ML20125B166
| ML20125B166 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 12/03/1992 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212090236 | |
| Download: ML20125B166 (15) | |
Text
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955-65 CHESTERBROOK BLVD.
WAYNE, PA 19087-5691 December 3, 1992
- o. u. suiTH Docket Nos. 50-277 l
...... vie...... v a v c'= a a 50-278 50-352 50-353
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License Nos. DPR-44 DPR-56 NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn:. Document Control Desk Washington, DC 20555
Subject:
Peach Bottom Atomic' Power Station,-Units 2 and 3 Limerick Generating Station, Units 1 and 2 Request for Approval to Change the Quality Assurance Program Description by Eliminating the Description of the Performance Assessment Section
Dear Sir:
This letter is submitted in-accordance with 10CFR50.54(a)(3) which requires prior NRC approval for any change which reduces the commitments in a previously accepted Quality. Assurance Program description.
Philadelphia Electric Company-(PECo) is proposing to eliminate the Performance Assessment Section (PAS), formerly the Performance Assessment Division (PAD), trom the Nuclear Quality Assurance (NQA) ' organization.
The ac tivities performed by this Section are-not needed to meet 10CFR50, Appendix B requirements.
However, since a discussion of the PAS organization is contained _ in the NRC approved Quality._ Assurance Program description.-. for both-Peach Bottom-Atomic Power Station (PBAPS), Units 2 and 3 and Limerick Generating Station (LGS), Units 1 and 2, we are requesting NRC approval of the change to eliminate the PAS organization prior to implementing the change.
The PAS is specifically discussed in Appendix. D of the - PBAPS Updated Final = Safety Analysis Report (UFSAR) and Chapter 17.2 of the-LGS UFSAR.
4 wanmqr 35 p-
Nuclear Regulatory Commission December 3, 1992 Document Control Desk Page 2 i
The PAD was created in 1988, during the time that the March 31, 1987 Order to Shutdown was in effect for PBAPS, Units 2 and 3.
During that time, significant organizational changes were being implemented and many new programs and procedures were being developed.
Many of these initiatives were corrective actions associated with the root causes of conditions that led to the Order.
The function of the PAD was to evaluate these new organizations, programs, and procedures.
The intent of the PAD evaluations was to focus on the effectiveness of these organizations, programs, and procedures, while using compliance with regulations as the minimum criteria for acceptable performance.
This emphasis on effectiveness and raising performance standards above minimum requirements, -rather than solely on
,1 compliance, is consistent with the approach used by the Institute of Nuclear Power Operations (INPC).
In fact, many of the current PAS assessment techniques are based on INPO guidelines. Our intent i
was for the PAD to perform functions beyond what was required by NRC regulations and, by design, the functional responsibilities of the PAS are not part of the Quality Assurance Program that is in place at PECo to comply with 10CFR50, Appendix B,
The NRC acknowledged, in Section 2.3.4 of the Safety Evaluation Report dated October 19, 1988 for the PBAPS, Units 2 and 3 Plan for Restart, that the PAD is not relied upon for compliance with NRC regulations.
After careful consideration, we have concluded that i
elimination of the PAS will allow more efficient expenditure of PECo Nuclear Group msources.
We recognize the benefits of
(,
continuing to perform the basic functions currently assigned to PAS.
As a result of efforts to continually improve Nuclear Group l
performance, these basic functions are being and will continue to l
be performed by other organizations within the Nuclear Group.
This conclusion is based on our observations of activities related to both PBAPS and LGS, and on an evaluation which identified the basic functions currently attributed to the PAS and a determination of l
where, if anywhere, in the Nuclear Group each basic function is being performed.
A summary of this evaluation is provided as an Enclosure to this letter.
i l
As shown in the Enclosure, the PAS basic functions are imbedded in Technical Specifications or UFSAR descriptions related to other NQA organizations. The primary PAS functions of assessing performance and raising performance standards are also being performed by line organizations outside of NQA through the self assessment process; whereas, previously, these initiatives came from sources external to the line organizations.
In many cases, the self assessments conducted by line arganizations are modeled after the same INPO guidelines used by :.he PAS.
[
l
Nuclear Regulatory Commission December 3, 1992 Document Control Desk Page 3 In addition to self assessments being performed by line organizations, other changes within the Nuclear Group have evolved since the creation of the PAD.
