ML20082J423

Proposed Tech Specs Consisting of TS Change Requests 94-51 Delete Independent Tech Review Section from TS, 94-52 Delete Nrb Review Section from TS & 94-53 Delete Nrb Audit Section from Ts

ML20082J423
Person / Time
Site:	Limerick
Issue date:	04/06/1995
From:	PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
Shared Package
ML20082J403	List: ML20082J400 ML20082J423
References
NUDOCS 9504180243
Download: ML20082J423 (25)

Text

- - _ _ . . _ - _ _ _ _ _ _ _ - .

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Attachment 2 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 NPF-85 .)

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 PDR ,

P.I of f LGS UFSAR AudiYs shall include verification of compliance and effectiveness of implementation of programs, procedures, regulations, and license provisions in the areas audited. Written reports of such audits -

shall be transmitted for appropriate action to the Senior Vice and management having and Nuclear Officer President Chief responsibility in the areas audited within 30 days after completion of the audit'by the auditing organization.

be performed by the Nuclear Quality Assurance Audits shall 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.

Timely follow-up action, including re-audit where appropriate, ,

l shall be taken when deficiencies are noted.

The audit program and schedules shall be reviewed semi-annually by the NRB to ensure that the audits are The being performed audit program in is accordance described j with the Technical Specifications.

in Chapter 17.

l_ECt/^hCAL RE VIDO FUNCDOAl 13.4.5 INDEPENDENT SM4iMPY-BN95tHHHtTNG GRGUS- g N

pendent Safety Engineering Group was established oflor to j An I initialx uel load of Unit 1 to perform independent revie stics, NRC plant N The ISEG examines unit operating charact j operation s, and other l (issuances, 1 dustry advisories, t design Licensee Event and operating experie Rep e information, /

sources of u f similar design, which may ' dicate areas for (s 1

/ including units s

[ improving unit sa y, i d of at least e dedicated, full-time The LGS ISEG is comp rintendent - ISEG, located engineers / scientists, in uding the S f 3

on-site. Each ISEG membe as a b elor's degree in engineering (

or related science and a min m two years of professional level N experience in their respective elds. The LGS ISEG Manager has a en s in the nuclear field. The LGS ,

minimum of six years of exp 1

f ISEG reports to the Dire t - Nuc' ar Quality Assurance. l

/

The ISEG is responn ble for mainta ng surveillance of unit that these activities to p Gide independent v ification erformed correctly and at human errors are l activities are ot responsible for reduced as mu as practical. The ISEG i l j

sign-off fu tions. /

views of plant The ISE s responsible for performing independent ma ndicate the <

opera ons, reviewing operating experiences whichimprov nts, and nee for improvements, recommending needed s of  !

ising management on the overall quality and ety a }

l perations.

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The haepended Technical Review Fhnchen is descad I

10 SCtiCO ll2,L13. 2.. 13.4-8 - nc. . c4 n/V 4

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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 organization with copies to the Director -

Nu ear Quality )

Assurance and e Senior Vice President - Nuclear t The LGS ISEG perfo s the functions of a independent safety l

engineering group as d cribed in Item I.B .2 of NUREG-0737. The

[

l 1 average years of nuclear- lated experie e exceed the 1 to 2 years i

of nuclear-related experien stated section 13.4 of the SRP.

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 areas of design, l PBAPS ISEG's asses ents, particularly in t 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 l is similar composition to and has similar respons ilities as l the LGS I G. l 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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13.4-9 Mcf,/03-

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GCR L.W - 1 O B0f" \

lgs UFSAR' l l h.

' Apprise; the iSenior ViceJ President and Chief Nuclear Officer; the Vice President,' Station Support;=the Vice- -)

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.

m. - Establish and maintain the Evaluated Vendors List--(EVL)=

of evaluated -and qualified - vendors in accordance with administrative procedures.

n.. Perform assessment / surveillance.of vendor activities as.- l appropriate.

b 'o. 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-b Ic. administrative procedures.

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d. Formulating the site Assessment rograms. Mel f6WCW l

Conducting assessments, surveillances,. and e.

l -verifications.

