ML20202J516

USAR Section 17.2, QA During Operations Phase Content Affected by Proposed Change

ML20202J516
Person / Time
Site:	Davis Besse
Issue date:	12/31/1996
From:	CENTERIOR ENERGY
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ML20202J513	List: ML20202J508 ML20202J516
References
NUDOCS 9802230167
Download: ML20202J516 (12)

Text

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ATTACllMENT 1 DAVIS-BESSE NUCL, EAR POWER STATION USAR SECTION 17.2," QUALITY ASSURANCE DURING THE OPERATIONS PIIASE" CONTENT AFFECTED BY PROPOSED CHANGE 4

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} . Docket Number 50-346 License Number NPF-3 Serial Number 2509 0"0"""" ..,

INFORMATION ONLY PRESIDENT - POWER GENERATION GROUP 20 The President -

Power Generation Group reports to the Chairman, President and Chief Executive Officer and is re ponsible for directing the operation of all CEC /CSC power stations.

SENIOR VICE_ PRESIDENT - NUCLEAR 18 The Senior Vice President - Nuclear reports to the President - Power 20 Generation Group and is responsible for directing the operation of the 4 Davis-Besse Nuclear Power Station.

VICE PRESIDENT - NUCLEAR - DAVIS.BESSE 14 The Vice President - Nuclear reports directly to the Senior Vice President 18

- Nuclear and is responsible for all matters relating to the engineering, design, operations, maintenance and modification of the Davis-Besse Nuclear l1 Power Station. The Vice President - Nuclear exercises responsibility over 14 the Toledo Edison Nuclear Group. He reserves the authority to conduct or order the auditing of any activity at any time to determine compliance to 1 the requirements specified in the Nuclear Quality Assurance Manual (NQAM).

He is responsible for final approval of the Nuclear Quality /.ssurance Manual 19 (NQAM) and the ASME Quality Assurance Manual (AQAM) and is also responsible for conducting continual review of the overall effer**-aness of the Quality 20 Assurance Program. 6 17.2.1.4 Toledo Edison Nuclear Group 18 DIRECTOR - NUCLEAR ASSUPANCE

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l1 The Director - Nuclear Assurance reports to the Vice President - Nuclear. 20 He is authorized to identify quality problems; initiate, recommend or provide 19 solutions, through d,esignated channels; and verify implementation of solutions. Conditions adverse to quality that appear to warrant suspension of reactor operation including startup or power generation are immediately reported to the Plant Manager. The Director - Nuclear Assurance is responsible for the development, maintenance and approval ef the Nuclear Quality Assurance Manual (HQAM) and the ASME Quality Assurance Manual (AQAM) as their sponsor. The Director - Nuclear Assurance is responsible for adequate staffing of the Nuclear Assurance Department. The - rector is responsible for managing the activities of independent safety engineering, and the review of external information and plant operations assessments. The Director - Nuclear Assurance is responsible for managing support services g associated with procedural control, record: management and document control.

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' and coordinating support servicer requested f rom the Centerior Service 20 Compaay. The Director - Nuclear Assurance is responsible for ntclear training and providing direction for the Nuclear Training Ptagram to support 19 the needs of site personnel in accordance with laws, regulations, standards and commitments. The Director. Nuclear Assurance is also responsible for security to ensure the security requirements are maintained in accordance with the Industrial Security Plan.

17.2-4 REV 20 12/96 0

', Docket Number 50 346 License Number NPF-3 Serial Number 2509 Attachment 1 Page 2 HANAGER - NUCLEAR SAFETY AND INSPECTION 19 9

The Manager - Nuclear Safety & Inspection reports to the Director - Nuclear 19 Assurance and is responsible for managing the Nuclear Safety & Inspection staff in the quality review, inspection, and examination of plant structures, 14 systems, and components within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and en;ineering specification requirements. This responsibility includes the inspection of welding to verify it meets ASME, National Board, and State of Ohio requirements in addition to coordinating tne activities of the Authorized 1 Inspection Agency to ensure Code compliance. The Manager - Nuclear Safety i 19 Inspection is also responsible for development and maintenance of the Nuclear Safety & Inspection and selected Nuclear Assurance Department Procedures and review and approval of the ASHE Quality Assurance Manual (AQAM) to verify it meeto ASHE, National Board, and State of Ohio requirements. Tne Hanager - Nuclear Safety & Inspection is also responsible for ::Vics cf 11

tiv: ::ti:n d:::::nt: fe:- 1::: ::t, review and approval or concurrence 20 with select site procedures, receipt inspections, vendor surveillances and review of vendor supplied documentation, and Nuclear Safety & Inspection 19 Staff training. The Manager - Nuclear Safety & Inspection is also responsible for directing the activities of the independent safety 18

