ML20081C223
| ML20081C223 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 03/08/1995 |
| From: | Peveler K IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT |
| To: | Bill Russell NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503170172 | |
| Download: ML20081C223 (5) | |
Text
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IES UTILITIES INC.
NUCLEAR GENERATION DIVISION March 8,1995 NG 0959 Mr. Bill Russell Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Station P1-137
- Washington, DC 20555
Subject:
Duane Arnold Energy Docket No. 50-331 Operating License DPR-49 Reporting of Changes to the Quality Assurance Program Description, UFSAR 17.2 Referennee:
IES Utilities Inc letter of December 5,1994 (NG-94-459) from John F. Franz, Jr. to Bill Russell File:
A-116, A-365, Q-98
Dear Mr. Russell:
Per conversation between F. Maura at NRC Region Ill and K. Peveler at DAEC on March 2 and 8,1995 find attached changes to the previous submittal of December 5,1994.
These changes include adding "once per 12 months" to paragraph 17.2.18.2.2.a, and the withdrawal of previously submitted clarification 6.8 on pages 17.2.A-5 and -6.
Very truly yours,
~k>
~ek Kenneth E Peveler Manager, Corporate Quality Assurance KEP/jmg Attachment Quality Assurance Program Description pages 17.2.35, 17.2.36,17.2 A-5 and 17.2 A-6 cc: J. Franz J. Martin (NRC - Region Ill)
NRC Resident Office B. Fisher F. Maura (NRC - Region 111)
DOCU G. Kelly (NRC - NRR 9503170172 950308 PDR ADOCK 05000331 j1 P
PDR l
1,< v u c o ouane Arnoia ene,oy Cenie,
- 3277 DAEC Road
- Palo. Iowa 52324
- 319/851-7611 I
An IES INDUSTRIES Company
17.2.18.2.1 External Organizations The audit program for suppliers is the responsibility of the Corporate Quality Assurance Department.
Audits will be scheduled at a frequency commensurate with the status and importance of the activity.
In general, the audit schedule will be responsive to th.e performance of audits before the initiation of an activity to ensure that the proper controls are in place, during the early stages of the activity to determine that the proper controls are being implemented, and near the end of the activity to determine that all specified requirements have been met, e
In general, the audit schedule will also include the performance of audits during the activity, assuming that the activity occurs over a sufficient length of time, to determine that the proper controls are being applied and no problems are occurring.
17.2.18.2.2 Internal Organizations The audit program for the internal IES Utilities Inc.
l organizations is the responsibility of the following:
1.
The Corporate Quality Assurance Department, to determine the compliance of the other organizations to the Operational Quality Assurance Program ard to evaluate performance.
2.
The Safety Committee, to determine the compliance of the DAEC to the Technical Specification requirements and license provisions and to evaluate performance.
3.
The Vice President - Nuclear, to determine the overall effectiveness of the Operational Quality Assurance Program.
A prominent factor in developing and revising audit schedules will be performance in the subject area.
The audit schedule will be revised so that weak or declining areas get increased audit coverage and strong areas receive less coverage.
The following internal areas will be audited at least once per 24 months, except where a specific frequcncy is listed.
a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
b.
The performance, training and qualifications of the facility staff.
17.2-35 Revision 15 To be determined
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c.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety at least.once per 6 months.
i d.
The performance of activities required by the Quality Assurance Program to meet the criteria of Appendix "B",
l e.
The DAEC fire protection program and implementing procedures.
i f.
Independent fire protection and loss prevention inspection and audit annually, utilizing either qualified offsite licensee personnel or an outside fire protection firm.
An inspection and audit by an outside qualified fire consultant shall be performed at intervals no greater than three years.
g.
Any other area of facility operation considered appropriate by the Safety Committee or the President.
h.
The radiological environmental monitoring program and the resul s thereof at least once per 12 months.
1.
The OFFSITE DOSE ASSESSMENT MANUAL and implementing procedures.
j.
The PROCESS CONTROL PROGRAM and implementing precedures.
k.
