ML20080A958

Proposed Tech Specs Re Change to QA Program Description by Eliminating Independent Safety Engineering Group Composition Requirement

ML20080A958
Person / Time
Site:	Peach Bottom
Issue date:	11/14/1994
From:	NEBRASKA PUBLIC POWER DISTRICT
To:
Shared Package
ML20080A951	List: ML20080A947 ML20080A958
References
NUDOCS 9411230164
Download: ML20080A958 (10)

Text

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ATTACHMENT 1 Proposed Change to the Quality Assurance Program Description for Peach Bottom Atomic Power Station Units 2 and 3 f l

4 9411230164 941114 PDR ADOCK 05000277 P PDR

PBAPS l 17.2.1.2.2 Station Sucoort ~

The organization, duties, and responsibilities of l Station Support are described in Section 13.

17.2.1.2.3 Nuclear Ouality Assurance - (Exhibit IV)

Nuclear Quality Assurance (NQA) is responsible for administering the overall Nuclear Quality Assurance Program of the Nuclear Generation Group.

l Nuclear Quality Assurance is headed by a Director, who reports directly to the Senior Vice President l and Chief Nuclear Officer. NQA is composed of the Peach Bottom Quality, Limerick Quality, and +he Corporate Nuclear Quality Divisions # nd the Peach --EL, htte and I.i q Lc L cre""r _ F#Re.v;w(eP3!j;gpendentJg;f;';y "nti_Jeri=0 Nde. : A s % )l a sut-;+441  ;. W '

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responsibilities and authorities.

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1. Formulate, develop, and establish Nuclear Quality Assurance policy in areas such as, Operations, Maintenance, Modifications, In- l Service Inspection / Testing, Surveillance -w 1 Testing, Fuel Handling, Health Physics, __, !

Chemistry, Radiological and Environmental ~'

Monitoring, Fire Protection, Physical Security, Emergency Preparedness, Radioactive i' Waste and Material, Training, Procurement, l Assessments, Records, Nonconformances, and Corrective Action.

2. Administer and coordinate the Nuclear Quality Assurance Program (NQA Program).

3. Furnish overall direction for implementing the NQA Program.

4. Provide recommendations for correcting program deficiencies or improving the implementation of the NQA Program, as appropriate.

5. Require tracking and verification of corrective action and problem resolution for all QA-identified Corrective Action Requests l (level 2 & 3 CAR issues). Require that deviations be tracked in accordance with Administrative Procedures. _..

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6. Direct cessation of work when such work is -

l considered by the Director, NQA, to be a D.11-2 Rev. 12 7/94

PBAPS

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" ^ ^ ' W serious quality degradation. This stop work (1, authority shall be delineated in applicable procedures.

7. Determine the on-going status and adequacy of the QA Program through regular review of QA Assessments, Surveillances and Verifications, identification and investigation of problem areas, determination of timely and effective steps taken to correct deficiencies, and the evaluation of general plant QA/QV performance through such other inputs as are available or are deemed necessary to make a reasonably objective and confident judgement.

8. Apprise the Senior Vice President and Chief Nuclear Officer; the Vice President, Station Support, the Vice President, Peach Bottom Atomic Power Station; and the Nuclear Review Board periodically of the status of the Quality Assurance aspects of Peach Bottom Atomic Power Station operations, and immediately of significant problems affecting quality.

9. Ensure that personnel involved in implementing l

,. the QA procedures are trained and/or J-~~ qualified, as appropriate.

10. Contract for QA/QV consulting services as l necessary.

11. Provide support for QA/QV training and l qualification programs, as required, for implementation and execution of the QA Program. l l

12. Establish and maintain the Evaluated Vendors l  ;

List (EVL) of quality and evaluated suppliers in accordance with administrative procedures.

13. Perform assessments /surveillances of vendor l l activities as appropriate.

14. Establish, administer, and coordinate the l Nuclear Quality Assurance Program associated with modifications, and capital equipment l installation or renewal. '

15. Assess and verify the adequacy and l effectiveness of activities covered by the QA program.

L,e 17.2.1.2.3.1 Peach Bottom Ouality Division D.11-3 Rev. 12 7/94

PBAPS The Peach Bottom Quality Division is under the supervision of a Manager, who reports to the l

l Director, Nuclear Quality Assurance. The Division  ;

is. composed of three sections: Assessment, Quality Verification, and Quality Support. The Manager is responsible for:

1. Providing technical and administrative direction to the Division-1

2. Providing single point accountability for all site quality activities,

3. Reviewing and approving site generated Administrative Procedures, and Lnds end ul~ ~ h hnim I R **I' #

l 4. Formulating the Site Assessment Programp

5. Conducting on-site assessments, surveillances and verifications.

6. Identifying specific and programmatic deficiencies and tracking these items until they are fully resolved, in accordance with Administrative Procedures.

