ML20099B171
| ML20099B171 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 07/23/1992 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207300224 | |
| Download: ML20099B171 (2) | |
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERDROOK DLVD.
July 23, 1992 WAYNE. PA 19007 5691 Docket Nos. 50-352 tem so4ooo 50-353 50-277 50-278 License Nos. NPF-39 NPF-85 DPR-44 DPR-56 U.S.
Nuclear Regulatory Commission Attention:
Document Control Desk Washington, DC 20555
Subject:
Limerick Generating Station, Units 1 and 2 Peach Bottom Atomic Power Station, Units 2 and 3 Request for Relief from Commitment to Audit All Provisions of Technical Specifications within a Fixed Period The Philadelphia Electric Company (PECo) requests relief from its current practice of auditing all major paragraphs of the Limerick Generating Station (LGS), Unita 1 and 2, and Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, Technical Specifications (TS) over a four year period.
The practice was developed in direct response to an NRC inspection concern for LGS Unit 1 prior to issuance of the operating license for Unit 1 as documented in NRC Inspection Report 50-352/84-21.
The concern was closed in NRC Inspection Report 50-352/84-56, based on specific revisione to PECo Quality Assurance Division Procedures (QADPs).
Those same procedures were and continue to be applied to PBAPS, Units 2 and 3.
Considerable resources are expended in performing and tracking audits of all TS paragraphs to assure full coverage within four years, at both stations.
Since NRC closure of this item, the Nuclear Quality Assurance (NQA) organi ation has enhanced its oversight capabilities.
We consider that devoting our resources to this oversight program, composed of performance and compliance based assessments, surveillances, monitoring, and independent safety engineering, is more effective.
Accordingly, thesa oversight activities are applied to areas affecting plant l
A safety, risk levels, and reliability in a manner which considers ir \\
current plant conditions, work activities, plant performance ig indicators, and industry issues.
As part of these oversight n
activities, compliance with the applicable TS is evaluated.
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I 9207300224 920723 PDR ADOCK 05000277 P
U.S.
Nuclear Regulatory Commission July 23, 1992 Do'cument Control Desk Page 2 this request is approved, the evaluation of TS compliance conducted during performance of oversight program activities will include prior findings, TS changes, and will ensure that the overall sample of items reviewed is not narrowly scoped.
We bave concluded that this is consistent with the direction that the NRC and the industry are moving as described in NUREG/CR 5151,
" Performance Based Inspections," and NUREG-0800, " Standard Review Plan," Section 17.3, " Quality Assurance Program Description, Revision 0."
Please note that this request is similar to the change requested by Detroit Edison, and approved by the NRC in its letter dated October 16, 1990 (copies attached).
PEco will continue to perform the TS audits as required by LGS and PBAPS TS Section 6.5.2.8, including the annual audit of the conformance of unit operation to provisions contained within the TS and applicable license conditions as required by TS Section 6.5.2.8a.
This audit will concentrate on the following four areas:
(1) Full Power or Startup Limiting Conditions for Operation (LCO), (2) the Surveillance Test Program, (3) Clearance and Tagging, and (4) Temporary Plant / Circuit Alterations.
While
" Clearance and Tagging" and " Temporary Plant / Circuit Alterations" activi'.ies are not traditional TS compliance audits, our experience has shown that these audits provide valuable o'arsight of compliance of plant activities to the TS.
Please contact John B.
Cotton at 215-640-5620, if any further information is required.
Sincerely,
>/
0Le?,'x f G. J.-Neck, Manager Licensing Section Nuclear Services Department Attachments cc:
T. T. Martin, Administrator, Region I, USNRC T.
J.
Kenny, USNRC Senior Resident Inspector, LGS J.
J.
Lyash, USNRC Senior Resident Inspector, PBAPS b
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Detroit 6400 North D Edison mars.seHgomav Ju1r 2. 1990 m>ta'_
1HC-90-0091 U. S. Ibclear Figulatory Comission Attention: Dccu::nnt Control Desk Washington, D.C. 20555 Ecferences:
- 1) Fermi 2 inC Dccket tio. 5')-341 IUC License 11o.13PF-43
- 2) NIC Inspcetion Ecport 13o. 50-341/E6011, datcd June 13, 1986
- 3) NIC Insptction Ecport 130. 50-341/87028, datcd Cetober 16, 1987
- 4) Detroit Edison letter IUC-88-0237, dated Cetober 18, 1988
- 5) IUC letter datcd August 24, 1989
Subject:
Deletion of 1001L Audit Coverage of Technical Srecification Line Items x
In April 1986,1GC Insgction 86011, Cpen Itcra 13o. 4, statcd that Fermi 2 did not have a dccurented policy for the tire frare in which to conplete 100% audit coverage of the Technical Speciff :ation line ite:as. Subsequently, Detroit Edison developed a program and revised.
the applicable procedures to establish a five year tinn frame;in which i
to coupletemuch aJdits. The five year time franc began with fuel.
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loa 3ing:3n. March of 1985.