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engineering group in providing technical expertise onsite to allow for systematic and independent assessment of plant activities, surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may af fect the underlying assumptions in the USAR Accident Anelysis. The Manager - Nuclear Safety & Inspection is also 19 responsible for the review of all external information received in support of improved performance and reliability and for plant operations assessments. 18 The Manager-Nuclear Safety and Inspection is responsible for cootdinating 20 inspection and examination services provided by the Centerior Service Company.

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HANAGER - QUALITY ASSESSHENT 18 The Manager - Quality Assessment reports to the Director - Nuclear Assurance. 19 but is authorized direct access to the Vice President - Nuclear or higher

, Corporate management for quality assurance matters if such a need exists.

The Manager - Quality Assessment is free of non-QA related duties. He is 3ndependent f rom cost and scheduling considerations when opposed to safety considerations. He has the authorit/ and organizational fr'edom necessary to adequate;y fulfill assigned responsibilities. The Manager - Quality Assess-ment is responsible for assuring and adelsing the Plant Manager and Vice 20 President-Nuclear of the adequacy and effectivene:s of implementation of th?

approved Nuclear Quality Assurance Program. He is responsible for review 19 and approval of the Nuclear Quality Assurance Manual to verify it meets codes, standards, and regulatory commitments. He also has the responsibility and authority for the interpretation of the Nuclear Quality Assurance Manual requirements, and codes, standards and regulatory commitments as they pertain i to quality assurance requirements. The Manager - Quality Assessment has the authotity to identify quality problems; initiate, recommend, or provide solutions, through designated channels: verify implementation of solutions:

and verify conformance to established quality requirements. The Manager -

Quality Assessment has the responsibility and authority to suspend i 17.2-5 REV 20 12/96

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Docket Number 50-346 License Nurtber NPF-3 Serial bhirnber 2509 Attachment ]

, Page 3 D-B (stop work) any activity except reactor operation not in conformance with requirements. He is responsible for the adequate staffing of the Quality Assessment Section to ensure that the requirements of the HQAM are effectively implemented. The Manager - Quality assessment is responsible for managing the Quality Assessment staf f in ths performance of internal and external (vendor)

QA audits, and for QA surveillance of station operations. He is also respens-ible for the development and maintenance of Quality Assessment Section and 19 selected Nuclear Group and Nuclear Assurance Department Procedures, review and approval or concurrence with inter-department procedures / Nuclear Group 20 procedures and selected site procedures, the review and approval of the vendor quality assurance programs and procedures, review of selected 19 procurement documents, and control of the approved vendors litt. He is also responsible for the development, maintenance and implementation of the trending and analysis pregram and Quality Assessment staf f training. The x Manager - Quality Assessment is responsible for the independent assessment of engineering activities and products. and for assessment of the pirnt chemistry and radiochemistry programs.

MANAGER - QUALITY SERVICES 18 The Manager - Quality Services reports to the Director - Nuclear Assurance and is responsible for managing support services associated with quality and 19 non-quality records management, document control, site wide procedure 18 control and administrative services.

HANAGER - SECURITY 19 The Manager - Security raports to the Director - Nuclear Assurance and is responsible for managing security related activities in accordance with the Industrial Security Plan and coordinating security background investigations 20 and fitness-for-duty and security force health assessment medical services provided by the Centerior Service Company.

19 MANAGER - NUCLEAR TRAINING The Manager - Nuclear Training reports directly to the Director - Nuclear Assurance and is responsible for the development and implementation of nuclear training programs to ensure compliance with regulations, commitments and industry stanuards and coordinating medical services provided by the 20 Centerior Service Company for operating personnel health assessment when required for training / qualification.

INFORMATION ONLY 37.2-6 REV 20 12/~

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,' Docket Number 50-346 License Number NPF 3 Serial Number 2509 m;;r" ~

FORINFORN10NONif 17.2.15 NONCONFORMING MATERIALS. PARTS. OR, COMPONENTS 17.2.15.1 Noacon formance Identi fic gf,, Loll Items or activities which deviate frura approved spec.t fications, codes, drawinP9 procedures or other applicable documen's. t or any or condition that affects the quality of items, services, or program, or prevent a structure, system or component from performing its intended function is considered to be a nonconformance and is identified as such and documented.