I Identifying specific and. programmatic f.

deficiencies, and tracking,these items.until they are fully' resolved, in accordance with .

Administrative Procedures..  !

j

g. Performing trend analysis. '

h. Providing periodic reports to the Director, i NQA, on the status and adequacy of the nuclear' and .

facility -Quality Assurance Program '

advising of any problems requiring special attention.

i. ~ Approving Stop Work directives.

l

-Providing and maintaining a- qualified and.

j. ,

. suitably trained quality assurance and staff. to staff '

carry out required project l

functions.  :~

17.2.1.2.3.1.1 Assessment Section I

The Assessment section is under the supervision of the site Quality Division Manager. The Manager has the following responsibilities:

.f

a. Provide administrative supervision of the activities of-l the section.

b. Direct the scheduling, planning, and' performance of.

j assessments and surveillances in accordance'with written procedures to ensure compliance with the NQA Program and Technical Specifications.

j

c. Oversee the preparation of NQA assessment checklists. i assessments and-

d. Review and approve results of surveillances.

e. Ensure that items requiring corrective action are l

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 1 les are described in Section 1 and 17.2.1.2.3.3 Corporate Nuclear Quality Division f.}

The Corporate Nuclear Quality Division is under the supervision ofThe a Manager who reports to the Director, Assessment, Nuclear Quality andAssurance.

Administration.

Division consists of two sections:

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

a. Manuals and procedures.

j l b. Vendor assessments and surveillances.

c. Training.

d. Oversight of the quality activities of the Station Support Department.

] e. Identification of specific and programmatic deficiencies and tracking of these items until they are fully resolved. .-

l f. Performing trend analysis.

l

g. Conducting internal assessments at the corporate offices.

17.2-12 . -Rev . '

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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:

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

b. Internal and external operating experience information that may-

.i

• 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 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.

( 7, 2. l, 2,3,2. 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 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. '

4 17, 2.1. 2 . J . 2.3 The written record of technical reviews shall be reported to, at a minimum, the Senior Vice President and Chief Nuclear Officer, the LGS Station Vice 2

President, the Nuclear Review Board, and the Director-Nuclear Quality Assurance. Records of the activities of the IndependentTechnical Review Program shall be prepared and forwarded each calendar month to the e Director-Nuclear Quality Assurance.

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

1. 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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l LGS UFSAR 17.2.2.12 Information concerning plant conditions and status will be made 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 l l

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 such requirements of the performed activity and of certification shall delineate the specific area expertise and criteria used.

17.2.2.14 The training / certification program shall include documentation of the and objective, content, enrolled attendees, date of attendance, 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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The Manager._ /Tndapanda".t Cafety Zuylueering Gicup (IO W is l

responsible 4f-or revicuing plant operating characteristics, NRC issuances, and other appropriate resources of plant design and that may indicate areas for operating experience information o improving plant safety, and for input and closure of we recommendations in the PIMS databas, V ._ -

pra result Pccm these reves. \

He Tedepeded Technical Revtus kccccan Is desuMd in Sechcn m / 7.1 i.2. 3,2, 4 -

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j. Review of the security plan and implementing procedu.res ._

l and submittal of recommended changes to the NRB.

k.

Review of the emergency plan and implementing procedures and submittal of recommended changes to the NRB.

1. Review of every unplanned onsite release of radioactive material to the environs including the preparation covering evaluation, and i forwarding of reports recommendations and disposition of the corrective action Plant to prevent recurrence to the Vice President, LGS, Manager, and to the NRB.

n.

Review of changes to the process control prcgram, offsite l dose calculation manual, and radwaste treatment systems.

The PORC shall:

a. Recommend in writing to the Plant Manager approval or disapproval of items considered under the first four areas described above.

b.

Render determinations in writing with regard to whether or not each item considered under areas b. , c. , d. , and f.

described above const.itutes an unreviewed safety

~~- question.

