IR 05000155/1987013
| ML20214W817 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 06/08/1987 |
| From: | Choules N, Jablonski F, Tella T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214W788 | List: |
| References | |
| 50-155-87-13, NUDOCS 8706160196 | |
| Download: ML20214W817 (5) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report.No. 50-155/87013(DRS)~
Docket No. 50-155 License No. DPR-06L Licensee: Consumers Power Company 212 West Michigan Avenue Jackson,lMI 49201 Facility Name: Big Rock Point Nuclear Plant -
-Inspection At: Charlevoix, Michigan-Inspection Conducted: May 18-22,-1987 Mfm
[>- b ' 8 7 Inspectors:
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. Approved By:
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Qualit Assurance Programs Data Section
' Inspection Sumary Inspection on May 18-22, 1987 (Report No. 50-155/87013(DRS))
Areas Inspected: Special unannounced inspection by two regional inspectors of-the-licensee's QA program. The inspection was conducted in accordance with'
selected sections of inspection modules'35701, 37702, 38701, 39701, 40702 and 62702.
-Results: No violations or deviations were identified.
8706160196 870609 PDR ADOCR 05000155 G
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DETAILS
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! Persons Contacted
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Consumers Power Company-
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E1 ward,1 Plant Manager
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- R. Alexanderf Technical Engineer
- R. Buckner,-Nuclear Training Administrator
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J..Corley,-QA~ Support Section' Head, Projects-
.K. Marbaugh,-QA Support Section Head, Program Development f *L.iMonshor, QA Superintendent
- E. Raciborski,^ QA Superintendent-1*G. Withrow, Engineering and Maintenance Superintendent ~
Other. personnel were contacted,as a matter of routine during the inspection.
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'* Denotes ~those attending the. exit interview on May'22, 1987.
2.
-QA Program Review The purpose of-this inspection was to respond to concerns expressed by the senior resident inspector.about the adequacy of Nuclear 0perations Department Standards (N0DS) and associated implementing plant.
- administrative procedures (APs). required by the licensee's Quality
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-Assurance Program Topical Report (CPC-2A).
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a.
Reference Documents
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(1)' Administrative P'rocedures (APs)
- AP 1.1
" Procedures Program", Revision 2-
- APL1.12
" Request for Modification", Revision 1
- AP'3.1.1
" Plant Modifications", Revision 0
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- AP 3.1.1.1
" Facility Change, Minor", Revision 3
- AP'3.1.1.5'
" Facility Change, Major", Revision 0
- AP 3.2.1
" Maintenance Order Processing", Revision 2
- AP 3.2.4
" Preventive Maintenance", Revision 0
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- AP 4.1.1
" Records Collection and Processing",
Revision 0
- AP 4.2.4
" Procurement of Materials", Revision 1
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~*NAPP VIII-4.
" Certification of Nuclear Assurance Audit Personnel", Revision 12'
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- PM&CP 14-2
'! Drawing Production.and Revision",.
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L(2)1 Nuclear-0perations Department St'an'dards-(N005)
- A03
" Document Control", Revision 5
- A12 ~
- " Personnel Selection, Qualification,
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Certification, and CareerLDevelopment",
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Revision'9 y(
- M01'
~" Procurement Process",-Revision 6
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" Design Document Control", Revision 16
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" Control of Modifications", Revision 6
'*P12-
" Nuclear Operating Plant Maintenance Program",-Revision 13'
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?*Q01
" Corrective' Action'& Control of
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Nonconforming Items", Revision 15
- Q02
" Audit & Surveillance", Revision ?.
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- QO3-
Inspection",- Revision 15
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Background of N0DS LAs approved in 1972, the licensee's original intent was for N0DS to-include all_ regulatory requirements committed to in the Consumer's Power Topical' Report CPC-2A. N0DS were supposed to provide guidance-to preparers of implementing procedures without referring to the l regulatory guides or standards committed to in the topical report.