5 Wen nonsonformances are fcund or suspected an appropriate status identi-fication such as the station tagging system, or hold tag is used to preclude further activity pending resolution of the adveras condition. Procedures contain provisions to ensure that nonconformances ruch as equipment malfunctions. procedure deviations, defective material and items, and

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deviations to regulatory requirements are promptly identified, documented.

evt.luated for impact on plant operability, reportability and significance. '

and corrected.

Nonconformances discovered by suppliers during the naufacturing of l5 materials or items are reported to the Nuclear Group. The supplier's 14 disposition is approved by Engineering or their agent. 19 Whenever a condition adverse to quality is identified that may t e detri- l9 mental to the safety of personnel or safe operation of the plant, immedi-ate action in taken to notify the Shif t Supervisor. If necessary, notification occurs prior to documenting the condition to ensure control 5 of the condition or item.

The Manager - quality Assessment has the author'ity to stop or delay work 19 activitieu, except reactor operations, at any time after a condition 0

- edverse to quality is identified, if proceeding could jeopardize the quality of an item, adversely affect the quality of subsequent work, or degrade the condition. Conditions af fecting react.or operations are

• reported to the Plant Manager for corrective mer.sures. Hold tag,u are attached to non-installed nonconfo. ming equipment that has been evaluated as non-operable and to nonconforming material and items found deficient durir.g tne receipt inspection process. Nonconforming plant installed equipment it ic;entified through the normal station tagging program. When practienl. nonconforming items are physically segregated from conforming items.

5 17.2.15.2 Review and Evaluation Documented ronditions ac' verse to quality ar reviewed by the initiators supervisor to verify the reported condition. If the condition could affect plant operation, the Shift Superviser evaluates the condition for 19 impact on Techical Specification requirements and. for determination of 5 the reportability to the NRC or other regulatory agencies.

If the condition could affect dry spent fuel storage operation, the Shif t Supervisor evalue es the condition for impact on the Dry Spent Fuel Storage 20 Cask Certificate of contpliance requirements and for determination of the reportaoility to the NIC.

17.2-42 REV 20 12/96 1

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Decket Number 50-346 License Number NPF-3 Serial Number 2509 Attachment 1

, Page 5 D-B As part of the evaluation and dispositior.ing process, nonconforming equipment is evaluated for the ability to perform its intended function and the department responsible for implementing the disposition is design-nated. If the nonconforming equipment cannot perform its intended func- 5 tion, an evaluation of the affected system's operability in accordance with Technical Specifications is performed.

Engineering evaluation of the nonconforming condition includes an assessment 19 to ensure that the item meets the functional requirements, including 5 performance, safety, reliability and maintainability. The engineering evaluation is required to be documented and traceable to the applicable corrective action document. -

w (ESP M3tht y"AQA4 a tu b n

C he acceptability of repaired or reworked items u ceterminea oy m } yin

! threugh inspection or testing that the lev 1 of quality obtained for the item 9 is LAsps_. or at_ le_a s t eouivalent to *

• neidnal quality r=;"i ents.

When tb nunconformance has been resolved, ' :1::: t.:::::nc e personr.el 18 s.3gnify their concurrence on the corrective action document.

, 5 Systems whjch contain nonconforming material or items and which have been declared inoperable due to the nonconforming condition, are not declared operable until documentary evidence is available to verify the material or item is in conformance with specified requirements or a documented evalua-tions provided by Engineering to ensure that it will satisfactorily perform 5 its intended function.

17.2.15.3 10CFR21 Reporting Conditions adverse to quality are evaluated and reported in accordance with 14 the provic'.ons of 10CFR21. 5 Material or items identified by suppliers as reportable in accordance with 14 10CFR21 are reviewed by Engineering to determine applicability and to 10 initiate corrective actions as appropriate.

Items considered to be reportable under 10CFR21 are reported to the Plant Manager and the Regulatory Aff airs Section for notification to the NRC in 18 accordance with the requirements of 10CFR21. 5 17.2.15.4 Trending The Director - Nuclear Assurance has established a trending and analysis 18 program to detect generic problems, adverse quality trends and repetitive 5 c ondition t. . This program includes the review of documented conditions adverse to quality and significant conditions advsrse to quality at a minimum. The specific documents included in the trending and analysis f progran are identified and distributed in accordance with implementing 9 procedures.

