Members shall be appointed in expert adyAl ernates shall serve on a continuing basis and shall be e.
nd all NRB meetings to keep informed of issues being Writing.
invited to at NRB.
Alternates shall function in a manner addressed by e f the Members except that Alternates shall vote similar'to that r for whom they are the Alternate is absent. The i
only when the Me (such as in Board meeting minutes),
writing 1
NRB may appoint, oses such as performing reviews or studies in gubcommittees for p creas requiring par cular expertise or for performing special investigations.
The NRB consists of the ollowing Members and their Alternates:
NUCL R REVIEW BOARD PS/ LGS' Posit Members NRB Chai an Chairman Vice Chairman / Member Director -
clear Quality Assurance en d Vice Presiden
- Limerick Member Member Vice President -
each Bottom Vice President - S tion Support Member Director - Engineerin Member Alternate Member Manager - Peach Bottom Q lity Manager - Limerick Quality Alternate Member Plant Manager - Limerick Alternate Member Plant Manager - Peach Bottom Alternate Member Alternate Member Manager - Corporate Quality l \\wo additional members of the NRB are not employees of PICo.
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Quality Assurance practice and cognizant' of the Quality As urance requirements of,10 CFR 50x Appendix B.
Additionally, will be' cognizant of the CorporaYe Quality Assurance Program the and ill have the Corporate Quality Assurance organization evnil le to them.
s and Alternates of the NRB shall be appointed in writing
- f. The Memb
- r Vice President and Chief Nuclear Officer and shall by the Sei odemic degree in an engineering or physical science have an a um of five years technical experience, of which three field, a min sional level experience shall be in one or more of years of prof in the second paragraph of this section.
the areas list performing reviews or audits under the The NRB, and t se shall have access to records and personnel cognizance of the B,
as necessary to prop ly perform their functions. The NRB shall be kept current on event within its responsibility by reviewing PORC Reports, violations, audit reports, other minutes, Licensee Even reports, and by the act ities of the Board members.
The NRB shall meet at lea once per six months or more often as determined by the Chairma A quorum shall consist of the chairman, or Vice Chairman, d at least four, but not less than half, of the voting Members.
1 more than a minority of the quorum shall have line responsibility or operation of the plant.
The NRB shall review:
a.
The safety evaluations f
- 1) changes to procedures, equipment or systems and 2) tests or experiments of 10CFR50.59, to verify completed under the provisio that such actions did not const tute an unreviewed saf6ty question.
Proposed changes to procedures, eq ' ment or systems that b.
involve an unreviewed safety que ion as defined in 10CFR50.59.
Proposed tests or experiments that invo e an unreviewed c.
safety question as defined in 10CFRSO.59 d.
Proposed changes to Technical specifica 'ons or the RC.
operating license prior to submittal to the e.
Violations of applicable statutes codes, reg
- ations, orders, Technical Specifications, license requi
- ments, clear or of internal procedures or' instructions having safety significance. This shall normally be accompl'shed by review of PORC meeting minutes, special reports or reports of audits.
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d the normal and expected performance of unit equipment an
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plant staff that; af f ect ' huclear safety.
This shall normally be acuomplished by review of PORC meeting minutes, special reports, or reports of audits.
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All Reportable Events.
recognized indications of an unanticipated deficiency g.
aspect of design or operation of structures, h.
A s or components that could affect nuclear safety.
in one all normally be accomplished by review of PORC syst minutes, special reports, or reports of audits.
This meetin meeting minutes of the PORC.
i.
Reports a corrective maintenance program, j.
Preventive a effectiveness of the Quality Assurance Program in term of the scope of the program and Assessment of t k.
processes used.
1 Assessment of the e fectiveness of the line safety assessment function (
RC) in terms of its scope of review and processes us The NRB will utilize, as necessar the Operating Experience d the Nuclear Assessment Program (OEAP) of the Licens ng Section, anrrent plant and P
Quality Assurance Department to reviewcohcerns and pe i
enior Vice President The NRB Chairman will report directly to theregular' b is c o n c e r n i n g,.t h e l
ersonnel of safe and Chief Nuclear Officer on a f
requirements for assuring the public and plan A writt summary of NRB operation of the nuclear power plants.
activities is sent to the Office of the Pres ent and Chief operating Officer of the Company.
and reports of actions tak shall be i
j Minutes retained and shall identify documents reviewed, of NRB meetings he NRB.
and and actions taken by prepared decisions and recommendations made,The minutes shall b entI days f lowing and Chief i each meeting) forwarded to the f manag Nuclear Officer followed by copies to other members o 4
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..r. f ' der the cognizance of the NRB:
perto u.
t operation to provisions contained The conformanc cations and applicable
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within the Technical a.