- In December 1984, the licensee's QA department performed an evaluation of'the effectiveness'of N0DS in conveying the requirements of the basic documents committed to in the topical report. This evaluation indicated that approximately 25%'of the requirements were inadequately addressed or not addressed at'all. The QA department
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also determined =that the Quality Assurance _ Requirement Matrix (QARM),
a cross indexing reference, had not been developed to assure
, incorporation of all committed requirements..The QARM was revised in May 1985 to include requirements of 10 CFR Appendix B, ANSI N18.7,
-and the ANSI.N45.2 series.
.In early 1986, QA personnel performed a detailed review of the
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-NODS and identified additional deficiencies.
In October 1986, the licensee initiated a plan to review, revise, and issue "high quality" F
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N0DS, and review the'QARM'accordingly. During the interim, by
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November 1986 the licensee revised Big Rock Point administrative
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procedures _'according to the standards comitted to in the topical
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report.and updated the QARM.
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.Results of' Inspection At the. time of this inspection, 26 of =27 N0DS had been drafted'and were being reviewed by the licensee. The licensee plans to issue the revised N0DS and QARM by September 1,.1987. This item is open
- pending verification that. revisions to the N0DS and QARM are -
completed. -(155/87013-01)'
The inspectors reviewed: selected APs, N0DS, and the QARM to determine if requirements of applicable ANSI standards ~ and other requirements had been incorporated. The OARM provided a useful cross reference
.of requirements to APs and N005. The QARM also listed deficiencies in APs and N0DS that were identified during a recent review by the licensee's QA department. The inspectors' general review of the.
N0DS identified several deficiencies; however, very few deficiencies.
were noted with the ' APs. -In almost every case, the -licensee's -
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QA department had identified the same deficiencies as the inspectors.
The inspectors also noted that several APs were not listed in the QARM. -QA' personnel had begun the final review of APs to ensure-that all regulatory requirements had been-incorporated. The licensee estimated that.the review, revisions, and QARM update would be completed by December 31, 1987. This matter.is open.pending-
-(155/87013-02)y the inspectors that the review is completed.
verification b The inspectors selected APs 3.1.1.1 and 3.1.1.5,.for design change control,ito determine if all pertinent. requirements had been incorporated.
The checklist for design inputs associated with AP 3.1.1.1,
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minor modifications, did not contain all the items'.in
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Section 6.3 of ANSI N45.2.11; however, it did have all necessary regulatory requirements and otherwise provided good detail.
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AP 3.1.1.5, major modification, provided little or no
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instruction to personnel for signing completed steps on an L
attached sign-off form. The procedure had a requirement for
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training, but did not require sign-off to verify that tra%ing L
had been completed.
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The weaknesses with AP 3.1.1.5 were discussed with the licensee who L
indicated that the procedure had not been used because all recent
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modifications had been minor; however, the inspector's coments f
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would be considered.
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Conclusion Based on previous inspections and the above review, it was concluded that'the N0DS did not include many regulatory or ANSI standard
. requirements; however, it appeared that the licensee had identified the deficiencies, and the upcoming revision should provide' adequate corrective action. -That action will be-reviewed by the inspectors.
There have not been any significant operating problems attributed to inadequate N0DS.
Since APs are used to implement plant activities, the' impact of inadequate N0DS on plant operations appeared to be negligible.
No violations were identified.
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Training Radiation protection, maintenance, I&C, and operations personnel had received formal training about APs because of a concern by the Resident
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' Inspector.
Engineering personnel had received informal training about APs during group meetings.
N0DS training had not been given-to anyone.
The inspectors suggested that'AP training for plant personnel should be included with the formal training program.
The inspectors also suggested that personnel responsible for preparing procedures should receive formal
, training about N0DS.
The licensee agreed to consider these suggestions.
No violations were identified.
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Open Items Open items are matters-that have been discussed with the licensee, which will be reviewed further by the inspectors,.and involves some action on-the part of the NRC, licensee or both.
Open items identified during this inspection are discussed in Paragraph 2.c.
5.
Exit Meeting The inspectors met with licensee representative (denoted-in Paragraph 1)
at the conclusion of the inspection and summarized the purpose, scope and results.
The inspectors also discussed the likely content of this-inspection report with regard to documents or processes reviewed by the inspectors.
The. licensee did not identify any such documents or processes as proprietary.
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