ML20113E685

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Informs Change in Assessment Frequency Does Constitute Reduction in Commitment Described in QA Program Description by Changing Fire Protection Assessment Frequencies
ML20113E685
Person / Time
Site: Peach Bottom, Limerick  Constellation icon.png
Issue date: 07/01/1996
From: Hunger G
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607080263
Download: ML20113E685 (9)
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  • Stat'en Support Deptrtmtnt y

PECO NUCLEAR esco coe uv comneev Nuclear Group Headquarters l

A Umr or PECO EntRcv Q yry fad July 1,1996 Docket Nos. 50-352 50-353 50-277 50-278 l Ucense Nos. NFF.39 NPF-85 DPR-44 l DPR-56 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 ,

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SUBJECT:

Limerick Generating Station, Units 1 and 2  ;

Peach Bottom Atomic Power Station, Units 2 and 3 Request for Approval to Cheage the Quality Assurance Program >

Description by Changing the Fire Protection Assessment Frequencies Gentlemen:

This letter is submitted in accordance with 10CFR50.54(a)(3), which requires prior NRC approval for any change which reduces the commitments in a previously accepted Quality Assurance Program Description (OAPD). The Quality Assurance Program is described in Appendix D of the Peach Bottom Atomic Power Station  !

(PBAPS) Updated Final Safety Analysis Report (UFSAR) and Chapter 17.2 of the ,

Limerick Generating Station (LGS) UFSAR. The OAPDs commit PECO Energy '

Company (PECO Energy) to perform three separate assessments of the Fire Protection Program. These assessments range in frequencies from once every 12 months to once every 36 months. PECO Energy is proposing to consolidate the three Fire Protection Assessment commitments described in the OAPDs into one commitment in each OAPD to be performed once every 24 months. ,

The proposed changes to the LGS and PBAPS OAPDs and their affected pages are i provided in Attachments 1 and 2 respectively.  !

' Assessment Descriotion The current Fire Protection Program assessment frequencies are based on NUREG-0123, " Standard Technical Specifications for General Electric Boiling Water Reactors',

Section 6.5.2.8, " Audits', items h, I, and J. These assessment frequencies are g lo i described by Generic Letter 82-21, " Technical Specifications for Fire Protection Audits." Currently, these assessments are invoked by three commitments included in PBAPS OAPD, Rev.13, Section 17.2.18.1.1 and LGS OAPD, Rev. 5, Section 17.2.18.6, as follows. ll/ fM.

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July 1,1996 Page 2 Assessments of plant activities in the following areas shall be performed under the cognizance of the NRB:

g. The Fire Protection Program and implementing procedures at least once every 24 months.

- h. An independent fire protection and loss prevention inspection and assessment shall be performed annually utilizing either qualified offsite PECO personnel or an outside fire protection firm.

l. An inspection and assessment of ths Fire Protection and Loss ,

Prevention Program shall be performed by an outside qualified fire  !

consultant at intervals no greater than thiriy-six months.  ;

i The current sections of the PBAPS and LGS OAPDs were evaluated in accordance with 10CFR50.54(a)(3). No other references to Fire Protection assessment l frequencies are described in the OAPDs or the Fire Protection Program. The affected pages of the LGS and PBAPS OAPDs are contained in Attachments 1 and 2 respectively.

Proposed Chanae to Assessments PECO Energy requests approval of the consolidation of these commitments in the following areas.

The consolidation will change the frequency for the independent fire protection and loss prevention inspection and assessment from once every 12 months to once every 24 months. This frequency change is based on the fact that during the interval between fire protection assessments, an on-going surveillance is conducted to prov'de l progressive assessments of functional performance.

The consolidation will change the frequency for the inspection and assessment of the Fire Protection and Loss Prevention Program performed by an outside qualified fire consultant from once every 36 months to once every 24 months. This change ,

facilitates the commitment consolidation.

The frequency for the assessment of the Fire Protection Program and implementing  !

procedures will remain the same.

