ML20236N039

Requests Mod of Util 821029 Plant Improvement Program Re Scope of Surveillances Because of Strong Control by Line Mgt.Sampling Techniques for Augmenting or Decreasing Scope & Routine QA Surveillance Program Will Be Used,W/Nrc Approval

ML20236N039
Person / Time
Site:	Brunswick
Issue date:	10/26/1987
From:	Richey R CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NLS-87-188, NUDOCS 8711130376
Download: ML20236N039 (3)

Text

I

.,r%

,f v) t s

r v

Carolina Power & Light Company P o. som 1551 e Raleigh, N C. 27602 OCT 26 35!

OE4.'fg FL B. RICHEY. Mana0*r Licensing & Nuclear Fuel Department SERIAL: NLS-87-188 Dr. J. Nelson Crace, Regional Administrator L

United States Nuclear Regulatory Commission l

101.Marietta Street, NW l

Atlanta, GA 30303' i

BRUNSWICK. STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS.-50L325 & 50-324/ LICENSE NOS. DPR-71 & DPR-62 l BRUNSWICK IMPROVEMENT PROGRAM

SUMMARY

On October 29, 1982, Carolina Power & Light Company submitted the Brunswick Improvement Program to the NRC.

Iri that submittal, the Company committed i.

to perform reviews in five areas described below. The Compcny has reviewed the results of these surveillance and has determined that line management has continued to exercise strong management control of these programs. Therefore, the Company believes that it is now appropriate to j

modify the scope of these surveillance.

DISCUSSION In the Brunswick Improvement Program (BIP), the Company committed to perform periodic reviews.in the following five areas:

1.

Technical Specification Surveillance (BIP Items III-1 and y

III-3) i 2.

In-Service Inspection / Appendix J (BIP Item III-1) 3.

Commitment Verification (BIP Item III-1) 4.

Technical Specification Amendments (BIP Item III-2)

I

-5.

Regulatory Requirements Changes (BIP Item III-2)

Impicmentation of these actions was assigned to the Corporate Quality I

Assurance Department and the BNP Onsite QA/QC Unit. Some of these activities were performed on a three-year cycle basis. The first three-year cycle covered the period September 1982 through August 1985; the second three-year cycle covers the period from September 1985 through August 1988. The results of these two cycles (through April 1987) have been reviewed and are summarized below:

I

l Dr. J.k

,an Grace

(

.pg;

'NLS-87-luu'/Pagsf 2

. Technical Specification Surveillance (BIP Items III-1 and 'III-3):

P Approximately 7,000_ completed surveillance test documents during the period have been' reviewed (out of a total of approximately 1,425,000-surveillance checks and -testa performed by the plant staf f.during the period). Only 10 nonconformances were identified by Quality Assurance j

and the NRC.(QA results ratio:.0.14%). Corrective actions identified i

L have been determined to be sufficient to. prevent recurrence.

l.

[

In-Service Inspection / Appendix J (BIP Item III-1):

The 'ISI/ Appendix J j

L

. program is implemented through approximately 340 procedures (covering l

[

~ approximately 2,600 valves, 43 pumps, andi3,000 component and support

'l

' examinations. : Only 15 nonconformances have been identified by the NRC i

and'QA (QA results ratio: 0.19%). None-of the identified nonconformances j

represented a programmatic problem.

Technical Specification Amendment Surveillance (BIP Item III-2): During Lthe-review period, 122 license amendments were issued.. Of these amendments, 97.affected surveillance requirements. Only two nonconformances have been identified; one'by the NRC'and one by QA. Neither of the nonconformances represented a programmatic problem..

Commitment Verification - (BIP Item III-1) : Approximately 2,000 co'mitments m

have been followed by QA during the review period. The number of j

nonconformances/ field reports identified by QA each year is as follows:

1983 -114, 1984 - 12, 1985 through 1987 - 14.

None of the nonconformances i

l identified represented a programmatic problem.

Regulatory Requirement Changes (BIP Item III-2): Since January 1983, there.have been 32 regulation' changes appropriate for QA review. No nonconformances have been identified.

CONCLUSIONS Based on the above results, the-scope of surveillance should be modified because line' management continues to perform with appropriate control of existing programs. A portion of this surveillance effort should be more appropriately directed to other areas. Therefore, the Company plans to

-adopt the following surveillance procedures:

Technical-Specification surveillance, in-service inspection / Appendix J, and commitment verification reviews will be performed using sampling techniques whereby increases and/or decreases in the scope of reviews

'will be based on the results of a given sample.

Technical' Specification amendment and regulatory requirement change

. reviews'will be performed in accordance with the Company's routine QA surveillance program.

-y ' <4W Q.,v. y

.. l

,~

(~4

.V 44 l

)

eq q Dr. J. (

on Grace f

c; t NLS-87-luti/Page 3 s'.

i' y

,1 The Company wishes to implement these revised l surveillance titograms.ap i

soon as possible. Therefore,1 you are requested to provide your conc prence

~v t'

with this action by December 1, 1987.

If.you have any questions concerning this matter, please contact I

Mr. S. R.-Zimmerman at (919) 836-6242.

( 'y Very truly yours.

-.s l \\ )

, Nj i J b &-

r

.9 R. B. Richey 1,-,

WRM/cej' (5277WRM)

Yl 1

cc:

Mr. W. H. Ruland-

' ' )1 Mr. E. D. Sylvester NRC Document Control Desk i

1 I

I l

I

-m-..-._

__.m_--.____-_._.

_2_._.__

_ _. _ _ _ _