One change is the improved audit and assessment capabilities of other groups within the NQA crganization.
These improvements are a result of the increased experience and expertise of the personnel performing the assessments and audits, and the improved assessment and audit techniques (i.e.,
vertical slice, process or performance based approaches).
Another change that has occurred since the creation of the PAD is the commitment to Nuclear Group cultural values.
These values include:
accountability, supervisory strengths, management involvement, procedure use and compliance, and teamwork.
We consider that these changes further justify the elimination of the PAS.
In conclusion, the PAD was created to perform functions beyond those required by regulations.
Consequently, elimination of PAS does not result in any failure to satisfy regulatory requirements.
4 In addition, the basic PAS functions will continue to be performed by other organizations within the Nuclear Group.
Further, PAD was created during a time when a significant number of changes were being implemented within the Nuclear Group and the ef fectiveness of these cMnges needed to be evaluated.
While change and improvements will continue to be part of the Nuclear Group, we do not expect the level of corrective action type changes to reach that which was experienced around the time of the creation of the PAD.
Consequently, we no longer see the need for the PAS functions to be performed by a single organization.
In addition, the PAD was created before formalized self assessment was being practiced extensively in the line organizations.
As indicated in previous discussions and correspondence with the NRC, self assessment by line organizations is occurring and is strongly encouraged by PECo senior management.
The other changes to the Nuclear Group discussed above that have evolved since the creation of the PAD further justify the elimination of the PAS.
i If you have any questions concerning our request to change the Quality Assurance Program description by eliminating the PAS please do not hesitate to contact us.
Sincerely,
/
1 l
Enclosure 4
cc:
T.
T. Martin, Administrator, Region I, USNRC J.
J. Lyash, USNRC Senior Resident Inspector, PBAPS T.
J. Kenny, USNRC Senior Resident Inspector, LGS 4
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Enclosure Page 1 of 12 Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2
]
Comparicon Summary of Performance Assessment Section Key Functions i
The following key functions have been identified as being assigned currently to the Performance Assessment Section (PAS)
(formerly the Performance Assessment Division (PAD)).
[1]
Independently evaluating nuclear activities with pcrticular emphasis on assessing and improving plant performance
[2]
Assessing nuclear programs
[3]
Monitoring of plant performance
[4]
Trending analysis
[5]
Observing plant conditions and activities
[6]
Conducting internal evaluations l
[7]
Performing special assignments and reviews
[8]
Reporting results of activities to Nuclear Review Board (NRB), Senior Vice President - Nuclear and Nuclear Group Vice Presidents through the General Manager, Nuclear Quality Assurance
[9]
Documenting status of activities I
i
[10) Providing technical support to NRB This list of key functions is based on a review of the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Updated Final Safety A.ialysis Report (UFSAR), the Limerick Generating Station (LGS), Units 1 and 2 UFSAR and the PBAPS Plan for Restart.
It is recognized that the PBAPS Plan for Restart is not part of the Quality Assurance Program description and, therefore, not subject l
to 10CFR50.54(a)(3).
The Plan for Restart was considered when I
performing this comparison summary to allow for compilation of a complete list of functions assigned to PAS or the former PAD.
The following two pages provide excerpts of PAS or the former PAD descriptions from these source documents.
Each excerpt is annotated with bracketed numbers.
Theso bracketed numbers refer to the key functions listed above.
=
1 Enclosure Page 2 of 12 Excerpts from Descriptions of PAS or the former PAD 4
i DOCUMENT /
FUNCTION DESCRIPTION REFEREN_U35 l
PBAPS UFSAR, The Performance Assessment Section is under the App. O, supervision of a Manager, who reports to the General 4
17.2.1.2.3.3, Manager, Nuclear Quality Assurance (NQA).
page Dll-9, and l
Performance Assessment is responsible for independently LGS UFSAR evaluating PECo's nuclear activities with particular 17.2.1.2.3.3, emphasis on assessing and inproving plant performance.
page 17.2-12
[1]
The assessments will be conducted to determine if appropriate nuclear programs have been developed, implemented, and are functioning in a manner to achieve excellence. [2]
I These assessments shall be baaed on sources of information such as monitoring of plant performance trends, QA and Quality Control reports, reports from the j
Independent Safety Engineering Groups, [3]
trend analysis, [4]
observation of plant condition and activities, [5]
the conduct of internal evaluations [6]
and special assignments, and reviews. [7]
The Superintendent will report on these subjects to the Nuclear Review Board, the Senior Vice President, Nuclear, and the three Vice Presidents through the Geaeral Manager, NQA. [8]
PBAPS UFSAR, The Superintendent, Performance Assessment Section, is App.
