ML20087H041

Application for Amends to Licenses DPR-44 & DPR-56, Consisting of Change Requests 94-11,94-12 & 94-13,relocating Certain Review & Audit Requirements to Plant UFSAR

ML20087H041
Person / Time
Site:	Peach Bottom
Issue date:	04/10/1995
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20087H045	List: ML20087H041 ML20087H049
References
NUDOCS 9504180299
Download: ML20087H041 (6)

Text

Etation Support Dep;rtment

,3 - o , 10 CFR 50.54(a)(3)(i)

^ 10 CFR 50.90

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PECO ENERGY Nuclear Group Headquarters 965 Chesterbrook Boulevard Wayne, PA 19087-5091 April 10,1955 Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 U. S. Nuclear Regulatory Commission Attn; Document Control Desk Washington, DC 20555

Subject:

Peach Bottom Atomic Power Station, Units 2 and 3 Responsef> RMuest for AdditionalInformation Regarding Technical 6pWl, cations Change Requests 94-11,94-12, and 94-13 and Proposed Change to Quality Assurance Program Description

Dear Sir:

Attached is our response to your Request for Additional Information (RAI) dated February 23, 1995 regarding our request to relocate certain review and audit requirements to the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, Updated Final Safety Analysis Report (UFSAR). Attachment 1 to this letter provides a restatement of the RAI followed by our.

response.

As Indicated in our response, the review and audit requirements will be relocated to the Quality Assurance Program Description (QAPD), which is controlled by 10CFR50.54(a)(3); accordingly, we are also proposing a change to the frequency for performing certain audit requirements which would now constitute a change which reduces the commitments in a previously accepted OAPD and requires prior NRC approval in accordance with 10 CFR 50.54(a)(3).

A change in frequency is proposed for audits of plant activities in the following areas:

1. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions from once every 12 months to once every 24 months. In accordance with 10 CFR 50.54(p), an audit of the security plan and implementing procedures will continue to be performed at least once every 12 months.

In accordance with 10 CFR 50.54(t), the emergency plan and implementing procedures will continue to be audited at least once every 12 months.

2. The performance, training and qualifications of the entire facility staff from once every 12 months to once every 24 months.

3. The results :)f actions taken to correct deficiencies occurring in facility equipment, structures, systems or mm.od of operation that affect nuclear safety from once every six months to once every 24 rr.onths.

4. 7.te performance of activities required by the Ouality Assurance Program regarding the radiological monitoring program to meet the provisions of Regulatory Guide 4.1, Revision 1. April 1975, from once every 12 months to once every 24 months.

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N , audits are regimentaHy scheduled on tho' basis cf annual and'sk month frequency requirements without due consideration of the need for audit in view of performance as indicated - i by empirical data, events, and trends." This can result in inappropriate allocation of assessment resources when other areas are in need of an audt as indicated by performance data. Audts, to be effective, must be performed on a frequency commensurate wkh their safety significance and with due consideration of performance data.- The change in frequency for audits to biennial wul enable management to mal e audit scheduling decisions and allocate assessment resources

> based on performance data relating to each audit activity. This mode of operation is further substantiated by the fact that during the interval between audits, survellances are conducted to 1

. provide for progressive assessment of functional performance. J j

ANSI N18.71972 states, " Audits of selected aspects of plant operation shall be performed with a ]

frequency commensurate with their safety significance and in such a manner as to assure that ,

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an audt of safety-related actMties is completed within a period of two years." PBAPS is committed to this standard which supports the proposed change in frequency for activities 1,2, -j and 3 identified above. 1 l

A review of Regulatory Guide 4.1, Revision 1, AprE 1975; Regulatory Guide 1.33, November 1972; ANSI N18.7-1972, and other documents (e.g., PBAPS Safety Evaluation Report, Regulatory Guide 4.8, etc.) could not identify a specific frequency for activky 4 identified above. Audits on a  :

biennial frequency would align this activity (UFSAR Section 17.2.18.1.j) wkh all activities not -  :

otherwise specified at a shorter interval by the Code of Federal Regulations (UFSAR Sections 1 17.2.18.1.e and f). OveraH, the Nuclear Quality Assurance Master Audit Plan (MAP) encompasses 50 audt areas.

In summary, changing the audit frequency for the four activities identified above does constRute '!

, a reduction in commitment relative to the frequencies described in the QAPD; however, the l change in frequency does not reduce the PECO Energy commitment to quality, compliance with 10 CFR 50 Appende S, or the effectiveness of the assessment program on the basis of the I

following:

1. Requirements for sk month and 12 month frequencies for the noted audit areas are not . t contained in the Regulatory Guides and Industry Standards identified in UFSAR 1

.- Appendk 17.2.A. j

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2. Audit areas will be scheduled according to their safety significance and empirical performance data such as trends, events, and surveNiance results. .

