ML20072S943

Responds to NRC Re Violations Noted in Insp Repts 50-266/91-02 & 50-301/91-02.Corrective Actions:Individual Assigned Responsibility for Initiating Escalation Process for QA Instruction (Qai) 16.2

ML20072S943
Person / Time
Site:	Point Beach
Issue date:	04/09/1991
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-91-034, CON-NRC-91-34 VPNPD-91-118, NUDOCS 9104170132
Download: ML20072S943 (2)

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i Wisconsin Elecinc POWER COMPANY A 221 M 231 w McNcort Po ik= 2046. MNosee W 53201 VPNPD-91-118 NRC-91-034 April 9, 1991 Document Control Desk U.

S. NUCLEAR REGULATORY COMMISSION Mail Station P1-137 Washington, DC 20555 Gentlemen:

DOCKET NUMBERS 50-266 AND 50-301 REPLY TO NOTICE OF VIOLATIOH REPORT NUMBERS 50-266/91002 AND 50-301/91002 POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2 On March 12, 1991, the subject inspection report and a Notice of Violation were transmitted to us.

The violation described in the notice cited a number of priority 1 and 2 Nonconformance Reports (NCRs) and Audit Finding Reports (AFRs) that "were allowed to lapse their due dates with either no or late escalation initiated."

This is contrary to the requirements of 10CFR50 Appendix B, Criteria V and the licensee escalation procedure, Quality Assurance Instruction (QAI) 16.2.

We acknowledge the failure to escalate a number of overdue items in strict adherence to QAI 16.2 due to inconsistencies in administra-tion of the procedure.

Initiation of the escalation process was the responsibility of auditors in the Quality Assurance Section (QAS) for open audit findings and Site Quality Assurance personnel for open NCRs.

The involvement of numerous individuals contributed to a variety of interpretations of the procedure and the consequent inconsistency in administration.

Furthermore, the procedure did not receive the same level of attention by everyone involved to ensure strict compliance.

We have also concluded that contributing to the problem was a lack of department-wide applicability and " ownership" of the procedure and administration of open items in general.

The procedure in place at the time of the inspection was in the form of a QAI, suggesting applicability only to the Quality Assurance Section.

After recognizing the weaknasses in the implementation of the escalation procedure several steps were taken to correct the problem.

During January 1991 a concerted effort was made to bring the escalation process up to date.

Also, a single individual in I

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Document Control Desk April 9, 1991 Page 2 QAS was assigned the responsibility for initiating the escalation process and ensuring compliance to QAI 16.2.

This consolidation of responsibility provided consistency in application of the procedure and made administration of the procedure a primary responsibility of this individual.

On April 1,

1991, a new department-wide procedure, Quality Assurance Procedure (QP) 16-6, " Delinquent Open Item Notification System," took offect.

This procedure simplifies the escalation process and clarifies applicability to all Nuclear Power Department Priority 1 & 2 open items.

In addition to the actions taken above, a departmental "open items coordinator" position has been created to help each section within the department better mcnage their commitments with respect to open items.

Better management of open items, we believe, will also help minimize the need to invoke the escalation procedure.

We believe the actions described above have been effective in resolving this matter and that we are now in full compliance with the cited requirments.

Very truly yours,

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C. W. Fay' Vice Presicent Nuclear Power Copy to:

NRC Resident Inspector NRC Regional Administrator

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