ML20096A509
| ML20096A509 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 05/04/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9205110092 | |
| Download: ML20096A509 (11) | |
Text
~
PIIILADELPIIIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERilROOK IILVD.
WAYNE. PA 19087-5691 (215) 640-6000 NUCI E AR ENGINEI RINO A $! RVICES DEPARTMENT May 4, 1992 Docket Nos. 50-277 50-278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 U.S.
Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Peach BottGm Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Request for Approval of a Change to the Quality Assurance Program Descriptions Supplementa1 Information Gentlemen Our letter dated December 13, 1991, requested approval of a change to tl.e Quality Assurance (QA) Program Descriptions incorporated l
jn the Updated Final Safety Analysis Reports (UFSARs) for Peach Bottcm I
Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Generating Station (LGS), Units 1 and 2.
The December 13, 1991 letter submitted proposed changes to the QA Program Descriptions by including the marked-up affected pages from the PBAPS and LGS UFSARs.
As a result of subsequent discussions with J. Caruso, NRC Region I, and NRC letters dated January 27, 1992, this letter submits revised changes to certain of the affected UFSAR pages.
The remaining marked-up UFSAR pages provided by our December 13, 1991 letter are unaffected by the revised changes.
In addition, we have modified the commitment concerning a biennial audit of the procedural development program proposed in our December 13, 1991 letter as described below and reflected in the marked-up UFSAR pages provided in the attachments.
g, I -l hh d[ f)[(, I k/S{M
$R O
O 7
t
- - -....~ -.-.-. _ - -
U.S.'Nucicar Regulatory C.vission May 4, 1992 Page 2 W
The specific UFSAR pages incorporating the revised changes are provided in Attachments I and 2 for PBAPS and LGS, respectively.
The revised changes involve delineation of the programs and processes described in our December 13, 1991 letter that assure procedures are maintained current in lieu of scheduled periodic procedure reviews.
The primary mechanism to validate that tne delineated programs and processes are maintaining the procedures is our assessment process.
This process is comprised of both individual organizational self-ascessments and the independent assessments conducted by the Nuclear Quality Assurance organization.. These assessments will provide a high degree of confidence that the delineated programs and processes are effective in maintaining procedures current.
If you have any questions or need additional information, please contact us.
Very truly yours, l nl Y f G. J.
eck, Manger Licensing Section Attachments 1
cc T.
T. Martin, Administrator, Region I, USNRC w/ attachments J.
J. Lyash, USNRC Senior Resident Inspector, PBAPS w/ attachments T.
J. Kenny, USNRC Senior Resident Inspector, LGS w/ attachments l-l l
l l
-.a
-._.___..,.:,......a.;_.--.,
4 ATTACHMENT 1 Peach Bottom Atomic Power Station 4
4 w
emu
_.___._________m.m.
_s._._
_.m
1
(
PBAPS 1he Materials Section and Purchasing Department shali only 17,2,a.7 process apprcved requisitions in accordance with PECO procurement procedures and policies.
17.2.4.7.1 The Purchasing Department shall not alter the technical information or quality assurance requirements on a recuisition of any procurement classificaticn identified as QS, QV, QD cr M item witnout, specifically requested prior, written approval of the requisitioning crganintica.
17.2.4.s The precurement dccument for 05 and QV items shall include a provision for the right-of. access to vendor f acilities for inspection er audit purposes.
17.2.4.9 Procurement documents shall be taintained in accordance witn section 17.2.17.
17.2.5 Instructions, Procedures, and Drawinas
-17.2.5.1 Activitir' associated with the implementatien of the Nuclear Quality Assurance Program shall be described and ace:mplished in accordance with appropriate instructions, procedures, aH
- 1NSERT A^
drawinas.
- Administrative procedures shall be written for l
safety'related activities and approved by the appropriate management. QA s M ll review and approved administranve procedures.
17.2.5.1.!
.PBAPS Administrative Procedures shall be written by the plant staf f, reviewed by the PORC, approved ay the Plant Mana;Er or an appointed designee and the site Quality Manager - HQA, and dis,tributed to predetermined personnel.