License Conditions at least once -
'2 months.
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, _r' operating staff at least 'once every 12 months.
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c The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or t
method of operation that affect nuclear safety at leas ce every six months.
erformance of activities required by the operational to meet the criteria of d.
Th program qual'ty assurance at least once every 24 months.
10CFR
, Appendix B, ency Plan and implementing procedures at least e.
The Eme 12 months.
once ever Plan and implementing procedures at least f.
The Securit once every 12,onths.
The Fire Protec 'on Program and implementing procedures 24 months.
g.
at least once eve protection and loss prevention l
An independent fi all be performed at least once per h.
inspection and audit er qualified offsite PECO' Energy 12 months utilizing ei ire protection firm.
personnel or an outside the fire protection and loss An inspection and audit o performed by an outside i.
shall prevention program tervals no greater than 36 qualified fire consultant at 1 months.
'toring program and hhe The radiologic'al environmental mo 2 months.
j.
results thereof at least once per The Offsite Dose Calculation Manua and implementing procedures at least once per 24 month k.
ng procedures The Process control Program and implemen.
1.
at least once per 24 months.
l propriate Any other area of unit operation considered Nuclear i
by the NRB or the' Senior Vice President and Chi m.
officer.
of activities required by the Q lity The performance the criteria of Regul ory n.
Program to meet at least once per 12 mon Assurance Guide 4.15, December,1977, a.m 2:
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M LGS UFSAR A d[ts shall include verification of compliance and effectivenes
/7;j lementation of programs, procedures, regulations, and lic se
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of provi ons in the areas audited.
Written reports of such udits shall b transmitted for appropriate action to the S or Vice President nd Chief Nuclear Officer and man ent having responsibilit n *.be areas audited within 30 da after completion of the audit by a auditing organization.
Audits shall be m ned by th uclear Quality Assurance Department or by speciall elect groups or individuals who have no immediate responsibility he activity they audit and do not, to a management representative while performing the audit epo who has immediate resp ibility fo he activity being audited.
Timely follow-up a on, including re-dit where appropriate, l
shall be taken w deficiencies are noted.
-annually by ogram and schedules shall be reviewed se The audit cordance o ensure that the audits are being performed in the NR vi he Technical Specifications.
The audit program is de ibed l
Chapter 17.
13.4.5 INDEPENDENT SAFETY ENGINEERING GROUP An Independent Safety Engineering Group was established prior to initial fuel load of Unit 1 to perform independent reviews of plant l
The ISEG examines unit operating characteristics, NRC operations.
A industry advisories, Licensee Event Reports, and other issuances, sources of unit design and operating experience information, y
including units of similar design, which may indicate areas for improving unit safety.
The LGS ISEG is composed of at least five dedicated, full-time engineers / scientists, including the Superintendent - ISEG, located Each ISEG member has a bachelor's degree in engineering on-site.
or related science and a minimum of two years of professional level The LGS ISEG Manager has a experience in their respective fields.
The LGS minimum of six years of experience in the nuclear field..
ISEG reports to the Director - Nuclear Quality Assurance.
The ISEG is responsible for maintaining surveillance of unit activities to provide independent verification that these activities are performed correctly and that human errors are reduced as much as practical.
The ISEG is not responsible for sign-off functions.
The ISEG is responsible for performing independent reviews of plant operations, reviewing operating experiences which may indicate the need for improvements, recommending needed improvements, and advising management on the overall quality and safety of operations.
- 9. #
13.4-8 t,. G4 n/94
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Entering NQA records into the Nuclear Records Management.
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System.
Review of NQA administrative procedures.
j f.
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Review of Nuclear Generation Group administrative procedures.
Review and revision of the UFSAR QA Program Description.
l h.
Plant Operation Review Committee (PORC) 17.2.1.2.4 are defined in Section composition and responsibilities The PORC 13.4.2.