~

c. Provide immediate written notification to the Vice l President - LGS and the NRB The of disagreement Plant Manager between shall have the l PORC and the Plant Manager. l 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, to the NRB. g j N44de M ktwtop 4/fc/fsegfgpp

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• g isactivities related to the' safe operat:[on of the sta to review, audit, and evaluate both technical and Its purp tters pertaining to safe operation of the station.

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 a

f's"Ch,irman an least five members who The FRB shall consist de members who are are IECO Energy employees and at-least two nority being not PEco Energy employees, with no more than u m osed of l members of the plant operating staff. The NRC shall b ~.

no less than eight members and no more than twelve (12) ne

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quired to review plant operations, metallurgy, nuclear engineering, chemistry nondestructive testing, mentation and control, radiolog ical safety, mechanical and en radiochemistry, ins olGc ical engineering, emergency administrative controls, quality assurance planning, maintenance, training and other pract es, The NRB can call upon crsas at may . affect . nuclear safety. .

various partments within PEco for technical' assistancetoand shall i nsultants, as determined by the Chairman, provide utilize All Alternates to Members shall be appointed in expert adyAl ernates e.  !

shall serve on a continuing basis and shall be Writing.

invited to at nd all NRB meetings to keep informed of issues being addressed by e NRB. Alternates shall function in a manner similar'to that f rthe for Members except that Alternates shall vote whom they are the Alternate is absent. The i only when the Me (such as in Board meeting minutes), .

NRB may appoint, writing 1 gubcommittees for p oses such as performing reviews or studies in creas requiring par cular expertise or for performing special investigations.

ollowing Members and their Alternates:

The NRB consists of the NUCL R REVIEW BOARD PS/ LGS' Posit Members NRB Chai an Chairman Director - clear Quality Assurance Vice Chairman / Member en d Member Vice Presiden - Limerick Member . Vice President - each Bottom Member Vice President - S tion Support Director - Engineerin Member .

Manager - Peach Bottom Q lity Alternate Member Alternate Member Manager - Limerick Quality Plant Manager - Limerick Alternate Member Plant Manager - Peach Bottom Alternate Member Alternate Member Manager - Corporate Quality l \wo T additional members of the NRB are not employees of PICo.

13.4-4 h. 64 11/M

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LGS UFSAR a _,m_ ,, , m sm o ,,4,, u ,. .,u m 4. m . , _ , '[

._y 1 Quality Assurance practice and cognizant' of the Quality Additionally, ..

As urance requirements of ,10 CFR 50x Appendix B.

the will be' cognizant of the CorporaYe Quality Assurance Assurance Program organization and ill have the Corporate Quality evnil le to them.

s and Alternates of the NRB shall be appointed in writing l I

f. byThetheMembSei *or Vice President and Chief Nuclear Officer and shall have an a demic um degree in an engineering or physical science of five years technical experience, of which three  !

field, a min years of prof sional level experience shall be in one or more of the areas list in the second paragraph of this section.

The NRB, and t se performing reviews or audits under the ,

cognizance of the B, shall have access to records and personnel as necessary to prop ly perform their functions. The NRB shall be kept current on event within its responsibility by reviewing PORC minutes, Licensee Even Reports, violations, audit reports, other 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 d at least four, but not less than chairman, or Vice Chairman, I

more than a minority of the quorum half, of the voting Members. 1 l

shall have line responsibility or operation of the plant. l I

The NRB shall review:

a. The safety evaluations f 1) changes to procedures, equipment or systems and 2) of tests or experiments completed under the provisio 10CFR50.59, to verify 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.

c. Proposed tests or experiments that invo e an unreviewed safety question as defined in 10CFRSO.59

d. Proposed changes to Technical specifica 'ons RC.

or the operating license prior to submittal to the

e. Violations of applicable statutes codes, reg ations, orders, Technical Specifications, license requi ments, or of internal procedures or' instructions having clear safety significance. This shall normally be accompl'shed by review of PORC meeting minutes, special reports or reports of audits. -

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This shall an 2 .'

normal and expected performance of unit equipment plant staff that; af f ect ' huclear safety.

normally be acuomplished by review of PORC meeting minutes, special reports, or reports of audits. }

g.