The performance of activities required by the QC Program for effluent and the vendors QA Program for radiological environmental monitoring.
l.
The Security Plan and implementing procedures at least once every 12 months (specified by regulation).
m.
Access Anthor.4 7ation at least once per 24 months f
(specified by regulation).
n.
Fitness for Duty at least once every 12 months (specified by regulation).
o.
Emergency Plan and implementing procedures at least once per 12 months (specified by regulation).
p.
Radiological Protection at least once per 12 months (specified by regulation).
q.
Design change package safety evaluations.
17.2-36 Revision 15 To be determined l
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6.3 Regulatory Guide 1.33 Regulatory Position, Section l
C.4, refers to Section-4.5,=" Audit: Program", of ANSI-N18,7-1976/ANS-3.2 and' lists specified audit frequencies for three (3 ) - audits.
The frequencies for audits lareinow specified'in UFSAR'Section.
17.2.18.2.2.
t 6.4~
Section 4.3.2.3 (Quorum for Independent Review
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' Program) of ANSI-N18.7-1976/ANS-3.2 indicates a'
"[
Quorum for formal meetings "...~shall consist of not-j less than a majority of.the principals, or duly appointed' alternatives... ". Additionally, "the
_7 chairman.(or his duly' appointed alternate) shall be present for all formal meetings".
Section 6.5.2.6 of-j Appendix A (Technical Specifications) to the Facility Operating License indicates "A-Quorum of the Safety Committee shall consist.of the Chairman or Vice Chairman and at least four members with a maximum of i
two alternates as. voting. members".
The requirements' of'the Technical Specifications as stated above shall j
govern.
6.5 With respect to Section 4.3.4 (1), Subjects Requiring
-l l
Independent Review, of ANSI-N18.7-1976/ANS-3.2,. the j
DAEC Safety Committee is not required to. review safety evaluations of changes in the facility which are completed.under 10 CFR Part 50.59.
6.6
.Section 5.1 (Program Description) of ANSI N18.7-l j
1976/ANS-3.2 requires a " summary document" for the Quality Assurance Program.
The QAPD and Appendix A-thereto fulfill this requirement for IES Utilities i
Inc.
6.7 Section.5.2.2 (Procedure Adherence) - Temporary l
procedure changes which do not. change the intent of the procedure.are required to be approved by two i
members of the plant staff, of which one shall hold a senior operators license.
In lieu of one of'these j
members being the on-shift senior operator, a non-shift senior licensed operator may approve of.these temporary. changes consistent with the DAEC Technical Specifications.
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i 17.2 A-5 Revision 15 To be determined l
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6.8 Not Used-6.9-Section 5.2.7. (Maintenance and ' Modifications) ~ of ANSI i
-N18.7-1976/ANS-3.2 lists six standards that are to be applied to activities occurring _during the
{
operational phase that are comparable to related i
activities during design'and: construction.
Five of these standards are addressed elsewhere in this-i Appendix A.
l IES Utilities,Inc. does not follow one of those-listed,1 ANSI N101'.4-1972, Quality Assurance for-Protective Coatings Applied to Nuclear Facilities.
'l See UFSAR Section-17.2.9.5 for IES Utilities Inc.'s controls relative'to "Special Protective Coatings".
'f l
6.10 With respect to Section 5.2.9 (Plant Security and Visitor Control) of ANSI N18.7-1976/ANS-3.2, the DAEC Security Plan meets the stated requirements.
i i
However, the Standard references ANSI N18.17 for l
guidance.
IES. Utilities Inc. is not committed to.
~
The DAEC Security Plan complies with.10 CFR Part 73.
l 6.11 Section 5.2.15 (Review,' Approval and Control of Procedures) of ANSI N18.7-1976/ANS-3.2, fourth
- t paragraph requires:
" Plant procedures shall be. reviewed by an l
individual. knowledgeable.in.the area affected by the procedure no less frequently than' every two years to determine if changes are i
necessary or desirable."
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17.2 A-6 Revision 15 To be determined L
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