ML20040C053
| ML20040C053 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/25/1982 |
| From: | Bachmann R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Bloch P, Paris O, Shon F Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8201270210 | |
| Download: ML20040C053 (3) | |
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January 25, 1982 J
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Peter B. Bloch, Chairman Dr. Oscar 11. Paris Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atonic Safety and Licensing Board U.S. fluclear Regulatory Comission U.S. fluclear Regulatory Cemission Washington, DC 20555 Washington, DC 20555 Mr. Frederick J. Shon Admin'istrative Judge A;onic Safety and Licensing Board U.S. Nuclear Regulatory Comission Washington, DC 20555 In the !!atter of Consumers Power Company (Big Reck Point Plant)
Docket flo. 50-155 -
(Spent Fuel Pool flodification)
Dear Administrative Judges:
In accordance with the Board's Order of December 11, 1981, the
"'aff encloses its supplemental profiled written testinony on O'Fleill Contention flo. II.G(a).
Sincerely, Richard G. Bachmnn Counsel for flRC Staff
Enclosure:
As stap d above cc: Service List Distribution:
Document Management Branch PDR/LPDR OELD Formal Files
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of I
h CONSUMERS POWER COMPANY
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Docket No. 50-155 (Big Rock Point Plant)
(Spent Fuel Pool Modification)
SUPPLEMENTAL TESTIMONY OF WALTER A. PAULSON CONCERNING O'NEILL CONTENTION NO. II. G(a)
S.Q.1, What does past experience show concerning the adequacy of the licensee's administrative controls?
S.A.I. Past experience showe, that Big Rock Point has never dropped a cask.
However, the licensee's administrative controls have been violated from time to time in the past at Big Rock Point.
In his testimony for the licensee on this contention, Mr. Raciborski indicated that the licensee's quality assurance (QA) program has identified 23 violations of the licensee's administrative controls related tn load handling and pool operations at Big Rock Point.
These violations represent a violation frequency of about once a year over the life of the plant to date. As Mr. Raciborski also indicated in his testimony, not all of these violations of plant administrative con-trols were significant; some were for violations as minor as failure to sign procedural check-off sheets.
To the best of nty knowledge, only one of these 23 violations of plant administrative controls (identified by tte licensee's QA program) resulted in a citation by the NRC Office of Inspection and Enforcement. That single citation by the NRC occurred in 1976. As the above statistics illustrate, one purpose of the licensee's QA program is to find such violations
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and to correct deficiencies to mininize future violations. The licensee's internal documentation presented in Mr. Raciborski's testimony is an example of how the quality assurance program identifies deficiencies.
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