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Set Zww~T 4) 17.2.1.2.5 Nuclear Review Board (NRB) 1 2n
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17.2.1.3 Power Generation Group The Power Generation Group organization is under the direction of the Senior Vice President, Power Generation Group.
The Senior Vice President is responsible for providing support for nuclear operation activities through the Oregon Shop which supplies various mechanical and electrical shop se.rvices to PECO Energy generation facilities, including fire protection services.
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Review of the security plan and implementing procedures and submittal of recommended changes to the NRB.
k.
Review of the emergency plan and implementing proc ures and submittal of recommended changes to the NR 1.
Review of every unplanned onsite release o radioactive material to the environs including the ep a t. ion and forwarding of reports coveri evc wation, recommendations and disposition of th corrective ad..cs to prevent recurrence to the Vice P esident,' LGS, Plant Manager, and to the NRB.
Review of changes to the proce control program, offsite m.
dose calculation manual, an adwaste treatment systems.
The PORC shall:
a.
Recommend in writin to the Plant Manager approval or disapproval of it s considered under the first four areas described ove.
b.
Render dete a nations in writing with regard to whether f
or not eac item considered under areas b.,
c.,
d.,
and f
f.
descr* ed above constitutes an unreviewed safety questio.
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c.
Pro de immediate written notific'ation to the Vice P
sident - LGS and the NRB of disagreement between the ORC and the Plant Manager. The Plant Manager shall have the resps 7sibility for resolution of such disagreements.
The P C shall maintain written minutes of each meeting and copies sha be provided to the Vice President - LGS, Plant Manager, and
, n 3
t the NR ZasH74e te daibn INDEPENDENT REVIEW f le [ [ U Nuclear Review Board shall provide independent review of The operating activities related to the safe operation of the station.
and evaluate both technical and Its purpose is to review, audit, organi7ational matters pertaining to safe operation of the station.
The NRB shall be established in a written charter that includes membership, responsibilities, reporting requirements, areas to be reviewed, and other aspects needed for the operation of the' NRB.
The NRB shall consist of a Chairman and at least five members who are PECO Energy employees and at least two outside members who are not PECO Energy employees, with no more than a minority being members of the plant operating staff.
The NRC shall be composed of no less than eight members and no more than twelve (12) members.
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_L ggggy LGS UFSAR P 9 of /4 The NRB shall collectively have the experience and competence required to review plant operations, nuclear engineering, chemistry cnd radiochemistry, mstallurgy,-~
nondestructive
- testing, instrumentation and control, radiological safety, mechanical and clectrical engineering, administrative controls, quality assurance practices, emergency planning, maintenance, training and other creas that may affect nuclear safety.
The NRB can call upon various departments within PEco for technical assistance and-shall as determined by the Chairman, to provide
, utilize consultants, All Alternates to Members shall be appointed in cxpert advice. Alternates shall serve on a continuing basis and shall be i
writing.
. invited to attend all NRB meetings to keep informed of issues being i
cddressed by the NRB.
Alternates shall function in a manner i
cimilar to that of the Members except that Alternates shall vote only when the Member for whom they are the Alternate is absent. The NRB may appoint, in writing (such as in Board meeting minutes),
subcommittees for purposes such as performing reviews or studies in areas requiring particular expertise or for performing special investigations.
The NRB consists of the following Members and their Alternates:
NUCLEAR REVIEW BOARD PBAPS/ LGS I
Position Members Chairman NRB Chairman Vice Chairman / Member Director - Nuclear Qualiti-Assurance Vice President - Limerick Member Vice President - Peach Bottom Member Vice President - Station Support Member Director - Engineering Member Alternate Member Manager - Peach Bottom Quality Alternate Member Manager - Limerick Quality Alternate Member Plant Manager - Limerick Alternate Member Plant Manager - Peach Bottom Alternate Member Manager - Corporate Quality l
Two additional members of the NRB are not employees of PECo.
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[*/d LGS UFSAR The Nmbers and alternates of the NRB will be competent in the area of Quality Assurance practice and cognizant of the Quality CFR Sh_ Appendix B.
Additionally, Assurance requirements of,10 they will be cognizant of the Corporate Quality Assurance Programorganization and will have the Corporate Quality Assurance available to them.