All Reportable Events.

recognized indications of an unanticipated deficiency

h. A one aspect of design or operation of structures, in s or components that could affect nuclear safety.

all normally be accomplished by review of PORC syst This minutes, special reports, or reports of audits.

meetin meeting minutes of the PORC.

i. Reports a corrective maintenance program,

j. Preventive a effectiveness of the Quality Assurance

k. Assessment of t of the scope of the program and Program in term processes used.

1 Assessment of the e fectiveness RC) in termsofof the itsline scopesafety of assessment function ( .

review and processes us -

the Operating Experience P The NRB will utilize, as necessar d the Nuclear Assessment Program (OEAP) of the Licens ng Section, anrrent plant and i

Quality Assurance Department to reviewcohcerns and pe enior Vice President The NRB Chairman will report directly to theregular' is cbo n c e r n i n g ,.t h e l and Chief Nuclear Officerthe onpublic a ersonnel of safe requirements for assuring andAplan writt summary of NRB f

operation of the nuclear power plants. ent and Chief activities is sent to the Office of the Pres operating Officer of the Company.

i and reports of actions tak shall be Minutes and retained and shall identify documents reviewed, of NRB meetings j

prepared and actions taken by helowing NRB.

days f decisions and recommendations made,The minutes and f manag Chief i shall b entI each meeting) forwarded to the Nuclear Officer followed by copies to other members o 4

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^' t operation to provisions contained applicable

a. The conformanc '

cations and within the Technical

'2 months.

License Conditions at least once -

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operating staff at least 'once every 12 months. .

c The occurringresults of equipment, in unit actions taken to correct structures, deficiencies systems or t

method of operation that affect nuclear safety at leas ce every six months.

Th erformance of activities required by thecriteria operationalof

d. program to meet the qual'ty assurance at least once every 24 months.

10CFR , Appendix B, The Eme ency Plan and implementing procedures at least e.

once ever 12 months.

Plan and implementing procedures at least

f. The Securit once every 12 ,onths.

g.

The Fire Protec 'on Program and implementing procedures l

at least once eve 24 months.

An independent fi protection and loss prevention ,

h. all be performed at least once per inspection and audit 12 months utilizing ei erire qualified offsite PECO' Energy protection firm.

personnel or an outside

, the fire protection and loss i.

An inspection and audit o performed by an outside prevention program shall tervals no greater than 36 qualified fire consultant at 1

' months.

'toring program and hhe The radiologic'al environmental mo j.

results thereof at least once per 2 months.

and implementing

k. The Offsite Dose Calculation Manua procedures at least once per 24 month ng procedures 1.

The Process control Program and implemen.

, at least once per 24 months.

l propriate

m. Any other area of unit operation considered Nuclear i by the NRB or the' Senior Vice President and Chi  ;

officer.

lity The performance of activities required by the Q ory

n. the criteria of Regul Assurance Program to meet at least once per 12 mon .

Guide 4.15, December,1977, a.m 2: 11fe+

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E Ld t L W H ffz-i LGS UFSAR [* [f # M A d[ts shall include verification of compliance and effectivenesse /7;j of lementation of programs, procedures, regulations, and licudits ,

~

provi ons in the areas audited. Written reports of suchor Vice transmitted for appropriate action to the Sent shall b Officer and man having President nd Chief Nuclear after completion responsibilit n *.be areas audited within 30 da of the audit by a auditing organization.

m ned by th uclear Quality Assurance Audits shall be Department or by speciall elect groups or individuals who have no immediate responsibility he activity they audit and do not, while performing the audit epo to a management representative who has immediate resp ibility fo he activity being audited.

including re- dit where appropriate, Timely follow-up a on, l shall be taken w deficiencies are noted.

-annually by The audito ensure ogram and schedules shall be reviewed se the NR that the audits are being performed in cordance 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 operations. The ISEG examines unit operating characteristics, NRC l

A issuances, industry advisories, Licensee Event Reports, and other 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 on-site. Each ISEG member has a bachelor's degree in engineering or related science and a minimum of two The years of professional level LGS ISEG Manager has a experience in their respective fields.

minimum of six years of experience in the nuclear field.. The LGS ISEG reports to the Director - Nuclear Quality Assurance.

