ML20155F509
| ML20155F509 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 10/07/1988 |
| From: | Martin R Office of Nuclear Reactor Regulation |
| To: | Alden W PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8810130281 | |
| Download: ML20155F509 (7) | |
Text
_ ___________ _ _
October 7, 1988 Docket Hos. 50-277/278 l
7 Mr. William Alden Director, licensing Philadelphia Electric Company f
2301 Market Street l
Philadelphia, Pennsylvania 19101 Dear Mr. Alden l
SUBJECT:
REQUEST FOR INFORMATION ON QUALITY ASSURANCE PROGRAM i
The staff has reviewed the changes to the Quality Assurance Program l
description that were described in Revision 6 to the Updated Final Safety Analysis Report and in the letter of Mr. E. P. Fogarty, PEco, to Mr. W.
Russell, NPC, dated August 8,1988 and has identified a need for additional infonnation as stated in the Enclosure.
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We suggest that it would be beneficial to discuss these issues in a meeting to I
l be followed by a written response.
l Sincerely, l
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/SI q
l Robert E. Martin, Project Manager i
Project Directorate 1-2 i
i Division of Reactor Projects I/II i
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October 7, 1988 Docket Nos. 50-277/2id Mr. William Alden Director, Licensing Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Dear Mr. Alden
SUBJECT:
REQUEST FOR INFORMATION ON QUALITY ASSURANCE PP0 GRAM The staff has reviewed the chances to the Quality Assurance Program description that were described in Revision 6 to the Updated Final Safety Analysis Report and in the letter of Mr. E. P. Focarty, PECo, to Mr. W.
Pussell, NRC, dated August 8,1988 and has identified a need for additional information as stated in the Enclosure, k'e sugaest that it would be beneficial to discuss these issues in a meeting to be followed by a written response.
Sincerely, L t O '?a k i
/ ober E. Martin, Project Manager Project Directorate 1-2 Division of Reactor Projects !/II
Enclosure:
As stated
~
Mr. William M. Alden Peach Bot +cm Atomic Power Station.
Philadelphia Electric Company Units 2 and 3 Cc' Troy B. Conner, Jr., Esq.
Mr. R. A. Heiss, Coordinator 1747 Pennsylvania Avenue, N.W.
Pennsylvania State Clearinghouse Washington. 0.C.
20006 Governor's Office of State Planning and Development Philadelphia Electric Company P. O. Box 1323 ATTN: Mr. D. M. Smith, Vice President Harrisburg, Pennsylvania 17120 Peach Bottom Atomic Power Statien Route 1. Box 208 Mr. Thomas M. Gerusky, Director Delta Pennsylvania 17314 Bureau of Radiation Protection Pennsylvania Department of H. Chris Schwem Environmental Resources Vice President, Production P. O. Box 2063 Atlantic Electric Harrisburg, Pennsylvania 17120 P.O. Box 1500 1199 Olack Horse Pike Mr. Albert R. Steel, Chairman Pleasantville, New Jersey 08232 Board of Supervisors Peach Bottom Township Resident Inspector R. D. #1 U.S. Nuclear Regulatory Comission Delta, Pennsylvania 17314 Peach Botten Atomic Power Statier P.O. Box 399 Mr. Gary Mock Delta, Pennsylvania 17314 P. O. Box 09181 Colorbus, Ohio 43209 Regional Administrator, Region !
U.S. Nuclear Regulatory Comission Delmarva Power and Light Company 475 Allendale Road c/o Jack Urban Kiro of Prussia, Pennsylvania 19406 General Maneger, Fuel Supply 800 King Street Mr. Bryan W. Gorran P.O. Box 231 Managsr - External Affairs Wilmington, DI 19899 Public Service Electric & Gas Cmpany P.O. Box 236, N?8 Fr. Tom Magette Hancocks Bridge, New Jersey 08038 Pcwer Plant Research Program Cepartment of Natural Resources B-3 Tawes State Office Building Annapolis, Maryland 21401 Mr. Roland Fletcher Department of Environment 201 West Preston Street Baltimore, Maryland 21201
4 REQUEST FOR ADDITIONAL INFORMATION PEACH BOTTOM UPDATED FSAR REVISION 6 QUALITY ASSURANCE i
i Q-0 Justify the deletion of Figure D.10.1, and clarify NQA's involvement in the PECO fuel quality assurance and nuclear material accountability
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program.
Q-1 Section 17.2.1.2 states that the Nuclear Group is supplied maintenance I
support from other PECO organizations and contractors as necessary.