Consolidation of the noted commitments will require that the Fire Protection Program and implementing procedures, including the inspection and assessment of the Fire Protection and Loss Prevention Program, be performed utilizing an outside qualified fire protection consultant at least once every 24 months,

July 1,1996 Page 3 Reason for the Chanae The purpose for consolidating the commitments is for clarity, as well as appropriate allocation of assessment resources based on evaluation of plant functional area performance.

The consolidation is prompted by the guidance provided for assessment frequency by NRC Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance" under the Reviews and Audits section.

The consolidation of Fire Protection assessment commitments will r0sult in an increase in the Quality Assurance Program effectiveness. Currently, the subject assessment area is regimentally scheduled for assessment on an annual basis w!thout due consideration of the need for the assessment in view of performance as indicated by empirical data, events, and trends. This can result in an inappropriate allocation of assessment resources when other areas are in need of an assessment as indicated by performance data.

Assessment activities, to be effective, must be performed on a frequency commensurate with tnelt safety significance, and with due consideration of performance data. The change in frequency for the noted assessment areas to at least once every 24 months will enable NQA management to schedule Fire Protection I assessments and allocate personnel resources based on performance data. This I mode of operation is substantiated by the fact that during the interval between assessments, an on-going surveillance is conducted to provide for progressive ,

assessment of functional performance. j l

The overall net effect of this change is that over a six-year period at least three l assessments (all involving an outside fire protection consultant) will be required.

Currently, six assessments (two involving outside consultants) are required.

Procram Continues to Satisfy Criteria The proposed change to the assessment frequencies will continue to satisfy 10CFR50, Appendix B and will be adequately described in the respective OAPDs. The purpose, I scope, and thoroughness of the current Fire Protection assessments will not be l affected by the change. Management oversight of the assessment process will not be diminished by the change.

Changing the frequency of the independent fire protection and loss prevention inspection and assessment to at least once every 24 months does constitute a reduction in commitment relative to the frequency as described in the OAPDs.

However, this change will not reduce the effectiveness of the Quality Assurance Program, nor will this change reduce the PECO Energy commitment to quality or to compliance with 10CFR50, Appendix B on the following basis:

1. The Fire Protection assessment will be scheduled based on empirical performance data such as trends, events, and surveillance results.

l July 1,1996 Page 4 f

2. On-going surveillance is conducted during the 24-month frequency interval that provide for progressive assessment of functional performance.
3. The allocation of assessment resources will be based upon performance data and thereby provide for timely assessment coverage of areas which warrant oversight attention.

Donclusion The proposed change in assessment frequency does constitute a reduction in l commitment as described in the OAPDs. This reduction requires NRC approval prior to implementation pursuant to 10CFR50.54(a)(3). The efiectiveness of satisfying 10CFR50, Appendix B, requirements will not be reduced as a result of the change.

Because approval of this change would impmve resource allocation and the effectiveness of the Fire Protection assessmeat, we request the NRC's prompt attention to approve these changes. If you have any questions or need additional information, please contact us.

Very truly yours,

4. 0. ,p.

G. A. Hunger, r.

Director-Ucensing Attachments

! cc: T. T. Martin, Administrator, Region I, USNRC W. L Schmidt, Senior Resident inspector, PBAPS, USNRC N. S. Perry, USNRC Senior Resident inspector, LGS R. R. Janati, Commonwealth of Pennsylvania l

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l ATTACHMENT 1 LGS UFSAR l

LGS UFSAR

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17.2.18.6 Assessments of plant activities in the following areas shall be performed under the cognizance of the NRB:

a. The conformance of unit operation to provisiens contained within the Technical Specifications and applicable license conditions at least once every 24 months.
b. The performance, training, and qualifications of the operating staff at least once every 24 months.
c. The results of actions taken to correct deficiencies  !

occurring in unit equipment, structures, systems, or '

method of operation that affect nuclear safety at least once every 24 months.

d. The performance of ~ activities required by the operational QA Program to meet the criteria of 10CFR50, Appendix B,

.at least once every 24 months.

