ML20070M118
| ML20070M118 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 03/07/1991 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CON-NRC-91-023, CON-NRC-91-23 VPNPD-91-084, VPNPD-91-84, NUDOCS 9103210073 | |
| Download: ML20070M118 (2) | |
Text
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POWER COMPANY i
231 w McNoas Po tex 2046 Muouxee wt 53201 (444):214 345 i
VPNPD-91 084 NRC-91 023-March 7, 1991 i
Mr. A.
Bert Davis, Regional Administrator U.
S.
NUCLEAR REGULATORY COMMISSION, REGION III 799 Roosevelt Road-Glen Ellyn, IL~60137-1
Dear Mr. Davis:
3 DOCKET NOS. 50-266 AND 50-301 REPLY TO NOTICE OF DEVIATION INSPECTION REPORTS 50-266/90027 AND 50-301/90027 POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 Your' letter of February 5, 1991, transmitted the subject inspection report.
The report contained one Notice of Deviation associated with the Quality Assurance (QA) Program as described in the Final Safety' Analysis Report (FSAR),-Section 1.B.
We received your letter on_ February 11, 1991.
The Notice'of Deviation cites discrepancies between actual practices being implemented and our approved QA Program.
- FSAR, Section~1.8, " Quality Assurance Program," states-.that "In matters related to quality assurance, the manager (Point Beach Nuclear Plant) remains cognizant through direct involvement.and1through i
input'from various sources including the in-plant Quality Assurance Coordinator (QAC) and'QA Representatives.
The Quality. Assurance Coordinator:and QA Representatives are appointed by the-Manager and-f are considered concurrent assignments."
The' deviation notes-that-we no-longer utilize the-position of QA Representative as described in the FSAR and plant procedures, and therefore','none are appointed.
Additionally, the current QA Coordinator does not meet
-the experience level criteria specified-in the-procedure.
We--acknowledge that our current practice is not consistent with the i
description in the FSAR, Section 1.8.
The current-QA Program 1 description:in the FSAR is' out of date because of timelags associated with our annual updates to Section 1.8, NRC acceptance of changes, and the subsequent issuance of these changes during_the FSAR update in'accordance with 10 CFR 50.54(a).- We are presently l
taking steps to resolve this problem.
A review of Section 1.8 was l
initiated;in late January, and proposed changes and updates will be l
submitted for NRC -acceptance in March.
This early update submittal 9103210o73 910307
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"Mr. A. Bert Davis l
. March.7,-1991' Page 2
.should allow us to11ssue Section 1.0 changes as part of our annual FSAR revisions-which are normally issued in July.
Future-Section 1.8 updates will,also be handled in this manner.
l 1
LThe' specific. discrepancies related to the-QA Coordinator-(QAC) and
-QA: Representatives result from evolving-changes'in quality assurance organizational functions.
In April 1989 a Site Quality Assurance group was established.
At that time,1some of-the functions previously_ performed'by the QAC and QA Representatives were transferred to'the Site QA (SQA) group.
Since that time,
-other' functional changes-have occurred and currently all functions g:
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previously performed by the1QAC and QALRepresentatives.are now performed by SQA.
We have, therefore, fcand it unnecessary to
-maintain the QAC_and QA_ Representative assignments.
As stated Labove,.these changes have not yet been reflected in. revisions to
.Section 1.8 in a: timely manner..The 1991 update of the FSAR, s
-Section#1.8 will-reflect these changes, and administrative procedures-PBNP 1.7.3 (" Quality Assurance Coordinator");and PBNP j'
,1.7.4f(" Quality l Assurance Representatives") will be canceled by March-15,. 1991.-
In-lightfor the discrepancies which were-noted, we have also
'determinedJto=take an:overall look at our entire-QA Program.
The l
QA Section isiin the process of obtaining an independent. third-
. party assessment of the WE QA-program.
We believe this self-cinitiated1 assessment will give us a more_ complete perspective on our1 quality-assurance practices and their implementation.
Following completion of this assessment, a-plan will be developed
- tofsddress anymissues which may beLidentified.
We enticipate that performance:of this--assessment and development of an action plan will-be completed byLoctober of this year.
If-you have any questions concerning this information, please e
contact Tus.
Veryftruly.yours,.
1 CL's $(I 'L l
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C.iW. ofay
=Vice President Nuclear Power LCopy.'to; Document Control Desk NRC Resident Inspector
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