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17.2-43 REV 19 5l95

Docket Number 50-346 Ucense Number NPF.3 Senal Number 2509 Attachment 1

, Page 6 D*8 s 17.2.10 CORRECTIVE ACTION 17.2.16.1 General Procedures have been established to ensure that significant conditions adverse to quality are promptly identified, documented, evaluated for their significance, and corrected. These procedures require that-the completed corrective action be documented and verified, and that the conditian be r reported to supervisory personnel. '

Conditions adverse to quality are also evaluated as to their reportability te the NRC in accordance with the provisions of 10CFR20, 10CFR21, 10CFR50, 5 It0FR70, 10CFR72 OR 10CFR73. 20 5

For significant conditions, the cause is determined and corrective action to preclude repetition identified, and the _ status is tracked until correc-tive action is complete and verified.

(' esp y ed k tv%cYut to Corrective action documents conta . provisions tor icentifying the root cause of the condition adverse t quality, the recommended corrective action, and the corrective act n taken to prevent recurrence, in addition ,

to the M_;L..;

.;..._...; 0;pe..-...;'; documented concurrence of the adequacy 18 of the corrective

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action. TL; Mu;1;.; f.;;;;;;;; 0;p_,;;;.. ; 21; h:; th; 2__.____ _ ,__ - - - "

5 The quality assurance requirements in procurement documents or contracts require the supplier or contractor not only to identify material or parts that do not conform to the procurement requirements, but alst to determine

.and correct the causes for the condition adverse to quality. When suppliers furnish items that do not conform to procurement requirements, the 7-nonconformance is documented snd evaluated for further action. The actions vary depending on the nature of the nonconformance and the supplier's quality history and may involve obtaining supplier corrective action or supplier reevaluation as a prerequisite for future procurement activities with the supplier.

17.2.16.2 Significant conditions Adverse to Quality 1 Conditions adverse to quality are considered significant when any of the following conditions exists

a. The condition requires immediate notification to the NRC in accor-dance with 10CFR50.72 or 10CFR72.75(a). 20 1

b. A serious failure or breakdown in the implementation of the Nuclear Quality Assurance Program,

c. A significant deficiency in final design as approved and released for implementation, such that the design does not conform to the criteria and basis stated in the Updated Safety Analysis Report (USAR) or Site 20 Certified Safety Analysis Report (CSAR) for dry spent fuel storage.

17.2-44 REV 20 12/96 i

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, Docket Nornber 50 346 License Number NPF-3 Serial Number 2509 Attachment i

, Page 7, D-B

d. A significant deviation from performance specifications or a significant deficiency in construction of, and/or modification to a structure, system or component which requires extensive evaluation, 5 redesign, or repair to meet the criteria and basis-stated in the USAR, site CSAR or to otherwise establish the adequacy of the structure. 20 system, or component to perform its intended safety function is 5 discovered,

e. A closed conunisment to an outside agency has not been implemented as required.

f. A repetitive or adverse trend exists.

g. Fa uure to resolve a deficiency in a timely manner or any condition 5 determined to be significant by the Director - Nuclear Assurance such 18 as the existence of a repetitive or adverse trend. >

Significant conditions adverse to quality are documented and reported to the Vice President - Nuclear, and the affected Nuclear Group Directors. 9 When the corrective action to a significant condition adverse to quality 5 has

vi:r been

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17.2.16.3 Tracking a d Resolution Implementing procedu s define the methods employed for tracking and 5 resolving corrective etion documents. The responsible Department has the 8 responsibility to tra k the' status of conditions adverse to quality until 5 the implementation of he corrective. action has been completed and to assure that adequate resource are applied to close out the conditions adverse to quality in a timely ma ner. .' ~ ' -

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17.2.17 (b CM ~ MOtedLA NtnSM h QUALITYASSUPANCERECORDSf g 17.2.17.1 General %ftpf' 4 Pertinent documentation classified as Quality Assurance Records such as