3. Allocation of assessment resources wNI be based on performance data and thereby provide for timely assessment coverage of areas which warrant oversight attention. -

4. Assessment resources wRI not be dButed by unnecessary calendar driven oversight of ,

audit areas which are performing at a high and steady rate. ,

5. Surveillances are conducted during the two-year audit frequency interval which provide .l

<. for progressive assessment of functional performance.

The proposed changes in the QAPD related to audit frequencies are provided in Attachment 2.

Changes to the QAPD were previcuely proposed with respect to the independent Safety Engineering Group (ISEG) in our letter dated November 14,1E04. To clartly that 10 CFR  !

50.54(a)(3) wNI control future changes, information that had been proposed for inclusion in i UFSAR Section 13.8.6 wgl now be located in PBAPS UFSAR Appendk D. Revised pages '

reflecting the proposed changes in the QAPD related to ISEG are provided in Attachment 3. -

Additionally, we request that our original Technical Specification Change Request dated ,

November 14,1994 be revised as follows.  ;

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-e (1) the requirements of Technical Specification (TS) Section 6.5.2.7 wRI be relocated to the PBAPS QAPD such that they wil be controlled by 10 CFR 50.54(a)(3); and (2) the requirements of TS Section 6.5.2.10 be revised to delete reference to TS Sections  !

6.5.2.7 and 6.5.2.8.

]

Revised pages 252 and 252a for each Unit are enclosed at Attachment 4. We have concluded that the proposed revision does not affect the conclusions previously submitted with our original submittal regarding a safety assessment, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

If you have any questions, please contact us.

Very truly yours,

$ .0 U G. A. Hunger, Jr.

Director - Licensing JLP/esr

Enclosures:

Affidavit, Attachment 1, Attachment 2, Attachment 3, Attachment 4 cc: T. T. Martin, Administrator, Region I, USNRC (w/ enclosures)

W. L Schmidt, USNRC Senior Resident inspector, PBAPS (w/ enclosures)

R. R. Janati, Commonwealth of Pennsylvania (w/ enclosures) 1 M. C. Modes, Chief, Materials Section, Region I, USNRC (w/ enclosures) r i

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COMMONWEALTH OF PENNSYLVANIA  :

COUNTY OF CHESTER  : l l

i W. H. Smith, lil, being first duly sworn, deposes and says:

-t' That he is Vice President of PECO Energy Company, the Applicant herein; that he has read the Enclosed 1 Response to the NRC Request for Additional information dated February 23,1995, concerning Technical Specifications Change Requests (Numbers 94-11,94-12, and 94-13) for Peach Bottom Facility Operating 'j Licenses DPR-44 and DPR-56, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

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Vice President Subscribed and sworn to before me this /0 N day #

of 1995.

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1 E1 j f f Notary Public Notana! Seal Erica A.S.tet Notary MAC MyCort m E M 0 905

• 's O ,

e 4 r ATTACHMENT 1

.. ,: . , Docket Nos. 50-277 -

50-278

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License Nos. DPR-44 DPR-56 Response to Request for Additional Information Peach Bottom Atomic Power Station, Units 2 and 3 Question PECO proposes to relocate the audit topics and frequencies in Technical Specification (TS) Section 6.5.2.8 (Nuclear Safety Review Board [NRB]) to the Peach Bottom Updated Final Safety Analysis Report (UFSAR) and eliminate the reference to NRB audits in Environmental TS Section 7.1.

The staff finds that additional information wHI be needed to complete the review. WhRe the relocation of the items to a licensee controlled document is acceptable, the staffs position is that the audit topics and frequencies should be relocated such that they be will be controlled by 10 CFR 50.54(a)(3), i.e., Section 17 of the UFSAR or the OAPD. Please provided descriptions as to where these items will be relocated.

Once this information is received from PECO, additional consideration of this specific change to relocate the audit topics and frequencies in TS Section 6.5.2.8 NRB to the Peach Bottom UFSAR and eliminate the reference to NRB audits in Environmental TS Section 7.1 will be pursued.

Resoonse PECO Energy proposes to relocate audit topics and frequencies in TS Section 6.5.2.8 to the Peach Bottom Atomic Power Station Quality Assurance Program description such that they wDI be controlled by 10 CFR 50.54(a)(3). PECO Energy also proposes to change the reference in Environmental TS Section  ;

7.1 from Section 6.5 of Appendix A to the Operating Ucense to the Quality Assurance Program as contained in proposed Environmental TS page 48 transmitted with our letter dated November 14,1994.

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