The ISEG is responsible for maintaining surveillance that these of unit to provide independent verification activities activities are performed correctly Theand ISEG that human is not errors are responsible for reduced as much as practical.  ;

sign-off functions. 1 l

The ISEG is responsible for performing independent reviews of plant operations, reviewing operating experiences which may indicate the recommending needed improvements, and need for improvements, and safety of advising management on the overall quality operations.

9. # >

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LGS UFSAR 1

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-l e Entering NQA records into the Nuclear Records Management. .

System.

j f. Review of NQA administrative procedures.

administrative Review of Nuclear Generation Group l

g.

procedures.

h.

Review and revision of the UFSAR QA Program Description.

l l 17.2.1.2.4 Plant Operation Review Committee (PORC)

The PORC composition and responsibilities are defined in Section 13.4.2. .--- -

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Nuclear Review Board (NRB) 17.2.1.2.5 Set- -Zww~T

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17.2.1.3 Power Generation Group The Power Generation Group organization is under the Thedirection SeniorofVice the Senior Vice President, Power Generation Group.

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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j. 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 reports coveri evc wation, forwarding of recommendations and disposition of th corrective ad..cs to prevent recurrence to the Vice P esident,' LGS, Plant Manager, and to the NRB.

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control program, offsite Review of changes to the proce adwaste dose calculation manual, an 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 b., c., d., and f

or not eac item considered under areas 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

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3 t the NR te daibn INDEPENDENT REVIEW ZasH74e .

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((U Nuclear Review Board shall provide independent review of operating activities related to the safe operation of the station.

Its purpose is to review, audit, and evaluate both technical and 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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LGS UFSAR P 9 of /4 The NRB shall collectively have the experience and competence required to review plant operations, nuclear engineering, chemistry radiochemistry, mstallurgy,-~ nondestructive testing, cnd 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

, utilize consultants, as determined by the Chairman, to provide All Alternates to Members shall be appointed in i cxpert advice.

writing. Alternates shall serve on a continuing basis and shall be l

. 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 l only when the Member for whom they are the Alternate is absent. The NRB may appoint, in writing (such as in Board meeting minutes), l 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 I

PBAPS/ LGS ,

I Members Position  !

Chairman NRB Chairman Vice Chairman / Member Director - Nuclear Qualiti- Assurance  ;

Member Vice President - Limerick l Member Vice President - Peach Bottom Member Vice President - Station Support 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 Two additional members of the NRB are not employees of PECo.

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N[k Ede zBys/WA LGS UFSAR [*/d The Nmbers and alternates of the NRB will be competentthe in the area Quality of Quality Assurance practice CFRandSh_cognizant Appendix B.of Additionally, Assurance requirements of ,10 they will be cognizant of the Corporate Quality Quality Assurance Assurance Programorganization and will have the Corporate 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.

reviews or QSfkth/N under the and those performing

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The NRB, cognizance of the NRB, shall have access to recordsThe and personnel 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.

l The NRB shall meet at least onceAper six months quorum shallorconsist more often as of the determined by the Chairman.

chairman, or Vice Chairman,No and at than more leastafour, minority but'not of theless

. than 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, or experiments equipment or systems and 2) tests to verify completed under the provision of 10CFR50.59, that such actions did not constitute an unreviewed safsty question.

b. Proposed changes to procedures, equipment or systems that involve an unreviewed safety question as defined in 10CFR50.59.

c. Proposed tests or experiments that involve an unreviewed

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safety question as defined in 10CFR50.59.

d. Proposed changes to Technical Specifications or the operating license prior to submittal to the NRC.

e. Violations of applicable statutes codes, regulations, l orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance. This shall normally be accomplished by review of PORC meeting minutes, special reports, or reports of audits.

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f. Significant operating abnormalities or deviations from~ l normal and expected performance of unit equipment and the l 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.

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! 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

) 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.