e. The emergency and implementing procedures at least once ,

every 12 months. i

f. The Security Plan an'd implementing procedures at least once every 12 months.
g. The rirc Prctcction Program and implc=cnting precedurec at 10 0t cn c cvery 2' =cnthc.
h. An independent fire protection and lecc prevention incpcction and accccc=cnt chall bc performcd annually utilicing cithcr qualified offcitc DECO personncl cr an cutcide fire prctcction firm.
i. An inspection and accccc=cnt of the rirc Prctcction and Lccc Prevention Program shall bc perfor=cd by an cutsid:-

qualified fire concultant at intervalc nc greater than a..__...,. u .. ___ u_

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p^new;g~h The Fire Protection Program and implementi. . .ng procedures,'

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including an inspection, and assessment of the Fire Protecticn and Loss Prevention Program, shall be performed utilizing an outside qualified fire protectiori ' ' ' " ' ' " '

cons,u,ltan_t, , at l,ea,st, once ' eve _ry~24_ months, . ~- ~'

_,< s s i h. The Ra lolog a En nmental Monitoring rogram and the results thereof at least once per 24 raonths.

k i. The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.

4 k. The Process Control Program and implementing procedures at least once per 24 months.

17-2-56 Rev. G6 4-/46

, 9 ATTACHMENT 2 PBAPS UFSAR 1

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PBAPS l- ,

,17.2.17.6 Types of quality records with minimum retention l periods are listed in Section 17.2.17.3. It should .

l be recognized that the nomenclature of these '

records may vary. For records not listed in ,

Section 17.2.17.3, the type most nearly describing  !

the record in question should be followed with  !

respect to its retention period.  !

l 17.2.17.6.1 NQA and other organizations responsible for records control are defined in the administrative and implementing procedures.

17.2.17.7 Original design, manufacturing, and installation records and specifications shall be controlled and maintained.

17.2.18 Assessments 17.2.18.1 Assessment Program 17.2.18.1.1 Assessments of plant activities in the following areas shall be performed, under the cognizance of the NRB.

a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions at least once every 24 months.
b. The performance, training, and qualifications of the operating' staff at'least once every 24 months.
c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems, or method of operation that affect nuclear safety at least once every 24 months.
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of 10CFR50, Appendix B, at least once every 24 months.
e. The Emergency Plan and implementing procedures  !

at least once every 12 months. j

f. The Security Plan and implementing procedures at least once every 12 months.

i g. The Firc Prctcction Progrcm cnd- implcm nting proccdurcc ct lecct once C/ cry 21 monthc.

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D.11-47 Rev. -14 14 )

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1 PBAPS

,, .. h. T.n indcpendent fire protection and lecc prevention inspection and acccccment chall be l performed annually utilicing cither qualified Offcit: PECC Encrgy perconncl Or an cutcide fire protection firm. l 1

i. An incpcction and acccccmcnt of the Firc l Prctcction and Lccc Prevention Program chall bc performcd by an cutcide qualificd firc eenet*Ltant at intervalc nc grcatcr than 2C month y l

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i h. The- adiological nvironmental. onitoring Program and - the results thereof to meet ~ the provisions of Regulatory Guide 4.1, Revision 1, April 1975, at least once per 24 months.

k i. The Offsite Dose Calculation. Manual and implementing procedures at least once per 24 months.

1j. The Process Control Program and implementing procedures at least once per 24 months.

m k. Any. other area of facility operation considered appropriate by the NRB .or - the Senior Vice President and Chief Nuclear Officer.

17.2.18.1.2 Assessments shall include verification of compliance and effectiveness of implementation of programs, procedures, regulations, and license provisions in the areas audited. Written reports of such assessments shall be transmitted for appropriate action to supervisors having responsibility in the areas assessed.

17.2.18.1.3 Assessments shall be performed by NQA personnel or by specially selected groups or individuals who have no immediate responsibility for the activity they assess and do.not, while performing the assessment, report to a management representative who has immediate responsibility for the activity being assessed.

Timely follow-up action, including re-assessment where appropriate, shall be taken when deficiencies are noted.

17.2.18.1.4 The assessment program and schedules shall be reviewed semi-annually by the NRB.

D.11-48 Rev . 3 14

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