The Members and Alternates of the NRB shall be appointed in writing by the Senior Vice President and Chief Nuclear Officer and shall have an academic degree in an engineering or physical science field, a minimum of five years technical experience, of which three -
years of professional level experience shall be in one or more of the areas listed in the second paragraph of this section.
QSfkth/N reviews or
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under the performing The NRB, and those shall have access to records and personnel cognizance of the NRB, The NRB shall be as necessary to properly perform their functions.
kept current on events within its responsibility by reviewing PORC minutes, Licensee Event Reports, violations, audit reports, other.
reports, and by the activities of the Board members.
The NRB shall meet at least once per six months or more often as l
determined by the Chairman.
A quorum shall consist of the chairman, or Vice Chairman, and at least four, but'not less than No more than a minority of the. quorum half, of the voting Members.
shall have line responsibility for operation of the plant.
The NRB shall review:
a.
The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments to verify completed under the provision of 10CFR50.59, that such actions did not constitute an unreviewed safsty question.
Proposed changes to procedures, equipment or systems that involve an unreviewed safety question as defined in b.
Proposed tests or experiments that involve an unreviewed c.
safety question as defined in 10CFR50.59.
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or the changes to Technical Specifications Proposed d.
operating license prior to submittal to the NRC.
Violations of applicable statutes codes, regulations, l
orders, Technical Specifications, license requirements, e.
or of internal procedures or instructions having nuclear This shall normally be accomplished safety significance.
by review of PORC meeting minutes, special reports, or reports of audits.
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f.
Significant operating abnormalities or deviations from~
normal and expected performance of unit equipment and the plant staff that affect huclear. safety.
This shall l
normally be accomplished by. review of - PORC meeting minutes, special reports, or reports of audits.
g.
All Reportable Events.
h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems or components that could affect nuclear safety.
This shall normally be accomplished by review of PORC meeting minutes, special reports, or reports of audits.
i.
Reports and meeting minutes of the PORC.
i j.
Preventive and corrective maintenanc'e program.
k.
Assessment of the effectiveness of the Quality Assurance Program in terms of the scope of the program and processes used.
1.
Assessment of the effectiveness of the line safety assessment function (PORC) in terms of its scope of review and processes used.
The NRB will utilize, as necessary, the Operating Experience Assessment Program (OEAP) of the Licensing Section, and the Nuclear Quality Assurance Department to review current plant and industry concerns and perform special studies and investigations.-
The NRB Chairman will report directly to the Senior Vice Presidgnt i
and Chief Nuclear Officer on a regular' basis concerning the requirements for assuring the public and plant personnel of safe
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operation of the nuclear power plants.
A written summary of NRB activities is sent to the Office of the President and Chief l
Operating Officer of the company.
'l Minutes of NRB meetings and reports of actions taken shall be prepared and. retained and shall identify documents reviewed, decisions and recommendations made, and actions taken by the NRB.
The minutes shall be promptly (normally within 14 days following each meeting) forwarded to the. Senior Vice President and Chief Nuclear Officer followed by copies to other members of management as appropriate.
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LGS UFSAR ggefg /f;ggg yitoH4 17.2.18.4 NQA is responsible for the planning.,. performance, reporting, and l.
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follow-up of the assessment program to= determine compliance with the c1cments and effectiveness of the NQA Program.
17.2.18.5 l
Assessments and Surveillances shall be performed in accordance with personnel, who are independent of any written procedures by NQA direct responsibilities for the performance of activities which they l
NQA may request the assistance of personnel from other will assess.
disciplines or technical specialists who are independent of areas g
baing assessed.
l shall establish the assessment program personnel The Director, NQA, qualifications and the requirements for the use of technical l
assessment of the Quality Assurance cpecialists to accomplish the Pregram.
Personnel shall be selected for quality assurance assessment assignments based on experience or training which l
are commensurate with the establish that their qualifications In l
complexity or special nature of the activities to be assessed.co ba given to special abilities, specialized technical training, prior and education.
partinent experience, personal characteristics,
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The following activities of afety importance of the activities.
assessed at least every 2 l
an the Q ty Assurance Program shall be as otherwise indicated:
7 years, ex a.
Trainin nit staff is assessed annually) b.
Health Physics c.
Chemistry d.
