ML20148Q661
| ML20148Q661 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/26/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20148Q647 | List: |
| References | |
| NUDOCS 9707070180 | |
| Download: ML20148Q661 (4) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION OUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE PHILADELPHIA ELECTRIC COMPANY LIMERICK GENERATING STATION. UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
1.0 INTRODUCTION
By letter dated February 24, 1997. PEC0 Nuclear Unit of the Philadelphia Electric Company (the licensee) transmitted a proposed revision to Revision 6 of the Limerick Generating Station (LGS) Quality Assurance Program Description in accordance with 50.54(a). The staff has reviewed the submittal in accordance with 50.54(a) and determined that the change to the quality assurance program is acceptable in that the quality assurance program continues to meet the requirements of Appendix B to 10 CFR Part 50 and meets the additional requirements of 50.34(B)(6)(ii) by discussing how the applicable requirements of Appendix B will be satisfied.
This safety evaluation describes the staff's analysis of the proposed alternative to previously approved provisions for the lead auditor qualifications, and annual supplier evaluation.
2.0 EVALUATION 2.1 Lead Auditor Qualification Process The licensee's Quality Assurance program description is contained in Appendix 17.2.II. item q of the LGS Updated Final Safety Analysis Report.
The licensee is presently committed in its quality assurance program to Section 2.3.4.
" Audit Participation." of ANSI N45.2.23-1978, " Qualification of OA Program Audit Personnel for Nuclear Power Plants." as endorsed by Regulatory Guide 1.146. " Qualification of Quality Assurance Audit Personnel for Nuclear Power Plants," dated August 1980.
Section 2.3.4 states the following:
"The prospective Lead Auditor shall have partici)ated in a minimum of five (5) quality assurance audits wit 11n a period of time not to exceed three (3) years 3rior to the date of qualification, one audit of which s1all be a nuclear quality assurance audit within the year prior to the individual's quali fication. "
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!* As described in the February 24, 1997, submittal, the licensee has proposed I
the following alternative to the provisions contained in Section 2.3.4 of ANSI i
N45.2.23-1978:
" Prospective Lead Auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. This process is described in written procedures which provide for evaluation and documentation of the results of this demonstration. A prospective Lead Auditor shall have participated in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification.
Upon successful demonstration of the ability to effectively implement the audit process and effectively lead l
audits, and having met the other provisions of Section 2.3 of ANSI /ASME l
N45.2.23-1978, the individual may be certified as being qualified to l
lead audits."
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The staff conducted its review in accordance with the guidance in Section l
17.2. " Quality Assurance During the 0)erational Phase." of NUREG-0800.
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" Standard Review Plan" (SRP 17.2). T1e introduction paragra)h of Section II,
" Acceptance Criteria," of SRP 17.2 contains provisions for t1e use of alternatives to the acceptance criteria contained in SRP 17.2 provided they are evaluated by the staff and are considered to be in compliance with pertinent NRC regulations.
Based on the staff's review it was determined that the alternative for lead auditor qualification aroposed by the licensee represents an acceptable alternative to Item 1833 of SRP 17.1 which is referenced in the criteria for i
audits in SRP 17.2.
This determination was based on the licensee's cuality assurance program controls which require that 1) prospective lead aucitors effectively demonstrate their ability to implement the audit process and lead l
an audit team. 2) this demonstration process be described in written procedures or instructions 3) the results of the demonstration be evaluated and documented, and 4) regardless of the methods used for the demonstration, the prospective lead auditor shall have participated in at least one nuclear i
cuality assurance audit within the year preceding the individual's effective l
cate of qualification. The alternative also contains provisions that upon successful demonstration of the ability to effectively implement the audit l
process and effectively lead cudits, and having met the other provisions of i
Section 2.3 of ANSI N45.2.23-1978, the individual may be certified as being i
qualified to lead audits.
2.2 Annual Supplier Evaluation ANSI N45.2.12-1977. " Requirements for Auditing of Quality Assurance Programs L
for Nuclear Power Plants " as endorsed by NRC Regulatory Guide (RG) 1.144.
" Auditing of Quality Assurance Programs for Nuclear Power Plants," Revision 1.
dated September 1980, describes a method acceptable to the NRC staff for complying with regulations concerning auditing of quality assurance programs for nuclear power plants.
Section 3.5.2 of ANSI N45.2.12-1977 requires that l
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audits of quality assurance activities be regularly scheduled to ensure that the quality assurance program is adequate and that activities are being 3erformed in accordance with the quality assurance program.
Regulatory i
)osition C.3 of RG 1.144 discusses what the NRC staff considers acceptable audit scheduling.
Regulatory Position C.3.b(2) specifically addresses the auditing of a supplier's quality assurance program and permits an audit frequency of 3 years provided that the licensee performs an annual evaluation
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l of the supplier's performance as follows:
"A documented evaluation of the su) plier should be l
performed annually.
Where applica)le this evaluation should take into account (1) review of supplier-furnished documents such as certificates of conformances.
i nonconformance notices, and corrective actions. (2) l results of previous source verifications, audits, and receiving inspections. (3) operating experience of identical or similar products furnished by the same i
supplier, and (4) results of audits from other sources (e.g., customer. ASME or NRC audits)."
The NRC considers the alternative proposed by the licensee to be an acceptable alternative to Regulatory Position C.3.b(2) of RG 1.144 based on the following discussion:
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The alternative to the preceding position provides for a continuous or ongoing
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evaluation of the sup)11er's performance be conducted rather than a delayed annual evaluation. T1e staff considers the alternative acceptable as long as the results of the ongoing evaluation are documented and the evaluation l
findings are reviewed in order to determine if any corrective action is requi red.
The alternative proposed by the licensee contains provisions for a documented ongoing evaluation of the supplier to be performed. Where applicable, this evaluation takes into account (1) review of supplier-furnished documents such as certificates of conformances. nonconformance notices, and corrective l
actions. (2) results of previous source verifications, audits, and receiving l
inspections. (3) operating experience of identical or similar products I
furnished by the same supplier and (4) results of audits from other sources (e.g., customer. ASME or NRC audits). The results of the evaluations are l
reviewed and appropriate corrective action taken. Adverse findings resulting from these evaluations are periodically reviewed in order to determine if, as a whole, they result in a significant condition adverse to cuality and to provide input to support supplier audit activities conductec by the licensee or a third party auditing entity.
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3.0 CONCLUSION
The staff has determined that the proposed alternatives identified in Revision 6 of the Limerick Generating Station s Quality Assurance Program Description, related to lead auditor qualifications and annual supplier evaluation represent an acceptable alternative to the review criteria contained in i
Section 17.2 of NUREG-0800 and these changes are acceptable and continue to meet the pertinent requirements of Appendix B to 10 CFR Part 50.
Principal Contributor:
L. Campbell Date: June 26, 1997 f
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