ML20140B037

Safety Evaluation Accepting QAP Description Change

ML20140B037
Person / Time
Site:	Peach Bottom
Issue date:	05/30/1997
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20140B029	List: ML20140B027 ML20140B037
References
NUDOCS 9706050273
Download: ML20140B037 (2)

Text

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>"s o p *, UNITED STATES a

ia s* j NUCLEAR REGULATORY COMMIS810N i i WASHINGTON, D.C. 30008 4001

• % * * * * * /g  ;

I SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION  ;

1

-0UALITY ASSURANCE PROGRAM DESCRIPTION CHANGE f

PECO ENERGY COMPANY 5 PUBLIC SERVICE ELECTRIC AND GAS COMPANY  !

DELMARVA POWER AND LIGHT COMPANY  !

ATLANTIC CITY ELECTRIC COMPANY '

i 4

PEACH BOTTOM ATOMIC POWER STATION. UNITS 2 AND 3  !

3-  !

. DOCKET NOS. 50-277 AND 50-278 jJ .

I

1.0 INTRODUCTION

I I'

By letter dated February 24, 1997, PECO Nuclear Unit of the PECO Energy I i

Company (PECO) transmitted a proposed' revision to Revision 13 of the Peach Bottom Atomic Power Station Quality Assurance Program Description in  ;

accordance with 50.54(a). The staff has reviewed the submittal in accordance i with 50.54(a) and determined that the change to the quality assurance program  ;

j is acceptable in that the quality assurance prooram continues to meet the i j requirements of Appendix B to 10 CFR Part 50 J meets the additional  :

i requirements of 50.34(B)(6)(ii) by discussing how the applicable requirements  ;

j of Appendix B will be satisfied. .

j This safety evaluation describes the staff's analysis of the proposed i i alternative to previously approved provisions for the lead auditor  !

j qualifications. j 1- 2.0 EVALUATION OF PROPOSED ALTERNATIVE FOR THE LEAD AUDITOR OVALIFICATION

PROCESS

(

) 2.1 Lead Auditor Qualification Process i

The licensee's Quality Assurance program description is contained in Appendix D of the Peach Bottom 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 QA 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 participated in a minimum of five (5) quality assurance audits within a period of time not to' exceed three (3) years prior to the date of qualification, one audit of which shall be a nuclear quality ,

assurance audit within the year prior to the individual's '

qualification.

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t As described in the February 24, 1997, submittal, the licensee has proposed the following alternative to the provisions contained in Section 2.3.4 of ANSI 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 audits, and having met the other provisions of Section 2.3 of ANSI /ASME N45.2.23-1978, the individual may be certified as being qualified to lead audits."

The staff conducted its review in accordance with the guidance in Section 17.2, " Quality Assurance During the Operational Phase," of NUREG-0800,

" Standard Review Plan" (SRP 17.2). The introduction paragraph of Section II, i

" Acceptance Criteria," of SRP 17.2 contains provisions for the 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 proposed by the licensee represents an acceptable alternative to Item 1883 of SRP 17.1 which is referenced in the criteria for audits in SRP 17.2. This determination was based on the licensee's quality assurance program controls which require that 1) prospective lead auditors effectively demonstrate their ability to implement the audit process and lead 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 '

quality assurance audit within the year preceding the individual's effective date of qualification. The alternative also contains provisions that upon successful demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of 1 Section 2.3 of ANSI N45.2.23-1978, the individual may be certified as being i qualified to lead audits.

3. CONCLUSION The staff has also determined that the proposed alternatives to provisions l identified in Revision 13 of the Peach Bottom Atomic Station's Quality J Assurance Program Description, related to lead auditor qualification, I represent an acceptable alternative to the review criteria contained in '

Section 17.2 of NUREG-0800 and that these changes are acceptable and continue to meet the pertinent requirements of Appendix B to 10 CFR Part 50.

Principal Contributor: L. Campbell Date: May 30, 1997

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