Conversely. Section 13.2.1.1.2 indicates there is a maintenance organi-i zation at PBAPS, and Section 17.2.1.2.3.1 indicates that there is a l
Nuclear Maintenance Division within the Nuclear Services organization of the Nuclear Group. Clarify the responsibilities for PBAPS mainten.
l ante and maintenance QA/QC for PBAPS.
1 Q-2 Section 17.2.1.2.2 refers to Section 13.2.3 for the PBAPS organization, and Figure 13.2.1 shows the Managers PBAPS Quality and the PBAPS ISEG j
located offsite. Discuss the pros and cons of offsite versus onsite location for these personnel.
(NotethatSection 17.2.1.2.4.2 shows the PBAPS ISEG onsite.)
i Q-3 Revision 6, in Section 17.2.1.2.4 has deleted the responsibility of the GeneralManager,NQA(Ex-Superintendent)to:
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Review and approve Administrative Procedures which implement the OQA i
(nowNQA) Plan I
5.
Approve all Nuclear Operations QA Division Procedures for the implementation of the OQA Plan 1
i Justify these deletions.
I Q-4 Clarify the auditing / surveillance responsibilities of the Quality i
Support Division (17.2.1.2.4.4) versus the auditing / surveillance responsibilities of the Peach Bottom Quality Division (17.2.1.2.4.1).
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Q-5 Clarify what MRF stands for in Section 17.2.1.2.4.1.3.
(Identifiedin Section 17.2.15.1 as"maintenancerequestform")
Q-6 Section 17.2.1.2.4.3 describes the duties of the Performance Assessment l
Division of NQA. Clarify whether there is an annual assessment of NQA j
which is performed by an entity independent of the NQA organization.
Q-7 Section 17.2.1.2.6 discusses the PORC. Does NQA audit the PORC7 If so, what organization within NQA is responsible for these audits 7
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not NQA, what organization audits the PORC7 l
1 Q.8 With the PECO reorganization, it is difficult to compare Rev. 6 of the f
l USAR with Rev. 5 and it is important that the margin lines showing l
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where changes occur be accurate.
It a t
should have a margin line (ppears, for example, that Section l
it doesn't) and that Section 17.2.1.2.1 l
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17.2.1.2.2 should not have a margin line (it does). Margin lines should indicate deletions as well as changes and additions.
Please verify the correctness of the margin lines in Appendix D.11 of the USAR and make any appropriate changes. Also, please prepare a table of the responsibility assignments in Revision 5 and show to whom (by position title or by organization) each responsibility is assigned in Rev. 6.
Q-9 Iter.i 14 on page D.11-9 of Rev. 6 introduces an "Evaluated Suppliers what would cause the removal of a supplier, etc. Discuss the list; that is, how d List."
Note reiteration of commitmentinSection17.2.4.5.)
Q-10 Section 17.2.1.2.4.4.2 indicates the Superintendent of the Engineering Support Section of the Quality Support Division provides "support for the software quality assurance program." Clarify what this support consists of and how it is provided.
Q-11 The section 17.2.1.3.1.1 list of organizations which make up the Fossil / Hydro Generation Division does not include Maintenance, but the list of organizations within this Division does include Maintenance.
Clarify.
Q-12 Clarify the last sentence on page 0.11-23 of Rev. 6 which states:
"Philadelphia Electric Company executive management mandates that with operations, maintenance, repairing, fueling, or modification activities shall be prepared, executed and verified to assure operational safety."
Q-13 Section 17.2.2.3 refers to "the latest revision of the PBAPS Project Sumary Q-List." Clarify whether this list is given in Table D.2.1 of the SAR.
Q-14 Section 17.2.2.5 no longer points out the "independence" of NQA personnel. Justify this deletion or replace the coccitment.
Q-15 Section 17.2.2.9.1 limits the Quality Support Manager's review and approval of Administrative Procedures that implement the NQA plan to those that are "site generated." Who (by position title) performs this function for such procedures that are not site generated?
Q-16 Sections 17.2.2.10 and 17.2.2.11 address the responsibilities of the Manager, Performance Assessment Division and the Manager, Independent Safety Engineering Division, respectively.
It appears that these responsibilities have also been addressed in Section 17.2.1.2.4.3 and 17.2.1.2.4.2, respectively. Cla rify. Also clarify whether the Inde-pendent Safety E6gineering Division tracks to completion the recem.
mendations and advice from the ISEGs.
Q-17 What is the significance of changing Section 17.2.3.3.2 reference from "off-the-shelf" comercially standard items to comercially standard "catalog items?"
