ML20238E197
| ML20238E197 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/23/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Johnston W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8801050041 | |
| Download: ML20238E197 (8) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA A. PA,19101 (215)0414o00 December 23, 1987 Docket No. 277 278 1
Mr. William V. Johnston, Acting Director Division of Reactor Safety Region 1 ATTN: Document Control Desk Washington, D. C.
20555 U.S. Nuclear Regulatory Commission
SUBJECT:
QA Program Description Changes.for Peach Bottom Atomic Station l
Unita 2, 3 l
Dear Mr. Johnston:
This is in response to your letter dated December 3, 1987 concerning QA Program Description Changes for Peach Bottom Atomic Power Stat!on, Units 2 and 3, Updated Final Safety Analysis Report (UFSAR) Revision 5, s nitted by Philadelphia Electric Co. on October 2, 1987. This response. incorporates information exchanged between L. J. Prividy of your. staff and 'D. L. Mcdonald of our QA Staff on November 30, 1987, and D. W. Rossman of our QA Staff on December 11, 1987 The attached Requests for Revision have been initiated and approved by Nuclear Quality Assurance to address concerns stated in Attachment 1 of your.
letter of December 3, 1987. The items of concern are restated below followed by our action for resolution.
Item 1:
In Section 17.2.1.4.1.1.a " specific" should be changed to "special" for correctness:
Resolution:
Paragraph 17.2.1.4.1.1.a - The word " specific" will be changed to "special." This was a typographical error Item 2:
The detal. led irnplementing requirements for the PECo Nuclear Fuel-QA Program previously in Rev. 4, Section 17.2.1.3.1.1.a through f. were deleted from the Rev. 5 submittal.:without justification.
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. _ Resolution:
The last sentence of Paragraph 17.2.1.2.2.6 will be revised so that it will read "as detailed in the PECo Nuclear Fuel Quality Assurance Plan." The Nuclear Fuel QA Plan details responsibilities for the Nuclear Fuel QA Program.
Item 3:
It is not clear what PECo group will assume detailed responsibility for the implementation of the PECo Nuclear Fuel Quality Assu-noe Program. This responsibility was previously included in the scope or the Nuclear and Environmental Section in the Engineering and Research (E&R) organization.
However, the licensee's reorganization prompted a change in Section 17.2.1.2.2.6 that the Fuel Management Section in Nuclear Operations (NO) will implement the PECo Nuclear Fuel Quality Assurance Program. Also, l
Section 17.2.1.4.1.1 indicates that the Fuel Management Section in Nuclear and Environmental Section in the E&R organization has interface responsibilities between the NO and E&R organizations for activities related to special nuclear material. Thus, it appears to be clear that the PECo Nuclear Fuel Quality Arsurance Pro 6 ram implementation is now the responsibility of the Fuel Management Section in the N0 organization.
l However, PECo indicated in it submittal of October 2, 1987, that this responsibility was still in the Nuclear and Environmental Section of the E&R organization.
Resolution:
The Resolution for Item 2 will clearly establish the responsibility for Nuclear Fuel Quality Assurance to be the Fuel Management Section in Nuclear Operations.
It was not intended to indicate otherwise in the October 2, 1987 submittal.
Item 4:
Section 17.2.1.3.1.3 and 17.2.1.3.1.3.3 delineate the role of the Technical Services Group in the Mobile Maintenance Section. But this group is not shown on the Maintenance Department organization chart (Exhibit VI).
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Resolution:
Paragraph 17.2.1.3.1.3 will be revised to agree with Exhibit VI by deleting Paragraph 17.2.1.3.1.3.3 The Technical Services Group is a subset of each of the following groups; Mobile Electric, Mobile Mechanical, and Inservice Inspection.
It is comprised of Maintenance engineers who provide technical support to these groups, i
i Item 5:
Section 17.2.1.4.3 delineates that the Senior Engineer - QC reports to the two Assistant General Superintendents. This is inconsistent with the organization chart for the construction Division (Exhibit XI) which shows QC reporting to the General Superintendent.
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t Nesolution: Paragraph 17.2.1.4.3 will be revised to show that Construction QC reports directly to the General Superintendent as shown in Exhibit XI ltem 6:
Section 17.2.4.3 - the addition of " preliminary" to this section requires clarification. Modification of this section to state that final requisitions are prepared by the Stores Division and based on preliminary requests from the ordering group appears to be inappropriate.
Resolution:
Paragraph 17.2.4.3 will be revised to read "... based on requests furnished by the ordering group." All requests, preliminary and interim, are used in-preparing the final l
requisition.
Item 7:
Section D.12.2.7.d - Minor maintenance work audits prevloitsly'11sted as a responsibility of the Plant Operations Review Committee were deleted without justification.