Fuel /In-vessel Material Shift operations e.
f.
Surveillance Testing Maintenance of Instruments g.
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Pr rement k.
Modific ions l '.
Radioactive ' ste Material Plans - Includes.
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Fire Protection *Pla Emergency Plan (asses d annually) sessed annually)
Physical Security Plan radiological Environmenta onitorinti Program (assessed annually)
Nuclear Engineering.
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Otherareasthatshallbesubjecttoscheduledahessmentsinclude l
preparation,
- review, approval',
and control of cifications, documents, instructions, procedures',
drawings; procurementreceiving and installation inspections; and vendor activies.
Regularly scheduled assessments may be supplemented by unannou ' d or j
. unscheduled assessments or surveillances as determined by NQA.
17.2.18.7 Assessment and surveillance procedures shall require that l
are identified be documented in sufficient nonconformances which detail to assure that required corrective action can be effectibely carried out by the assessed organization. Corrective action may be l
recommended, as appropriate, by NQA.
17 2.18.8 Responsible management shall take the necessary action to correct any identified deficiencies and to report the cause of the deficiency and 1
Unless justified in writing as not j
the corrective action to NQA.
appropriate, corrective action intended to prevent recurrence shall also be taken and reported.
17.2.18.9 When corrective action measures are indicated, follow-ups or re-assessments of applicable areas shall be conducted, to assure l
implementation and effectiveness of corrective actions.
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r of plant activities in the following areas shall be performed under the cognizance of the NRB:
i The conformance of unit operation to provisions contained a.
within the Technical Specifications and applicable
- License conditions at least once every months.
of b.
The performance, training and qualifications of the operating staff at least 'nce every te months.
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i c.
The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or j
method of operation that affect nuclear safety at least ist months.
onceeveryw$
d.
The performance of activities required by the operational quality assurance program to meet the criteria of 10CFR50, Appendix B, at least once every 24 months.
The Emergency Plan and implementing procedures at least i
e.
once every 12 months.
f.
The Security Plan and implementing procedures at least once every 12 months.
g.
The Fire Protection Program and implementing procedures at least once every 24 months.
t??M6MY h.
An independen 1re protection and loss prevention inspection and
shall be performed at least once per 12 months utilizing either qualified offsite PECO' Energy personnel or an outside fire protection firm.
i.
An inspection and o
- e. fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 36 months.
j.
The radiologic'al environmental monitoring program and the results thereof at least once per months.
k.
The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.
1.
The Process Control Program and implementing procedures at least once per 24 months.
m.
Any other area of unit operation considered appropriate by the NRB or the Senior Vice President and Chief Nuclear
- Officer, n.
The performance of activities required by the Quality.
Assurance Program to meet the criteria of Regulatory Guide 4.15, December, 1977, at least once per W uonths.
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- WF4WD shall include verification of compliance and effectiveness 2._21t of implementation of programs, procedures, regulations, and licenseWritten repor provisions in the areas audited.
chall be transmitted for appropriate action to the Senior Vice 1
ficer and management having President and Chief Nucly within 30 days after completion
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responsibility in the areas _.b the c_litir organization.
of the taint AW4H
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shall be performed by te Nuclear Quality Assurance gg s who have D:partment or by specially selected groups or indivi u o the activity they and do not,
. while performing the _ __gf port to a management representative no immediate responsig who has immediate responsibility for the if1'are appropriate, follow-up action, including re-Timely chall be taken when deficiencies are noted.
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ph am and..schedul shall be reviewed semi-annually by The the NRB to ensure that' the 2" Aite are being performed in accordance with the Technical Spec'ifications.
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17.2.18.10 l
Ths results of the assessment program bh_all be documented by NQA and dictributed to the appropriate levels of management including the l
management of the assessed area.
l Asssssment results shall be analyzed and a statement regarding-the i
sffectiveness of the QA Program in the areas assessed shall be j
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included in the Assessment Report.
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nce of the Nuclear Review l
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Aesessments performedIn Section 13.4.
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i 17.2.18./ldir Tha assessment program shall be periodically reviewed and revised as l
nscessary to assure that coverage and schedule reflect current 1
activities.
17.2.18. //d l
NQA,. is responsible to identify overdue corrective The Director, l
action to the appropriate responsible management."
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