17.?.5.1.2 These Administrative Procedures shall contain provisions which clearly delineate the sequence of actions for the preparation, review, approval, and control of activity implementing procedures, instructions and crawings. Exhibit XI delineates the manner in which the criteria of 10CFP30, Appendix B, are implemented for each plant activity, D 11-27 P,ev. 9, 07 /91 g
Proposed
m_.
s/^
PBAPS APPENDIX 17.2A
-REGULATORY Gul0ES AND ANSI STANDARDS NUCLEAR GROUP OPERATIONS PHASE QUAllTY ASSURANCE PECo will follow the QA guidelines included in WASH 1284 (10/26/73),
" Guidance on Quality Assurance Requirements Ouring the Operations Phase of Nuclear Power Plants"; WASH 1309(5/10/74)-GuidanceonQualityAssurance
- Requirements. 0uring tne Construction Phase of Huciaar Power Plants"; WASH 1283. (5/24/74) " Guidance on Quality Assurance Requirements During Design and Procurement Phase' of Nuclear Power Plants" - Rev.1; and -other Regulatory _ Guides and Industry Standards applicable for operations of.PSAPS as described in this Appendix.
The Peach Bottom GA Program is described by the PBAPS QA Plen.
PECo has conducted an extensive review cf the above listed WASH documents The standards were along with the Regulatory Guides and Industry Standards. reviewed wi
-phase that are comparable in nature and extent to related activities The recommendations and occurring during initial-design and construction.
a guidance.of the Regulatory Guides and ANSI Standards which are applicable to
_: nuclear _ plant operations are incorporated in the PSAPS QA Plen.
-Administrative and implementing procedures-affected by any revisions of the PBAPS-QA Plan will be. revised as required in accordance with Administrative
~
Procedures.
- nc ANSI Referenced guides or standards addressed by the Regulatory G;ide:
Standards are excluded unless addressed separately.
1.; Reculatory Guide 1.8 - 3/10/71, Personnel Selection and-Training. Endorses ANSI N18.1 1911.
COMPLY ~
=.,.
0.11-51 FOR'INFORMATION ONLY a'
9, 07/91 I
_1_
_ -___ - _ _ no _ __ -
_ _ _r_ ' -
-i
FBAPS ANSI N45.2.4, Section 6.2.1, Ecuicment Tests, Installed items requiring e.
calibration are controlled thrcugh the preventive maintenance ccmpu:er tracking system. Tags or labels are not affixed to the item to indicate calibration status.
- 4. Reculatory' Guide 1.33 - November 1972, Quality Assurance Program Requirements (Operatien).
PECo shall comply with Regulatory Guide 1.33,11/72, which endorses ANSI H45.2 - 1971 and ANSI H18.7 - 1972 exclusive of other documents referenced.
j
- INSIn 3
- 5. Regulatory Guide 1.37 - 3/16/73, QA Requirements for Cleaning cf fluid Endorses ANSI Systems and Associated Ccmpenents of Water-ccoled NPPs.
H45.2.1 - 1973.
Decontamination and cleanup of radicactive c:ntaminated systems and components are not included in the scope of this response.
PECo shall comply with Regulatory Guide 1.37 - 3/16/73 and ANSI H45.2.1 -
1973Property "ANSI code" (as page type) with input value "ANSI H45.2.1 -</br></br>1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for those activities occurring during the cperational phase that are comparable in nature and extent to related activities occurring during the initial design and construction phase except for the following al trnate:
ANSI H45.2.1, Section 3.2, Water Ouality Recuirements - pH measurements a.
are not required for conductivity values of less than or equal to 1 umho/cm. PECo utilizes pH limits of 5.2 to 8.6 at 25 C, uncerrected for CO2 and may apply conductivity measurements in place of total dissolved solids.
- 6. Reculatory Guide 1.38 - 3/16/73, QA Requirements for Packaging, Shi;cing, Receiving, Stcrage and Handling of Items fcr Water-cooled NFPs. Enerses ANSI H45.2.2 - 1972.
PECo,shall comply with Regulatory Guide 1.33, 3/16/73, and AH51 N:5.2.2 -
1972 for those activities occurring during the operational pha:e tnat.a:e comparable in nature and extent to related activities occurring during the initial design and construction phase except for the following alternates:
ANSI N45.2.2, Paragraph 2.7, Classification of items - PECo does not a.
classify items into the four (4) levels described in this Standard.