_ <<th d fgC design, procurement, fabrication, inspection, nonconformances and corrective action, tests, audits, and construction reports: document reviews, material analysis, and monitoring of work performances qualifi-cation of personnel, procedures and equipment: drawings, specifications, calibration procedurt.s and reports, NDE procedures and reports: pertinent operating logs: maintenance and modification procedures: reportable 5 occurrences: and other records as required by the Technical Specifications and the Dry Spent Fuel Storage Caskt, Certificate of Compliance are 20 retained and available for review. 5 A Nuclear Records Management Program, as defined in approved implementing procedures. Jientifies these records in the nuclear records list. This list is reviewed, approved and revised in accordance with written proce-dures and conta!ns provisions for identifying the records to be retained, identifying the organization (s) witn record copy responsibility, specifies the minimum retention period for each record type and specifies the method 17.2-45 REV 20 12/96 1

ATTACHMENT 2 DAVIS-BESSE NUCLEAR POWER STATION EVALUATION OF PROPOSED QUALITY ASSURANCE PROGRAM REDUCTIONS

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Docket Number 50 346 License Number NPF-3 Serial Number 2509 Attachment 2

,Page1, DAVIS BESSE NUCLEAR POWER STATION USAR CIIAPTER 17.2," QUALITY ASSURANCE DURING TIIE OPERATIONS PIIASE" 19 CFR 50.54 EVALUATION FOR UCN 97-124U

SUMMARY

OF MODIFICATIONS The proposed changes replace the Nuclear Assurance Department's Nuclear Safety and Inspection -

Section in-line close-out review of corrective action documents other than audit findings with line management's review of the proposed corrective actions for adequacy. The changes also replace the Nuclear Assurance Department's follow-up review au j audit of all significant conditions adverse to quality other than audit findings with reporting of the corrective actions taken to appropriate levels of management. The Nuclear Assurance Department will continue to perform audits as described in USAR Section 17.2.18," Audits."

PROPOSED CHANGES The proposed changes to the USAR Chapter 17.2, Quality Assurance Program, are shown on the ma;ked-up pages of Sections 17.2.1.4,17.2.15.2,17.2.16.1, and 17.2.16.2 and are considered to be reductions in commitments under 10 CFR 50.54(a).

DESCRIPTION OF MODIFICATIONS I) 17.2.1.4, Page 17.2-5: Modify the fourth sentene in the Manager - Nuclear Safety and Inspection description by removing the phrase " review of all corrective action documents for close-out," to read:

"The Manager - Nuclear Safety & Inspection is also responsible for review and approval or concurrence with select site procedures, receipt inspections, vendor surveillances and review of vendor supplied documentation, and Nuclear Safety & Inspection Staff training."

2) 17.2.15.2, Page 17.2-43: Restructure the third paragraph by moving the first sentence to follow the second sentence in the paragraph, and modify the second sentence by replacing " Nuclear Assurance" with " responsible management." The proposed third paragraph would read:"When the nonco-formance has been resolved, responsible management personnel signify their concurrence on the cor .ctive action document. The acceptability of repaired or reworked items is determined by verifying through inspection or testing that the level of quality obtained for the item is the same as, or at least equivalent to the original quality requirements."

3) 17.2.16.1, Page 17.2-44: Modify the first sentence in the fourth paragraph by replacing " Nuclear Assurance Department's" with " responsible management's" to read: " Corrective action documents contain provisions for identifying the root cause of the condition adverse to quality, the recommended corrective action, and the corrective action taken to prevent recurrence, in addition to the responsible management's documented concurrence of the adequacy of the corrective action."

Docket Number 50-346 License Number NPF-3 Serial Number 2509 Attachment 2

, Page 2

4) 17.2.16.1, Page 17.2-44: Eliminate the second sentence in the fourth paragraph: "The Nuclear Assurance Department also has the Gnal review of all corrective action documents for closcout." -

5) 17.2.16.2, Page 17.2-45: Modify the second sentence in the Hrst paragraph by replacing " Nuclear Assurance Department perfonns a follow-up review or audit to verify the adequacy of the corrective action" with "correctise action taken shall be documented and reported to appropriate levels of management" to read: "When the corrective action to a signi6 cant condition adverse to quality has been completed, the corrective action taken shall he documented and reported to appropriate levels of management."

E REASON FOR MODIFICATIONS These changes are designed to establish greater product ownership and accountability in line management for ensuring proper corrective action administration and implementation, and allow the Nuclear Assurance Depanment to continue to focus on the independent evaluation of corrective action documents and the effectiveness of the corrective action process through the 10 CFR 50 Appendix B audit process.

The proposed clari6 cation of the discussion of nonconformance review and evaluation on USAR page 17.2-43 is made to improve readability of the paragraph and provide a more complete understanding of the processing of nonconformance/ corrective action documents.