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hk Line Item tbtrix which would enable ranagerent to assign and track the In August.1986, Detroit Edison daveloped a Technical Specification 2-X
.F-Technical Specification line iters for audit purposes. Approxirately three ran nonths were spnt on this effort.
The first Technical Spccification line item audits began in June 1987. The first five year cycle was conpleted in }brch 1990. During that cycle of audits, the audit program did not identify any violation of the Technical Specification sections 2. 3 and 4 iters.
In 1989 alone, Detroit Edison spent in excess of 3770 ran hours cen3uctinj Technical Spe::ification line item audits. During the five year cycle approximately 15,000 ran hours were spent with no significant findings.
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U. S. !bclear Fegulatory Ccrnission IGC-90-0091 July 2, 1990 Page 2 The comitnent to audit 1006 of all the Tex:hnical Specification line ite:a overy five years hzu required significant Cuality Assurz.nce (CA) resources. Rather than adhere to a strictly prescribcd conpliance-bastd schcdule, CA should have the flexibility to focus audits in suspctcd weak performance areas or on itms significantly affecting plant safety and reliability.
Our preference is to continue to inglenent our performrnce-bascd auditing techniques. The perfornance-based auditing was introduccd by the IUC with !EH3/tR-5151 in June 1983. This audit concept provides nuch more tenefit for the effort expendcd than a purely conpliarce-bascd audit which is charzcteristic of the Technical Specification line item audits.
In Cctcber 1988, a request was submittcd to the IUC to grant relief from the 100% aadit of Technical Specification line iters. This request was sutsequently denicd. However, since this request has been ride, there has been increased enphasis on perforrance-based auditing. In zddition, Detroit Edison's Technical Specification Inprevenent Program has been conpleted which provided an extensive review of the Tcchnical Epecification line itms.
I Detroit Edison has concludcd that the Technical Specification line item audits hme provided little or no benefits ard is contrary to perforrance-based mditing. This Itck of benefit was discusscd with IUC (Divisjon of Fcactor Safety) personnel at the Great Lakes CA Managers neeting in May 1990. They soggested, that Detroit Edicen resubmit the request to te grantcd relief from the comitrent to -
perform 1001 mdits of the Technical Specification 1dne iters.
If you have any questions, please contzet Mr. Joseph Perdergast, y.
Conpliance Engineer, at (313) 586-1682.
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I cc:
A. B. Davis R. W. DeFayette H. Miller M. Phillips W. G. Rogers J. F. Sta.g Region III
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U. S. Ibclear Fogulatory Ccnmission IUC-90-0091 July 2, 1990 Page 3 bec:
R. Ardersen S. G. Catola/G. Cranston P. Fessler D. R. Gipsen L. S. Cadran D. Eahn Silchigan Dept./Public Health)
A. Kowalcruk/R. Matthws R. It:Keon W. E. Miller C. A. thegeli W. S. Orser J. Plena /F. Svetkovich E. Preston T. L. Riley A. C. Settles /N. Tucker R. B. Stafford R. Thorson G. M. Trahey Inforration ihnagerent - 140 tXI Secretary's Office (2412 KCB)
!TRR Chren File ISM Coordinator (316 tKC)
NSIG S<cretary FICIS Coordinator UFSAR Coordinatcr Author Licensing Engineer Pouting Copy k'
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OCT 221990 o
OCT 161E R2(.'50 Docket No. 50-941 The Detroit Edison Company ATTN:
W.
S.
Orser Senior Vice President Nuclear Generat'.on 6400 North Dixie Highway Newport, MI 48166 Gentlemen:
This refers to your letter NRC-90-0091 dated July 2, 1990, in which you requested NRC approval to delete your commitment to complete 100% audit coverage of the Technical Specification line items every five years in order to free up audit resources to broaden the application of perfor=ance based auditing principles.
The justification for the deletion was based on the fact that you
,had comp 12 Led the first 100% audit coverage of the line items, had found only one significant finding over the last four years,
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and had expended over thirty percent of the entire audit budget to perform them.
This request was discussed with Messrs. W. E. Miller, D.
- Delk, and others of your staff c3 October 9, 1990, in the Region III office.
Based on our review and evaluation of your request and the above discussion, we understand that future audits and surveillances of technical specification line items will be performance based.
In addition, we understand that the annual sampling of the line items to be reviewed will focus on prior findings, technical specification changes, and ensure that the overall. sample of items reviewed over time is not narrowly scoped.
Based on this understanding, your request is approved.
Please contact Mr. Monte Phillips of my staff (708/790-5530) with
_ any questions you have regarding this matter.
Sincerely,
[AR H
ert J. Miller, Director Division of Reactor Safety See Attacher 1 stribution
e The Detroit Edison Company 2
007 1 6 1330 Distribution
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cc:
D. R. Gipson, Assistant Vice President & Manager Nuclear Production Patricia Anthony, Licensing P. A. Marquardt, Corporate Legal Department OC/LTDCB Resident Inspector, RIII Fermi James R. Padgett, Michigan Public Service Commission i
Harry H. Voight, Esq.
Michigan Department of Public Health Monroe County Office of Civil Preparedness Fermi, LPM, NRR J.
Spraul, LPEB, NRR 6-
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