ML20002C748
| ML20002C748 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 03/08/1973 |
| From: | Sewell R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Skovholt D US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8101100814 | |
| Download: ML20002C748 (5) | |
Text
.
m ev.
,r 'q..:; ~ g
Q h u.a g &v-S C u l !
) ):g (
4-Consumers an r i g/3
=
?
,.7. y Power
- v. f
~
Company
~
s.rf.-
o.n.,.i omc..: m w..
u.c n.g., A..no.. A
.on, u.enig.n moi. 4,.. coo. eir ree.osso March 8,1773 u,3 j'
"U
- ..CQ k
l
- ? ?[/) P @fe: Docket No 50-155 Mr. Donald J. Skovholt (9,
.p.[-%
License No DPR 6 Directorate of Licensing afs ctIr' US Atomic Energy Commission Washington, DC 20545 V ki A
Dear Mr. Skovholt:
This letter is written in reply to your letter of December 8, 1972, concerning our Quality Assurance Program at Big Rock Point Plant.
We have taken the necessary steps to fully implement the eighteen (18) points of Appendix B of 10 CFR 50 criteria. We have used as a guide in formulating our program ANSI 18.7, Standard for Administrative Controls for Nuclear Power Plants. We feel this is an ongoing type of program based on the fundamentals of the criteria and is continuously being re-fined as techniques are developed.
We have enclosed a copy of Consumers Power Quality Assurance Policy Manual (Attachment A), which outlines the organization (Criteria 1) and discusses Management's responsibility toward each of the eighteen (18) points. Also, enclosed is a copy of the index for the Operational Quality Assurance Procedures Manual for the Big Rock Point Plant (Attachment B).
The following discussion will attempt to relate each of the remaining seventeen (17) points of the criteria to specific sections of the Quality Assurance Procedures Manual.
Section 2 - Quality Assurance Program - A written program has been implemented identifying the scope of activities to be covered by the program, assigning responsibilities and providing for the review of those activities.
Section 3 - Design Control - The adaptation of design control measures of the operating organization involves the review of changes to the facilities in accord with 10 CFR 50.59 requirements. In meeting these requirements, the procedures of Paragraph A.4.2.3 of the Station operating Procedures (Section 9A of the Quality Assurance Muual) apply. All safety-related changes are reviewed by the Safety Audit and Review Board (SARB) for determination as to whether they involve an unresolved safety problem.
All changes are screened at the Plant level by the Plant Review Committee.
-( 1
.E 1598 f/ C// O O ff
(
(
Mr. Donalr' J. SPc vholt 2
Dockst No 50-155, Licanse No DPR-6 March 8, 1973 Section h - Procurement Document Control - The control of procurement documents is gpecified in Section 6E of the QA Procedures Manual. This procedure is a computerized method of filing and controlling all procurement documents and provides for their review by the Plant QA Engineer.
Section 5 - Instructions, Procedures and Drawings - Activities affecting quality are divided into various categories such as operations, maintenance and testing. Procedures for these activities have been written in accordance with ANSI 18.7 guidelines and are to be found in the designated sections. These procedures are issued and approved by Plant Management.
Section 6 - Document Control - Section kA of the QA Manual describes the program and procedures that have been developed to control documents affecting quality. It assigns responsibility for the mainte-nance of various documents, the control of issuance of documents, and issuance of changes to documents. It provides for a periodic review of controlled documents to ensure they are complete and up to date.
Section 7 - Control of Purchased Material, Equipment and Services - The program to ensure that procured items conform to quality requirements is outlined in Section 6 of the QA Manual. Procured items are categorized as to their application to safety-related systems, are controlled upon receipt and are only released for use after proper inspec-tion and verification of proper documentation.
Section 8 - Identification and Control of Material, Parts and Components - Identification and marking of procured material is controlled by implementation of the requirements of Section 6C of the QA Procedures Manual. All safety-related items are serialized and assigned a safety class designation. The procedure requires that all such parts be labeled to ensure their proper identification.
Section 9 - Control of Special Processes - Special processes such as velding and nondestructing testing are controlled by implemen-tation of Sections 7E and 8 of the QA Procedures Manual supplemented by Consumers Power standards for these processes. Procedures and personnel are qualified in accordance with applicable codes and standards. Only those personnel certified by appropriate Consumers Power Management to be qualified for a given process are allowed to perform that process.
Section 10 - Inspection - A program of inspection is included as part of all the various activities affecting quality as described in appropriate sections of the QA Procedures Manual. A specific inspection program is included as Section 10 of the QA Procedures Manual. The In-Service Inspection Program is conducted in accord with written procedures to meet the requirements of ASME Boiler and Pressure Vessel Code, Sec-tion 11, and Plant Technical Specifications.
(
i Mr. Donalet 1 svholt 3
Docket No 50-197, License No DPR-6 March 8, 1973 Section 11 - Test Control - A test program is outlined in Paragraph 4.4.6 of the Station Operating Procedures (Section 9A of QA ProceduresManual). This program is established to meet the require-ments of the Plant operating license. It is conducted in accord with written procedures and forms and results are reviewed by appropriate level of Plant Management.
Section 12 - Control of Measuring and Test Equipment - The control of measuring and test equipment is effected by implementation of the requirements of Section 9B of the QA Procedures Manual. Test equipment used on safety-related equipment is calibrated on a periodic basis as recommended by the roanufacturer or dictated by experience.
Stickers and/or calibration sheets are used as objective evidence of calibration. Installed instruments in safety-related systems are periodically calibrated as outlined in the written instrument procedure program.
Section 13 - Handling, Storage and Shipping - Measures to control the handling, storage and shipping of materials affecting quality are accomplished through in:plementation of Section 7C of the QA Procedures Manual. This section requires written procedures or instructions for the handlin6, shipping and storage of safety-related items and for the separation of nonconforming items.
Section 14 - Inspection, Tests and Operating Status - As applied to operating plants, this requirement is covered by Consumers Power Tagging Procedure which is outlined in Paragraph A.2 9 of the Station Operating Procedures (Section 9A of the QA Procedures Manual).
Items not in routine service are red or yellow tagged in accord with the Tagging Procedures. Tagging must have written supervisory approval.
Section 15 - Nonconforming Material, Parts or Components -
Nonconforming materials are controlled through implementation of Section 6G of the QA Procedures Manual. Segregated " hold" and " reject" areas are established for this purpose.
Section 16 - Corrective Action - Measures to ensure that deficiencies, deviations, malfunctions, etc, are identified, documented and corrected are outlined in Section 4C of the QA Procedures Manual.
A computerized form listing the deviations and requiring corrective action by set action dates is in use. These are reviewed by SARB.
Section 17 - Quality Assurance Records - Procedures to ensure that records of activities affecting Quality Assurance are identified, maintained and are retrievable, are contained in Section 4A of the QA Procedures Manual. QA records responsibility is assigned. In the future, these records will be indexed and stored by cocputer entry.
Mr. Donald J. 6xovholt 4
Dock 3t No 50-155, Lic:nso No DPR-6*
' March 8, 1973 Section 18 - Audits - A comprehensive system of planned and periodic audits of both plant and vendor activities affecting quality are outlined in Section 5 of the QA Procedures Manual. The audits are conducted by cognicant General Office Nuclear Operations personnel.
They are conducted in accordance with audit plans and are reviewed by menbers of SARB.
Yours very truly, i
w af l
WGF/ map Ralph B. Sewell Nuclear Licensing Administrator CC: BHGrier, USAEC e
_,...