Q 18 The addition of "safety related" to Sections 17.2.4.6 and 17.2.4.7 of the SAR could imply that (1) Nuclear Engineering procurement documents for nonsafety-related modification shall not be controlled and that (2) unapproved requisitions may be processed by Purchasing for nonsafety-related items. Clarify.
0-19 Sections 17.2.2.1 and 17.2.2.1.1 and elsewhere refer to the Nuclear Quahty Assurance (or NQA) Plan. Sections 17.2.2.3 and 17.2.2.4.1 refer to the "QA Plan." Section 17.2.2.1 refers to the "nuclear Quality Assurance Program, and 17.2.2.2 refers to the "QA Program."
Section 17.2.4.9 refers to "this Plan." Sections 17.2.6.2 and 17.2.6.3 refer to the PBAPS QA Plan. Clarify these terms throughout Rev. 6 of the SAR for consistency and clarity. (Revise 17.2.6.3.1 accordingly.)
Q-20 Sections 17.2.5.1 and 17.2.5.1.1 appear to differentiate between administrative procedures (lower case) and PBAPS Administrative Procedures (capitalized). Section 17.2.5.1.2 refers to "These Administrative Procedures" (capitalized, but without PBAPS). Clarify these terms as for Q-19.
Q-21 Discuss the significance of adding "tech spec delineated site" to describe implementing procedures and procedure changes in Section 17.2.5.2.1.
Are these procedures different from the procedures discussed in Section 17.2.5.17 Q 22 Section 17.2.5.3 no longer addresses the distribution of Maintenance Administrative Procedures. Justify or clarify.
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Q-23 Rev 6. has deleted the last subsection of Sections 17.2.5 through 17.2.16 and 17.2.18 which referred to Engineering and Research in Rev.
i 5.
Should there not be comparable sections for Engineering and Production?
Q-24 Section 17.2.9.1.2 appears to have divided responsibility for control of welding, heat treating, and nondestructive testing initiated by the Nuclear Group and Engineering and Production. Clarify (1) what organi-zation is responsible for cor. trolling these activities and (2) what organization is responsible for controlling these activities when not j
initiated by the Nuclear Group or Engineer'ng and Production.
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l Q-25 Clarify whether there is any conflict or contradiction between 17.2.10.2 and 17.2.10.4 or 17.2.10.4.1 l
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Q-26 Justify the deletion of the last sentence from Section 17.2.11.8 of J
Rev. 5.
l Q-27 Section 17.2.15.1 continues to use the term "QA Hold Tag", but Section l
17.2.15.2 has changed " 'QA HOLD' tag" to " ' HOLD' tag." Clarify for j
consistency.
)
Q-28 Section 17.2.5.5 refers to "Nuclear Engineering PORC."
It appears i
there should be a come before PORC.
Q-29 Clarify which Vice Presidents are referred to in Section 17.2.16.4.
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Q 30 Section 17.2.18.1 (and elsewhere) refers to surveillances and monitorings. Describe the difference (s) between the activities. This section also refers to corrective action as required by audit findings.
Clarify that corrective action may also be required by findings of surveillances and monitorings, Q-31 Discuss how (as required by Section 17.2.18.5) the General Manager, NQA, can assure timely corrective actions by responsible management or modify the requirement.
Q-32 With regard to Paragraph 17.4 of N45.2.2 (page 0.11-64) of Appendix 17.2A, briefly describe how the PECO approach differs from the guidance.
Q-33 The text of the Appendix D.11 of the updated FSAR has generally been revised to eliminate differences in the treatment of major and minor modifications. However, the clarification of PECO's comitment to Reg. Guide 1.64 still addresses the categorization of modifications into major and minor.
It appears that the clarification may not be required since the word "COMPLY" appears imediately below it.
Clarify PEC0's cemitment to Reg. Guide 1.64 for the PBAPS.
Q-34 Reinstate the comitment to comply with Reg. Guide 1,74 or justify not doing so.
Q-35 In updating PECO's comitment to ANSI N45.2.12 from the 1974 to the 1977 revision (Item 19, page D.11-69), the new comitment should address Reg. Guide 1.144, Rev. 1, which endorses the 1977 version.
Q-36 Differences in the Rev. 5 and Rev. 6 matrices of procedures versus 10 CFR 50 Appendix B criteria are not highlighted with lines in the margin.
Verify the correctness of the Rev. 6 matrix and add lines in the margin where appropriate.
Q-37 The Table of Contents indicates that Section D.12. "Philadelphia Electric Company Maintenance and Modification Quality Assurance Plan,"
has been incorporated into the Nuclear Quality Assurance Plan, Modifi-cation Activity Section. Justify deleting this section from the FSAR.