Resolution:
In Paragraph D.12.2.7.d, "..
and makes audits of the work." was deleted because Paragraph 17.2.1.2.5 of Section D.11 states in part, "The NRB is also responsible for the conduct of periodic audits of. plant operations.
" Minor maintenance falls under the purview of plant operation.
l PECo will include all the above listed Requests for Revision in the next annual revision of the PBAPS UFSAR.
If you have any questions, please do not hesitate to contact us.
I Very truly yours, cc:
Addressee W. T. Russell, Administrator, Region I, USNRC T. P. Johnson, USNRC Resident Site Inspector
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1 ELECTRIC PRDDUCTlDN REQUEST NO.
32 REQUEST FOR REVISION OF PEACH BOTTOM pg3 OR LIMERICK FSAR(S).SECTION 17.2. AND
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QUALITY ASSURANCE PLAN (S). VOLUME III
.OlVISION PART I:
REVISION T0:
I i QA PLAN.VOL.III. OPERATIONS PHASE LI.J FSAR.SECTION 17.2. OPERATIONAL OA LLJ PBAPS n LGS DESCRIPTION OF REVISION REQUESTED:
Paragraph 17.2.1.2.2.6 last sentence. Add to the'end of the last sentence " as detailed in the PECo Nuclear Fuel Quality Assurance P:an".
REASON FOR REVISION:
To clearly show responsibility and where responsibilities are defined
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EttCTRIC PRODUCTION REQUEST NO.
33 REQUEST FOR REVISION OF PEACH BOTTOM
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T-OR LIMERICK FSAR(S).SECTION 17.2. AND QUALITY ASSURANCE PLAN (S). VOLUME III nuaun ASSURANCE e m slDN PART I:
REVISION TO:
I I OA PLAN.VOL.III. OPERATIONS PHASE ED FSAR.SECTION 17.2. OPERATIONAL 0A L2J PBAPS I
ILGS DESCRIPTION OF RE'/ISION REQUESTED:
Paragraph 17.2.1.4.1.1.a Change the word specific to special I
REASON FOR REVISION:
Typographical error
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ELECTRIC PRDDUCTION REQUEST NO.
34 REQUEST FOR REVISION OF PEACH BOTTOM
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OUALITY ASSURANCE PLAN (S). VOLUME III nusun ssuRact DIVISIDN PART I:
REVISION TO:
1 1.0A PLAN.VOL.III. OPERATIONS PHASE L2J FSAR.SECTION 17.2. OPERATIONAL QA PBAPS R LGS DESCRIPTION OF REVISION RE00ESTED:
Paragraph 17.2.4.3 change paragraph to read "... based on requests furnished by the ordering group."
REASON FOR REVISION:
Theword" preliminary"wasinadverteklyadded.Allrequests, preliminary and interim are used in preparing the final requisition.
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PREPARED BY NAME DATE N,AME DATE PART 2:
RESOLUTION OF REQUEST I
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CADF 4-I REY. 4.1244.
4 ELECTRIC PRODUCTION REQUEST NO.
3C REQUEST FOR REVISION OF PEACH BOTTOM
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OUALITY ASSURANCE PLAN (S) VOLUME III AUALITY ASSURANCE DIVISlDN PART I:
REVISION T0:
I I QA PLAN.VOL.III. OPERATIONS PHASE LLJ FSAR.SECTION 17.2. OPERATIONAL QA LLJ PBAPS LGS DESCRIPTION OF REVISION REQUESTED:
Paragraph 17.2.1.4.3 Revise paragraph to show that QC reports directly to the General Superintendent REASON FOR REVISION:
To show the correct organizational reporting as shown in Exhibit XII
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APPROVED BY-PREPARED BY NAME DATE NAME DATE PART 2:
RESOLUTION OF REQUEST I
IAPPROVED REQUEST FOR IMMEDIATE IMPLEMENTATION OF REVISION APPROVED REQUEST FOR IMPLEMENTATION AT NEXT SCHEDULED REVISION OF DOCUMENT I
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ELECTRIC PRODUCTION REQUEST No. 3 7 REQUEST FOR REVISION OF PEACH BOTTOM
'MV OR LIMERICK FSARCS).SECTION 17.2. AND QUALITY ASSURANCE PLAN (S) VOLUME III QUALITY ASSURANCE DIVISION PART !:
REVISION T0:
1 i OA PLAN.VOL.III. OPERATIONS PHASE FX 1 FSAR.SECTION 17.2. OPERATIONAL QA T PBAPS I
ILGS DESCRIPTION OF REVISION REQUESTED:
Revise paragraph 17.2.1.3.1.3 to agree with Exhibit VI Delete paragraph 17.2.1.3.1.3.3 REASON FOR REVISION:
Revision required as the Technical Services Group doesn't actually exist. There are engineers who give technical support to the Mobile Electric. Mobile Mechanical.and Inservice Inspection groups as required.
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