However, the specific guidance and reccamendations which are appropriate to each class are applied to those items packaged, shippec 0.11-53
?HPMo Rev. 9, 07/31
1 1
Insert A Programmatic controls and processes described 1 Item 4 of UFSAR Appendix 17.2A are in place to assure that procedures are maintained current.
These controls take the place of, and eliminate the need for scheduled periodic reviews and revisions.
insert B Add:
except for the following alternatet a.
the following programmatic controls and processes are used to assure that procedures are current.
These controls take the place of scheduled periodic reviews.
Plant modif.ication process.
Amendments to the Technical Specifications.
Programs governing the identification, documentation, and initiation of procedural improvemente.
Temporary procedure changes.
Nuclear Quality Assurance assessment activities.
In-House Event Investigation Program.
Operating Experience A-sessment Program.
Vendor Manual Program.
Procedure change tracking and trending process.
Line organizations that have responsibility for procedures or procedure cetegories will perform biennial self-assessments of the appropriate components that comprise the procedural development program in accordance with established guidelines.
These self-assessments will provide a high degree of confidence that the programs and processes identified above are effective in maintaining procedt;es current.
In addition, the Nuclear Quality Assurance (NOA) organization will assess the programs and processes identified above as part of the NQA assessment function that includes audits and surveillances.
(
t I
I l
I i
i b
r l
l ATTACl! MENT 2 Limerick Generating Station
~,
I l
l 6
i k
i i
i I
I L
l i
i:
?
l
{
i t.
l l
l i
i i
.l i
- l
l l
LGS'UFSAR Sectien' 5.2.13.1, 17.
NISI
'N18. 7-197 6 pdi$
3.2, Procurerent and Docurent Control, (second sentence)
QA Program requirenents or ' alternate' approved methods will be used to ensure quality.
Examples of alternates for suppliers withcut. 0A prograns
- include:
material analysis, sample testing, in-process inspection and nonitoring, and design review by PEco.
- 18. ' ANSI N18.7-1976/ANS 3. 1, Section 5.2.15, hyirL Acerovd and Control ef"Plecedures - The frequen:y of review of plant procedures is discussed in UFSA..
[
3 Section 13.5.*
- I55Eil A 19.
NiS1 N18.7-1976/ANS 3.2, Section 5.2.17, Insuections. - The results of inspections are net always subject to a further evaluaticn.
Fcr
- example, evaluatien beycnd that given by inspectien-level personnel is not ner: ally required for go/no-go and pass /f ail type inspections.
20.
ANSI N13.7-197 6/NIS 3.2, Section 5.3, Precaretics of Instrug ions and Procedures (last centence)
The clarification regarding energency maintenance in Item 12, above, applies.
21.
MISI N18.7-197 6/ ANS 3.2, Section 5.3.10, Test,_cd Inspection Procedures, (first paragraph)
The clarification regarding test result svaluations in Item 19, above, applies.
22.
ANSI N18. 7-197 6 / ANS 3.2, Section 5.3.10, Test ens Insnection Procedures, (second paragraph, last These precedural aspects will te sentence) included when appropriate.
Fcr eunple, "as-fcun:.
condition" is not applicable to all. test end inspection procedures.
f d.
E3erulatorv Gulf [1. 37, March 1973, " Quality Assurance 3
Requirements f or Cleaning of Fluid Systems and Associated Components of Water-cooled Nuclear Power Plants."
Endorses ANSI N45.2.1-1973.
Decontamination and cleanup of radioactively contaminated systems and cceponents are not included in the secpe of this response.
Proposed 17.2.II-6
'3.5
_F I..A_N.T_ PROCEDURES-Sa f ety-relr ted activities perforned by the plant staff shal) he coverned by written and approved procedures of a type appropriate to the circunstances and activity, and shall he carried out in accordance with those precedures.
Where appropriate f:r determining that important activities have been satisfacterily accompliched, quantitativo or qualitative acceptance criteria chall be included, pEco utilices the operating experience gained at PEAPS Units 2 &3 (BWR units similar to LOS) in the development of the procedures.