7. Performing trend analysis; d-l 8. Providing periodic reports to the Director, NQA, on'the status and adequacy of the Nuclear Quality Assurance Program and advising of any problems requiring special attention; ,

9. Approving Stop Work Directives.

10. Providing and maintaining a qualified and suitably trained quality assurance staff to carry out required project and staff functions.

l 17.2.1.2.3.1.1 Assessment Section The Assessment Section is under the supervision of the site Quality Division Manger. The Manager has the following responsibilities:

1. Provide administrative supervision of the activities of the section.

2. Direct the scheduling, planning, and performance of assessments and surveillances, in accordance with written procedures to l assure compliance with the QA Program and Technical Specifications.

D.11-4 Rev. 12 7/94

PBAPS 4

9. Maintenance of NQA personnel qualification j

[. records.

1772.1.2.3 ? Peach Bottom Indenerdert CafetV Engineerind'Droup each Bottom ind afety Engineering Group (ISEG) composition and respono e e described in Section 13.0.6 17.2.1.2.3.3 Coroorate Nuclear Ouality Division The Corporate Nuclear Quality Division is under the supervision of a Manager who reports to the Director, Nuclear Quality Assurance. The Division consists of two sections: Assessment and Administration.

The Manager, Corporate Nuclear Quality, is responsible for all Corporate Nuclear Quality Division activities. This includes:

1. Manuals and procedures,

2. Vendor assessments and surveillances

3. Training, f.

""~ 4. Oversight of the quality activities of Nuclear Support

5. Identification of specific and programmatic l deficiencies and tracking of these items until they are fully resolved,

6. Performing trend analysis, l

7. Conducting internal assessments and l surveillances at the corporate offices,

8. Single point of accountability for all l Corporate Nuclear Quality (CNQ).

17.2.1.2.3.3.1 Assessment Section The Assessment Section is under the supervision of the Manager, Corporate Nuclear Quality Division.

The Manager's responsibilities include:

1. Providing administrative supervision and I I

technical direction of the activities of the section.

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D.11-7 Rev. 12 7/94

. PBAPS

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17.2.2.9 The PBAPS QA program is documented by written policies, procedures and instructions and shall be carried out throughout the life of the plant.

17.2.2.9.1 The Corporate Nuclear Quality Division Manager reviews and approves all non-site generated Administrative Procedures that implement the QA Program.

17.2.2.9.2 The administrative and implementing procedures and instructions pertaining to quality-related activities are written to accomplish those activities with appropriate equipment under suitable environmental conditions.

Q Q ;4y Division 40 e.nsee. A ZndepmJek Tec/mical RsJew %m l 17.2.2.10 The3 Manager J ".dep~

is responsible fer[hdent Safcty Engineerir e r^ups reviewing plant operating characteristics, NRC issuances, and other appropriate resources of plant design and operating experience information that may indicate areas for improving plant safety, and for inputting and closure of GMHMF recommendations in the Plant Information Management System (PIMS)pt re.3 Srom , +hsse.

rolews . Tke, rdcpsndeaf Techical Rwew % am .s' 17.2.2.11 byeYat*In$[ peYsbn"ne[*s lection and training complies with PBAPS Technical Specifications and is in accordance with ANSI N18.1 - 1971. '

a 17.2.2.11.1 The training program assures competent material selection and instruction. The retraining program is designed to maintain current operator competence and uses current NRC recertification, proposals as a guide. Training aids and materials i are utilized. Formal classroom and individual I study periods are scheduled. Evaluation of I trainee's progress is documented. I 17.2.2.11.2 The training program also includes provisions for non-licensed personnel and general employee i indoctrination. General Employee Training includes: quality-related plans and procedures appropriate to the specific job related activities; radiological health and safety (ALARA Program), industrial safety; plant controlled access areas and security; and the use of l protective clothing and respiratory equipment.  !