D, responsible for 17.2.2.10, page 4'
D.ll-20, and ascuring that appropriate programs are in place to evaluate organizational performance, [2]
i LGS UFSAR 17.2.2.16, page inputting and closure of PAD recommendations in the PIMS 17.2-26 database, [9]
and providing independent assessment of the effectiveness of Nuclear organizations. [1]
i The Superintendent will report on these assessments to the Nuclear Review Board, the Senior Vice President, Nuclear, and the three Vice Presidnats through the General Manager, NQA. [8]
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Enclosure Page 3 of 12 Excerpts from Descriptions of PAS or the former PAD (Cont.)
PBAPS Restart A Performance Assessment Section (PAS) will be added to Plan, Section Nuclear QA.
I, (Corporate Action) Page The Manager, Performance Assessment will be responsible 41.
for assessing organizational performance and providing independent evaluations of the effectiveness of the Company's Nuclear program. [1]
These assessments will be based on sources of information, such as monitoring of plar.t performance trends, QA and Quality Control reports, reports from the Independent Safety Engineering Group (ISEG), [3]
trend analysis, [4]
observation of plant condition and activities, [5]
the conduct of internal evaluations similar to those performed by INPo, [6]
and special investigations and reviews. [7]
The Manager, PAS, will report on these subjects to the NRB, the Executive Vice President-Nuclear and the five Vice Preside ~ir through the General Mgnager-NQA. [8]
PBAPS Restart PAS will be acoed to Nuclear QA with responsibility for Plan, Section assessing organizational performance and providing I,
(Corporate independent evaluation of the effectiveness of the Action), page Company's nuclear program. [1]
3.
PBAPS Restart
- Independ6nt assessment of Nuclear operaticnal Plan, Section performance. [1]
l I,
(Corporate l
Action),
- Independent evaluations of Nuclear organization
[
Figure 6, page effectiveness. [1]
39; and Section II
- Monitoring effectiveness of Nuclear Performance (PBAPS Management Program. [4]
Action), App.
D, page
- Trend analysis of performance. [4]
164
- Technical support for the NRB. [10) 1 w
Enclosure Page 4 of 12 The following table. identifies other organizations within the Nuclear Group which are also responsible for performing the PAS / PAD key functions listed on page 1 of this Enclosure.
PAS / PAD Key Function Organization
[1]
Nuclear Quality Assurance (NQA)-
Independent Safety Engineering Groups, NQA
[2]
NQA Corporate Nuclear ~ Quality Division, NQA Peach Bottom Quality Division, NQA.
Limerick Quality Division, NQA
[3]
NQA Peach Bottom Quality Division, NQA Limerick Quality Division, NQA Independent Safety Engineering Groups, NQA
[4]
NQA Corporate Nuclear Quality Division, NOA 1
Peach Bottom Quality Division, NQA Limerick Quality Division, NQA-
[5]
NQA Peach Bottom Quality Division,.NQA Limerick Quality Division, NQA Ind0 pendent Safety Engineering Groups, NQA
[6]
NQA Ccrporate Nuclear Quality Division, NQA Peach Bottom Quality Division, NQA Limerick Quality Division, NQA
[7]
Any Nuclear Group organization, upon request
[8]
NQA Peach Bottom Quality Division, NQA Limerick Quality Division,-NQA-Independent. Safety-Engineering-Groups,-NQA
{9)
NQA Corporate Nuclear Quality Division, NQA Peach Bottom Quality Division, NQA Limerick Quality Division,-NQA
__i____.i.___.-._
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Enclosure i
l Page 5 of 12 i
[10)
NQA i
Any Nuclear Group organization, upon request 4
The following pages provide excerpts of function descriptions for i
each organization listed above.
Each excerpt is annotated with bracketed numbers.
These bracketed numbers refer to the PAS or the j
former PAD key functions listed on page 1 of this Enclosure.
