U-602398, Forwards Changes to Plant QA Program Consisting of Revise Plant Commitment to Reg Guide 1.33,Rev 2 QA Program Requirements (Operations) & Revise Plant Commitment to Reg Guide 1.144,Rev 1 Auditing of QA Programs for Nuclear..

Forwards Changes to Plant QA Program Consisting of Revise Plant Commitment to Reg Guide 1.33,Rev 2 QA Program Requirements (Operations) & Revise Plant Commitment to Reg Guide 1.144,Rev 1 Auditing of QA Programs for Nuclear..

ML20080J333
Person / Time
Site:	Clinton
Issue date:	02/17/1995
From:	Phares R ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.033, RTR-REGGD-01.144, RTR-REGGD-1.033, RTR-REGGD-1.144 U-602398, NUDOCS 9502270271
Download: ML20080J333 (5)

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!!hnois Power Company Chnton Power Stabon P.o. Box 678

.,. Chnton. IL 61727 Tel 217 935-8881 l

P4WWER U-602398 L30-95(02-17 )IE 1A.120 February 17, 1995 Docket No. 50-461 10CFR50.54(a)(3)

Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555 i

Subject:

Quality Assurance Program Revision Clinton Power Station

Dear Sir:

Attached for your review and a proval are two cha ,, to the Clinton Power

' Station (CPS) quality assurance (QA) p gram consisting of the following:

Revise CPS commitment to Regulatory Guide 1.33, Revision 2 (February 1978),

" Quality Assurance Program Requirements (Operations)," to perform audits in selected areas on the same frequency as stated in American National Standards

' Institute (ANSI) Standard N18.7-1976.

Revise CPS commitment to Regulatory Guide 1.144, Revision 1 (September 1980), " Auditing of Quality Assurance Programs for Nuclear Power Plants," to allow the auditing organization to dr. ermine which program deficiencies or nonconformances require root cause evaluation and follow-up by the auditing i organization.

The purpose of these changes is to utilize audit resources in the most effective manner, Both changes have been determined to be reductions in quality assurance program commitments, therefore, require NRC review and approval prior to implementation.

Illinois Power (IP) intends to implement these changes within 60 days in accordance with 2700m 9502270271 950217 '

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U-602398 Page 2 a

10CFR50.54(aX3Xiv). IP has evaluated the changes to the CPS QA progtrg and has concluded that the revisions to the CPS QA program continue to satisfy the requirements of 10CFR50, Appendix B.

Sincerely yours, N.S. 30h-Richard F Ph es Director, Licensing JLP/csm -

Attachment:

Summary of Changes and Justification 1

cc: NRC Clinton Licensing Project Manager )

NRC Resident Office, V-690 1 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety I

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ito U-602398 Page1of3-Changes to the Clinton Power Station

. Quality Assurance Program r

Summary of Cha_nges and Justification J

l. Revise CPS commitme'nt to Regulatory Guide 1.33, Revision 2 (February 1978), ]

." Quality Assurance Program Requirements (Operations)," to perform audits on the same frequency as stated in American National Standards Institute (ANSI)

Standard N18.7-1976.

Background:

In accordance with the CPS Updated Safety Analysis Report (USAR), CPS currently -

complies with Regulatory Guide 1.33, Position C.4, which endorses ANSI Standard N18.7-1976, Section 4.5, " Audit Program," by stating that " audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their -

safety significance and in such a manner as to ensure that audits of all safety-related functions are completed within a period of 2 years." Regulatory Positions C.4.a, C.4.b, C.4.c specify more frequent audits for selected program elements. The CPS Technical

Specifications previously contained audit requirements and frequencies; however, with the implementation of the Improved Technical Specifications, the audit requirements and frequencies were relocated to the Operational Requirements Manual (ORM) Section 6,5.2.8. The proposed changes to the ORM consist of the following

a. Revise the frequency from 6 months to 12 months for audits encompassing the results of actions taken to correct deficiencies occurring in unit equipment, stmetures, systems, or method of operation that affect nuclear safety,

b. Revise the frequency from 12 months to 24 months for audits encompassing the conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions.

c. Revise the frequency from 12 months to 24 months for audits encompassing the performance, training and qualifications of the entire unit staff.

The above changes will allow CPS to schedule audits based upon the current 18-month fuel cycle rather than on the annual or semi annual basis as performed currently. The CPS

'USAR and the ORM will be revised to reflect CPS revised commitment to Regulatory Guide 1.33.

Attachment

, to U-602398 Page 2 of 3 Justification:

The current audit program requirements consume resources for auditing areas having fewer problems that would be better spent in monitoring and assessing weak areas or areas ofdeclining performance. The proposed changes would allow CPS to schedule audits to )

better match plant activities. This would result in more meaningful results and would allow more flexibility in scheduling audits. The audits required by ANSI N18.7-1976 would generally be scheduled on a two-year basis, but the intent is to schedule the audits to follow the 18-month fuel cycle. Audit attention may be increased if the organization or program shows a declining level of performance as indicated by trend reports or as directed by management. This change will not result in a reduction of the overall effectiveness of the quality assurance program at CPS and will continue to meet 10CFR50, Appendix B.

2. Revise CPS commitment to Regulatory Guide 1.144, Revision 1 (September 1980), " Auditing of Quality Assurance Program for Nuclear Power Plants," to allow th auditing organization to determine which program deficiencies or

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noncomormances require root cause evaluation and follow-up by the auditing organizatte.

Background:

In accordance with the CPS USAR, CPS currently complies with Regulatory Guide 1.144, which endorses ANSI Standard N45.2.121977, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants." The current practice for processing audit fmdings identified by the auditing organization requires the management of the audited organization to perform root cause analysis, to take corrective action and actions to prevent recurrence prior to submitting the audit finding for closure. The CPS Nuclear Assessment (NA) department performs a verification ofimplementation of remedial actions and actions to prevent recurrence ' prior to closure. NA also approves corrective actions to remedy the deficiency. The proposed change will enable the auditing organization to determine which program deficiencies or nonconformances (based upon significance) require root cause evaluation and/or follow-up by the auditing organization.

Corrective action implementation for deficiencies or nonconformances oflower significance is verified through the site corrective action program and the normal audit and surveillance process. (Reference ANSI N45.2.12 Sections 4.3.2, Audit Process, and 4.5, Follow-up).

The CPS USAR will be revised to reflect the above change.

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' Page 3 of 3 Aistification:

Conditions adverse to quality are currently reported and processed in accordance with a common corrective action system used by all departments at CPS. Processing of -

conditions adverse to quality (findings) identified during the audit process, that are

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' determined to be'significant, will not be changed. However, findings oflow significance (based on nuclear safety, radiological safety, regulatory considerations or other factors as deemed by the auditing organization) may require remedial corrective actions only (i.e., no root cause or action to prevent recurrence). For these findings, the plant trending -

program and periodic re-audits willidentify declining trends and the need for additional actions. The current program expends resources on verification activities in areas oflow significance. The proposed change will allow resources to be used on other assessment activities in areas having more significance and maximize the effectiveness of the audit program. The proposed change will not result in a reduction of the overall effectiveness-of the quality assurance program at CPS and will continue to meet 10CFR50, Appendix B.

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