As fully described belev, PEco has inplencnted ANSI U18.7 (1976)/
ANS 3.2, Section 5 as ncdified by NRC Regulatcry Guide 1.33 (Rev 2), paragraphs C.1 and C.5.b thrcugh C. E. j, as these docutents apply to operating staff activities, in the preparation, centent,
- INSEM B - and-control of procedures.
l Sections 13.5.1.1 through 13.5.1.25 describe adninistrative precedures.
Many of these sections descrite hcw varicus precedure types (such as naintenance procedures cr preventive raintenance develeped end centro 11ed, whereas other secti:ns procedures) are describe an administrative process (such as purchasing).
We s t at e d--o t-h erw i-s c i n-t h e-s e e di e n s-whi-ch-d ece-b e-hm-vedn----
-p r e c e d u r c-t-y p e o-a r e -d ev eh p e d-e n d-c o n t reler-t-he -Fe ded i : rev w e E-th c-p r o c e d u r e s -w i 1-1--b e-o n-a-3-ye a r-basbr---Mes t. t het-*i+1-b+
r++iewed-wath-e-r-year-$recuency-are-previdW #ie--raties4+ r.+
support-this-pcc-i-t4cn.
Each - c f - the-rationaler-rests-a-t-Lcast-in-per4-uperrthe-poshha that-the-nere-pas s ase--of--tice-le-not-suf-f-hi+nt-re n en t: r;vi+v-e preeedur: Sor-edequ acy, Ec.'M~-standeed-thet-reemends-t-he- ^--
year-f requency-doc s-not-pr+v-ide-a-basio--far-the-selest44r. c ! :
vec es r-S o m e t h im o-m u st-o c c u r-d u r-ing-th e--p as sage-of-th e-eat-+:4d h+ko-the-r-eview dr-r-evi-s4+r -f+preceduroarr-+pprepr4ete-est4c te takt.
' t-should -beH,oted-t het--centr c l i c i-reviews + Whip *nt-er sust em-r.cdif-icat ion s-ra sult-in-t h e-r+ view-ef-appi-i-ab4e v.ecede m f ar-the-potenthl-ef-f4eb--Of-thc-DOdi-I-iOE-t49n.
IJ ;ddhitn, ste-ndard-pract4ees-regarding-rev-ieur4-response-ta-?ccmarAr -such as---NRC-Bulleting r---CiMula r-G-and-Nothe s,
ISE4-dseusents n#r ndustcy-documentrs-that-+re--GCr4GRGd-- h2 tM --Op er ati"{ PTCri e"~
- Assessment-Pr-egran-and-f+Fwtrded M wien--by-the-pl:.nt--stMf-:tra 1-n-dec e and c-ause-precedurec tc-b6--r+%iewed-a nd-r+vi-c ed a c-epprIopr4crte-in-r+1st4+n-tc the--r+%i4W +f theM - 1 n3i4100+':-
-d ecume-nt-s.
h.
.;>4 13.5-1
4 Insert A Add:
"except for the following alternative:
a) programmatic controls and processes described in UFSAR section 13.5 are used to assure that procedures are current.
These controls take the place of scheduled periodic reviews."
Insert B "The following programmatic controls and processes are in place to assure that procedures are maintained current.
These controis take the place of, and eliminate the need for, scheduled periodic reviews and revisions."
Plant modification process.
Amendments to the Technical Specifications.
Programs governing the identification, documentation, and initiation of procedural improvements.
Temporary procedure changes.
Nuclear Quality Assurance assessment activities.
In-House Event Investigation Program.
Operating Experience Assessment Program.
Vendor Manual Program.
Procedure change tracking and trending process.
i Line organizations that have responsibility for procedures or procedure categories will perform biennial self-assessments of the appropriate components that comprise the procedural development program in accordance with establiced guidelines.
Thene self-assessments will provide 6 high degree of confidence that the programs and processes identified above are effective in maintaining procedures current.
In addition, the Nuclear Quality Assurance (NOA) organization will assess the programs and processes identified above as part of the NQA assessment function that includes audits and surveillances.
_ _. _