Personnel performing quality-related activities are trained and qualified in the principles and techniques of the activities being performed. l These areas include technical training, on-shift training, qualification or certification requirements, and qualifying tests as appropriate for the job position. Administrative procedures delineate the scope, objectives and methods D.11-14 Rev. 12 7/94

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ORGANIZATION CHART NUCLEAR QUALITY ASSURANCE PECO Energy Company EXHIBIT IV no.2im

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PBAPS l also processed by the OEAP. Experience items are evaluated and corrective actions initiated as appropriate. Such actions are entered into the Commitment Tracking Program to

~.N j, ensure proper closure. The status of all operating experience information being reviewed, as well as actions being taken to address evaluated items, are reported to management frequently. ~

13.8.6 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG}/

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A Independent Safety Engineering Group (ISE performs in ependent reviews of plant operations. The IS examines uni operating characteristics, NRC issuan s, industry advis les, Licensee Event Reports, and ot r sources of l unit d ign and operating experience info ation, including imilar design, which may

• dicate areas for l plants improving of u 't safety.

The PBAPS ISEG 1 composed of at I st five dedicated, full-time engineers inc ding the ISE6 Superintendent, located onsite. Each has bachelo 's degree in engineering or related science. The perin endent shall have at least 6 years of full-time rcial nuclear experience. The engineers in the PBAPS IS .ach have a minimum of 2 years of full-time commerci nuc ar experience. Not more than one of the members sha have le than 3 years of full-time commercial nuclear perience. luding the experience of the Superintendent, he members coll tively shall have at least 16 years of ull-time commercial uclear experience.

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The PBAPS IS reports to the General anager - Nuclear Quality Assur ce.

The ISEG is responsible for maintaining surveill ce of unit activitiec to provide independent verification t at these activiti-; are performed correctly and that human e ors are reduced as much as practical. The ISEG is not res nsible for si n-off functions.

The ISEG is responsible for performing independent rev'ews I of lant operations, reviewing operating experiences wh ch m indicate the need for improvements, recommending need

'nprovements, and advising management on the overall qualit

/and safety of operations.

R EPL AC.g W4TH ATTACHE D s HeET 13.8-9 Rev. 9 01/91

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PBAPS l Ke ISEG makes detailed recommendations for revised pro dures, equipment modifications, maintenance activit' operat o, ,

activities or other means of impiovin unit safety. b recommendations shall be submitted ough the General Mana -

Nuclear Quality Assurance o the Senior Vice President - clear.

Also, because the Pe Bottom a imerick plant designs are similar, many of t Li rick ISEG's assessments, particularly in the areas esign, training, corrective maintenance and, to some ent, o ations, may be directly applicable to Peach ottom and vi versa.

ISEG The Limerick is similar n composition to has similar responsibiliti as the Peach Bottom ISEG.

l The ISF Superintendent reports to the General M er -

Nucl s

Quality Assurance on matters of both a routine a a ty-related nature.

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W R EPL AC E. WITN A T TACH ED SH EET i

13.8-10 Rev. 9 01/91 (

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. f.5 ATTACHMENT 1 13.8.6 INDEPENDENT TECHNICAL REVIEW PROGRAM An Independent Technical Review Program shall be established to satisfy the following:

13.8.6.1 The Independent Technical Review Program responsibilities shall encompass:

a. NRC issuances, industry advisories, Ucensee Event Reports, and other sources that may indicate areas for improving plant safety;

b. Internal and external operating experience information that may indicate areas for improving plant safety;

c. Plant operating characteristics, plant operations, modifications, maintenance, and surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical; and

d. Making detailed recommendations to the Directors of the affected organizations, with copies to the Director-Nuclear Quality Assurance and the Senior Vice President and Chief Nuclear Officer for revising procedures, equipment modifications or other means of improving nuclear safety and plant reliability.

13.8.6.2 The Independent Technical Review Program shall utilize several on-site personnel who are independent of the plant management chain to perform the reviews. These individuals shall report to the PBAPS Site Quality ,

Division Manager. The PBAPS Site Quality Division Manager is responsible i to ensure the Independent Technical Review Program is implemented as  ;

indicated in section 13.8.6.1. The Site Quality Division Manager shall utilize l information obtained as part of this program as input to advise management  ;

on the overall quality and safety of operations.

13.8.6.3 The written record of technical reviews shall be reported to, at a minimum, l the Senior Vice President and Chief Nuclear Officer, the PBAPS Station Vice President, the Nuclear Review Board, and the Director-Nuclear Quality Assurance. Records of the activities of the Independent Technical Review Program shall be prepared and forwarded each calendar month to the Director-Nuclear Quality Assurance. l l

L.8.6.4 Personnel performing reviews pursuant to section 13.8.6.1 shall have at  !

least 3 years of related experience and a bachelor's degree in engineering l or a related field; or shall have at least 8 years of related experience. The PBAPS Quality Division Manager shall meet the requirements of ANSI N18.1-1971.

g. p.8-9

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