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Enclosure Page 6 of 12 e
Excerpts from Descriptions of Nuclear Quality Assurance (NQA) i' DOCUMENT /
FUNCTION DESCRIPTION j
REFERENCE PBAPS UFSAR, Audits of plant activities in the following areas shall 1
13.8.4, pages be performed under the cognizance of the NRBs 13.8-7 and Any other area of unit operation considered 13.8-8 m.
j appropriate by the NRB or the Executive Vice President-Nuclear. [10]
Audits shall include verification of compliance and ef fectiveness of implementation of programs, procedures, regulations, and license rovisions in the aress audited.
[2]
Written reports of such audits shall be transmitted for appropriate action to supervisors having responsibility in the areas audited. [8]
PBAPS UFSAR, The General Manager, NQA, has the following App.
D, responsibilities and authorities.
17.2.1.2.3, pages D.11-2 7.
Determine the on-going status and adequacy of the i
and D.ll-3 QA Program through regular review of QA Audits, Surveillances, Monitorings and Inspections, identification and investigation of problem areas, determination of timely and effective steps taken to correct deficiencies, and the evaluation of general plant QA/QV performar.ee through such other inputs as are available or are deemed necessary to make a reasonably objective and confident judgmsnt.
[1], [3], [5] and (6).
8.
Apprise the Senior Vice President, Nuclear; the Vice President, Nuclear Engineering and Services; the Vice President, Peach Bottom Atomic Power Station; and the Nuclear Review Board periodically of the status of the Quality Assurance aspects of 4
Peach Bottom Atomic Power Station operations, and immediately of significant problems affecting quality. [8]
I PBAPS GFSAR The Audit Program will involve compliance-based, App. D, performance-based and/or technical-based audits or a 17.2.18.1.2 combination there of as appropriate. Where it is page D.11-47 practical and appropriate (e.g., operational audits), the audits will be primarily performance-based and/or technical-based audits. [1]
PBAPS UFSAR The results of these audits and surveillances sh.ll be App.
D, documented by the General Manager, NQA, or an rppointed 17.2.18.4 designee and reviewed by management having responsibility page D.11-48 in the area audited, and distributed to appiopriate Nuclear management and other concerned supervision.
[8),[9]
l
Enclosure Page 7 of 12 Excerpts from Descriptions of NQA (Cont.)
LGS UFSAR Audits of plant activities in the following areas shall 13.4.4, pages be performed under the cognizance of the NRBs 13.4-6 and Any other area of unit operation considered 13.4-7 m.
appropriate by the NRB or the Senior Vice President, Nuclear. [10]
Audits shall include verification of compliance and effectiveness of implementation of programs, procedures, regulations, and license provisions in the areas audited. [2]
Written reports of such audits shall be transmitted for appropriate action to corporate officers and management positions responsible for the areas auditad within 30 days after completion of the audit by the auditing organization. [8]
4 3
LGS UFSAR The General Manager, NQA, has the following 17.2.1.2.3, responsibilities and authorities:
pages 17.2-6 j
and 17.2-7 g.
Determine the on-going status and adequacy of the QA Prograa through regular review of QA Audits, Surveillances, Monitorings and Inspections, 2
identification and investigation of problem areas, determination of timely and effective steps taken i
l to correct deficiencies, and the evaluation of j
general plant QA/QV performance through cuch other inputs as are available or are deemed necessary to make a reasonably objective and confident judgment.
l
[1], [3], [5], and [6).
I h.
Apprise the Senior Vice President, Nuclear; the Vice President, Nuclear Engineering and Services; the Vice President, Limerick Generating Station;
{
and the Nuclear Review Board periodically of the status of the Quality Assurance aspects of Limerick Generating Station's operations, and immediately of l
significant problems affecting quality. [8]
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l Enclosure Page 8 of 12 Excerpts from Descriptions of NQA (Cont.)
LGS UFSAR The NQA auditing program shall consist of 17.2.18.2, page 17.2-62 a.
Audits - Documented activities performed in accordance with ANSI N45.2.12 as described in Appendix 17.2.II.
4 b.
Surveillances - Cocumented activities identical to Audits except that no formal audit plan and audit checklist are generated and no exit interview is conducted if no noncompliances are identified.
Surveillances are normally initiated on short notice based on plant conditions and may include observation of work in process. [1], [5]
LGS UFSAR The results of the auditing program shall be documented 17.2.18.10, by NQA and distributed to the appropriate levels of page 17.2-65 management including the management of the audited area.