Minutes of NRB meetings and reports of actions taken shall be

'l 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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NQA is responsible for the planning.,. performance, reporting, and l. ~-

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 written procedures by NQA personnel, who are independent of any direct responsibilities for the performance of activities which they l will assess.

NQA may request the assistance of personnel from other g disciplines or technical specialists who are independent of areas baing assessed.

l shall establish the assessment program personnel The Director, NQA, for the use of technical qualifications and the requirements assessment of the Quality Assurance l cpecialists to accomplish the shall be selected for quality assurance Pregram. Personnel experience or training which l on assessment assignments based establish that their qualifications are commensurate with the 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, 17.2.18,6 [gggg7[ j -

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J s s m ._ , ,7 _t_ w . j 3,_ ,_ n ; _ _ _ l an afety importance of the activities. The following activities of assessed at least every 2 l the Q ty Assurance Program shall be as otherwise indicated:

years, ex 7

a. Trainin nit staff is assessed annually)

b. Health Physics

c. Chemistry

d. Fuel /In-vessel Material

e. Shift operations .

f. Surveillance Testing

g. Maintenance of Instruments G.V 17.2-63 ch i . 4 " f./9d ___

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i. Maintenance /I&c .i .

j . Pr rement

k. Modific ions l '. Radioactive ' ste Material

m. Plans - Includes.

Fire Protection *Pla Emergency Plan (asses d annually)sessed annually)

Physical Security Plan onitorinti Program radiological Environmenta (assessed annually) ,

n. Nuclear Engineering. .

l Otherareasthatshallbesubjecttoscheduledahessmentsinclude control of cifications, preparation, review, approval', and drawings; documents, instructions, procedures', '

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procurementreceiving and installation inspections; and vendor activ Regularly scheduled assessments may be supplemented by unannou ' d or j , _ , .

. unscheduled assessments or surveillances as determined by NQA.  !

17.2.18.7 procedures shall require that l Assessment and surveillance  !

nonconformances are identified be documented in sufficient detail to assure which 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 l' Responsible management shall take the necessary action to correct any identified deficiencies and to report the cause of the deficiency and 1

j the corrective action to NQA.

Unless justified in writing as not l' appropriate, corrective action intended to prevent recurrence shall also be taken and reported.

17.2.18.9 indicated, follow-ups or  ;

When corrective action measures are "

re-assessments of applicable areas shall be conducted, to assure q

l implementation and effectiveness of corrective actions.

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'O k"7activities in the following areas shall be '

performed under the cognizance of the'NRB: .

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a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable

• I License conditions at least once every months.

of . . . . . . _ .

. b. The performance, training and qualifications of the -

operating staff at least o 'nce every te months.

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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.

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d. The performance of activities required by the operational l quality assurance program to meet the criteria of l 10CFR50, Appendix B, at least once every 24 months.

e. The Emergency Plan and implementing procedures at least i once every 12 months. l i

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.

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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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1. WF4WD 2._21t shall include verification of compliance and effectiveness 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

and Chief Nucly ficer and management having l President ~ within 30 days after completion l responsibility in the areas _.b the c_litir

• organization.

- of the AW4H taint gg shall be performed by te Nuclear Quality Assurance  ;

?' s who have l D:partment or by specially selected groups or o the activity theyindivi u and do not, l no immediate responsig _,

. while performing the _ __gf port who has immediate responsibility for the to a management representative including re- if1'are appropriate, Timely follow-up action, ,

chall be taken when deficiencies!?*Et49Ad/ are noted. ]

ph am and..schedul shall be reviewed semi-annually by ,

The l the NRB to ensure that' the 2" Aite areC'c. being performed in accordance

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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.

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j Asssssment results shall be analyzed and a statement regarding-the l

sffectiveness of the QA Program in the areas assessed shall be l included in the Assessment Report. '  :

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nce of the Nuclear Review l l Aesessments performed

• In Section 13.4.

I i 17.2.18./ldir i l l Tha assessment program shall be periodically reviewed and revised as 1 nscessary to assure that coverage and schedule reflect current activities.

17.2.18. //d l The Director, NQA,. is responsible to identify overdue corrective l

l action to the appropriate responsible management." .

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