EVALUATION The DBNPS corrective action program is designed to meet 10 CFR 50 Appendix B Criterion XV,

" Nonconforming Materials, Parts, or Components"; Criterion XVI, " Corrective Action"; and applicable DBNPS USAR requi.ements. The USAR Sections 17.2.15, " Nonconforming Materials, Parts, or Components", and 17.2.16, " Corrective Action", require in part that procedures be established to ensure that conditions adverse to quality are promptly identified, documented, evaluated for their signiReance, and corrected. Additionally, the USAR Quality Assurance Program requires that corrective action documents contain provisions for identifying the root cause of the condition adverse to quality, completing remedial corrective actions and corrective actions to prevent recurrence. The corrective action document requirements are then further denned in Nuclear Group (NG) procedures.

The primary corrective program at the DBNPS is implemented by proccoure NG-N A-00702," Potential Condition Adverse to Quality (FCAQ) Reporting." This process is managed by the Nuclear Assurance Department and administered in accordance with the referenced Nuclear Group procedure. The PCAQ process involves every organization at the DBNPS.

Prior to 1986, several processes existed to document conditions adverse to quality. These included nonconformance reports, deviation reports, supplier deviation reports, and stop work actions. Since 1986, the DBNPS corrective action program has shifted to a single program to document these types of nonconforming conditions, as well as potential conditions adverse to quality. Additionally, w;aknesses in the corrective action pregram effectiveness warranted Nuclear Assurance in-line review, concurrence, and close-out of all PCAQ Reports (PCAQR) and Nuclear Assurance follow-up reviews / audits of

Docket Number 50-346 License Number NPF-3 l' Serial Nun ber 2509 Attachment 2

, Page 3, completed corrective actions for all "significant" conditions. These activities utilized the Nuclear Assurance Department to control and direct the corrective action process as it matured.

Analysis of the close-out review of corrective action documents for 1997 (including significant conditions adverse to quality) indicate the number of unsatisfactory PCAQR corrective action documentation errors has decreased to less than 1% as compared to 18% in 1988 and 3% in 1995. These rejections involved only minor administrative errors and not failuees of the corrective action process.

Therefore, the Nuclear Assurance in line review efforts are now considered to be an unnecessary level of review which can be eliminated. The existing reliance on Nuclear Assurance fcr in line review, concu ence, close-out, and follow-up reviews and audits of corrective action documents will be modifi, to make line manap - nt responsible for proper corrective action administration and implemcatation. This is consi & with the requirements of 10 CFR 50 Appendix B, Criterion XVI,

" Corrective Action."

In addition, recent Nuclear Assurance audits of the corrective action program and significant conditions adverse to quality have established that the program is adequate and effective. Therefore, the specific requirement for Nuclear Assurance reviews / audits of corrective actions for all significant conditions adverse to quality is not considered necessary. Nuclear Assurance will continue to monitor the effectiveness of the nonconformance/ corrective action program, and the effect of the proposed changes, as it performs Technical Specification 6.5.2.8.c required audits of 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 six months.

While the changes are considered to be reductions to existing commitments, the DBNPS has reviewed the requiren ents of the associated 10 CFR 50 Appendix B criteria, related Regulatory Guides and Industry Standards, and determined that these will not be affected by the proposed changes. All 10 CFR 50 Appendix B nonconformance and corrective act* program requirements will continue to be satisfied by the DBNPS Nuclear Quality Assurance Program. The proposed changes remove self-imposed "non-regulatory" in-line reviews which have been determined to be unnecessary.

REFERENCES 10 CFR 50 Appendix B Criterion XV (Nonconformance) 10 CFR 50 Appendix B Criterion XVI(Corrective Action) 10 CFR 50 Appendix B Criterion XVill (Audits) 10CFR50.54(a)(Changes to the Quality Assurance Program)

TS 6.5.2.8.c (Administrative Controls)

USAR 13.4 (Review and Audit)

USAR 17.2 (Quality Assurance During the Operating Phase)

RG 1.33-11/72 and ANSI /ANS-3.2-1982 (Quality Assurance Program Requirements)

RG 1.28-2/79 and ANSI N45.2-1977 ( Quality Assurance Progran Requirements)

- RG l.144-9/80 and ANSI N45.2.12-1977 (Auditing of Quality Assurance Programs)

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