[8), [9]
1 PBAPS Restart The General Manager-NQA is accountable to the Executive Plan, Section Vice President-Nuclear fors II (PBAPS Monitoring and assessing the effectiveness of the Action), App.
C, page 157 Nuclear Performance Management Program for Excellence and providing independent feedback to line management and the Executive Vice President-Nuclear. [4]
Conducting independent evaluations of the effectiveness of the company's nuclear performance and providing feedback for line and senior Nuclear management's use. [1]
Providing technical support to the Nuclear neview Board. [10]
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S Enclosure Page 9 of 12 1
Excerpts from Descriptions of Corporate Nuclear Quality Division DOCUMENT /
FUNCTION DESCRIPTION REFERENCE l
PBAPS UFSAR The Corporate Nuclear Quality Division is under the Appendix D supervision of a Manager who reports to the General 17.2.1.2.3.4 Manager, Nuclear Quality Assurance... The Manager, pages D.ll-9 Corporate Nuclear Quality is responsible for all and D.ll-10 Corporate Nuclear Quality Division activities. This and includes:
(
LGS UFSAR Identification of specific and programmatic 17.2.1.2.3.4 deficiencies and tracking of these items until they page 17.2-2 are fully resolved. [2] and [9]
Performing trend analysis (4) 1 l
Conducting internal audits at the corporate offices. [6]
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Enclosure Page 10 of 12 Excerpts from Descriptions of Peach Bottom Quality Division, NQA 1
5 DOCUMENT /
FUNCTION DESCRIPTION REFERENCE PBAPS UFSAR The Peach Bottom Quality Division is under the App. D supervision of a Manager, who reports to the General 17.2.1.2.3.1 Manager, Nuclear Quality Assurance.
. The Manager is pages D.11-4 responsible fort and D.11-5 5.
Conducting on-site audits, surveillances, inspections, and monitorings; [3), [5] and [6]
6.
Identifying specific and programmatic deficiencies and tracking these items until they are fully resolved, in accordance with Administrative Procedures; [2), [6] and [9]
7.
Performing trend analysis; [4]
8.
Providing periodic reports to the General Manager, NQA, on the status and adequacy of the Nuclear Quality Assurance Program and advising of any problems requiring special attention; [8]
j i
l Enclosure i
Page 11 of 12 i
Excerpts from Descriptions of Limerick Quality Division, NQA 1
DOCUMENT /
FUNCTION DESCRIPTION REFERENCE LGS UFSAR The Limerick Quality Division is under the supervision of 17.2.1.2.3.1 a Manager who reports to the General Manager, Nuclear
. The Manager, who meets the j
page 17.2-7 Quality Assurance.
4yuirements of ANSI /ANS-3.1-1978, is responsible fort e.
Conducting audits, surveillancos, inspections and monitorings. [3), [5] and [6]
f.
Identifying specific and programmatic deficiencies, and tracking these items until they are fully resolved, in accordance with Administrative i
Procedures. [2), [6] and [9]
g.
Performing trend analysis. (4) h.
Providing periodic reports to the General Manger, NQA, on the status and adequacy of the nuclear facility Quality Assurance Program and advising of any problems requiring special attention. [8]
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Enclosure Page 12 of 12 A
Excerpts from Descriptions of Independent Safety Engineering Groups (ISEG), NQA DOCUMENT /
FUNCTION DESCRIPTION REFERENCE PBAPS UFSAR The ISEG is responsible for performing independent 13.8.6, pages reviews of plant operations, reviewing operating 13.8-9 and experiences which may indicate the need for improvements, 13.8-10 and recommending needed improvements, and advising management on the overall quality and safety of operations. [1], [3]
LGS UFSAR, 13.4.5, pages 13.4-8 and 13.4-9 Limerick The ISEG shall make detailed recommendations for revised Technical procedures, equipment modifications, maintenance Specification, activities, operations activities, or other means of 6.2.3.1, and improving unit safety. [1]
6.2.3.3, page 6-6, and such recommendations shall be submitted through the General Manager-Nuclear Quality Assurance to the PBAPS Executive Vice President-Nuclear." [8]
Technical Specification, The ISEG shall be responsible for maintaining 6.2.3.1, and surveillance of unit activities to provide independent 6.2.3.3, page verification that these activities are performed 245b correctly... [5]
__________-___J