IR 05000255/1986026
| ML18052A793 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/26/1986 |
| From: | Jablonski F, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18052A791 | List: |
| References | |
| 50-255-86-26, NUDOCS 8612040029 | |
| Download: ML18052A793 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-255/86026(DRS)
Docket No. 50-255 Licensee:
Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Generating Plant Inspection At:
Covert, Michigan Inspection Conducted:
September 16-18, 23-25, 29-30, October 1-3, and 20, 1986 Inspector:
R. N. Sutphin Approved By: r:8.a~.t Quality Assurance Programs Section Inspection Summary Inspection on September 16-18, 23-25, 29-30,
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License No. DPR-20 11f~sj8'1 Date Date
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October 1-3, and 20, 1986 (Report No. 50-255/86026(DRS))
Areas Inspected:
Routine, unannounced safety inspection by one regional inspector of licensee action on previous inspection findings; quality assurance program (35701); offsite review commit.tee (40701); offsite support staff (40703); and audit program implementation (40704).
Results:
Of the five areas inspected, no violations or deviations were identified in four areas; one violation was identified in the remaining area (40704) (failure to take prompt and timely corrective action -
Paragraph 3.c.(2)(c)).
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- DETAILS Persons Contacted Consumers Power Company (CPCo)
- T. Bordine, Staff Engineer, Nuclear Licensing
- J. J. Fremean, Director, Nuclear Safety
- D. R. Hughes, Director, Quality Assurance Support
- D. Jones, Section Head, Supplier Evaluation, & **J. G. Lewis, Plant Technical Diector, Palisades
- D. G. Malone, Senior Engineer, Licensing
- R. P. Margol, Quality Assurance Administrator
- R. E. McCaleb, Quality Assurance Director, Palisades
- L. F. Monshor, Quality Assurance Superintendent, Big'Rock Point
- K. E. Osborne, Technical Engineer, Palisades Licensing
- L. T. Schuster, Section Head, Audits
- G. B. Slade, Executive Director, Nuclear Assurance
- R. A. Vincent, Plant Safety Emngineering Administrator Nuclear Regulatory Commission - Region III
- D. C. Anderson, Resident Inspector, Palisades Other personnel were contacted as a matter of routine during the inspectio *Denotes those attending the exit meeting at corporate headquarters on October 1, 198 **Denotes those attending the exit meeting at the site on October 3, 198 ***Denotes those participating in the exit telecon between NRC and the site on October 20, 198.J *. * - Licensee Action on Previous Inspection Findings (Closed) Open Item (255/84009-07):
Completion of Program for Maintenance Trendin The licensee has developed and implemented a new procedure, No. EM-20, 11 Equipment Performance Monitoring and Trending, 11 dated February 2, 198 The procedure was implemented and as of February 8, 1986, the Systems Engineers have identified some repetitive equipment failures and adjusted maintenance and testing schedules accordingl This item is close (Closed) Violation (255/84009-08):
Failure to provide technical justification for installing nonconforming materia Items that-are deficient are identified as nonconforming and use is controlled by a Nonconforming Material Report (NMR).
If the item is installed
prior to the closeout of the NMR, it is further controlled by the issuance of a (CMR) Conditional Material Releas Both the NMR and CMR require the items to be tagge Prior to placing reliance on a safety-related item, all NMRs and CMRs associated with the item must be closed ou In accordance with ANSI N45.2.2-1972, the technical justification required to close out the NMR is also considered the technical justification to close out the CM In accordance with the NRC's concern in this area the licensee has modified their procedures to add the following for an item to be conditionally released for installation:
(1) the item is likely to be acceptable; (2) the item will not need rework or repair after installation; (3) the item is not consumable (e.g. chemicals, weld rods, resins, etc.); and (4) there must be a means, such as a caution tag, to assure the item is not declared operabl The inspector has no further concerns in this area at this tim This item is close (Closed) Violation (255/84009-10):
Failure to include adequate technical requirements in procurement document The licensee corrected the information about the technical requirements of the motor, which established the basis for this finding, and established an ongoing policy to review, in greater detail, the addition of technical requirements for procurement document Authorizations to purchase and purchase requisitions are now reviewed fo~ technical requirements to preclude a repetition of this proble This item is close ;J,.*. (Closed) Unresolved Item (255/84009-15):
Licensee to include Q-List interpretation status on equipment databas The licensee revised administrative procedures to streamline the retrieval of Q-List interpretations from the equipment databas The backlog of items that was unclassified has been reduced to less than 10 Over 7000 items have been reviewed by the study group and Quality Assuranc This item is close (Closed) Unresolved Item (255/85017-01):
Improvements needed in the Quality Trend Progra The licensee issued monthly trend reports for the past eight month A review of the reports indicated a continued improvement in the type and quality of the Trend Program data and graphs. Additional planned improvements were discussed with the license The inspector has no further question regarding improvements in the Trend Progra This item is close (Closed) Unresolved Item (255/85017-02):
Completion of Procedure for Safety. Evaluatio Palisades Nuclear Plant Administrative Procedure No. 3.07, Title:
11Safety Evaluations, 11 was completed and issued as Revision 0 on July 23, 198 The contents of the procedure adequately address the requirements and methods for conducting 10 CFR 50.59 Safety Evaluation This item is closed.
- Quality Assurance Program Annual Review (35701)
This inspection was conducted to verify that personnel responsible for the development of implementing procedures for changes to the licensee's Quality Assurance (QA) program were familiar with the changes or revisions; that the revised implementing procedures were in conformance with the changes described in the docketed QA program; and that the licensee had implemented a QA program that was in conformance with regulatory requirements, commitments, industry guides, and standard The inspection was performed by reviewing applicable procedures and records, conducting personnel interviews, and observing work activities in the areas of offsite safety review committee, offsite support staff and design interface, and audit program implementatio Results of the inspection are as follows: Offsite Review Committee (40701)
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Inspection of the offsite review committee was performed to verify activities were conducted in accordance wfth Technical Specifications
{TS) and other regulatory requirement (1) Reference Documents (a) Topical Report, CPC-2A, "Quality Assurance Program Description for Operational Nuclear Power Plants, 11 Revisions 3, 4, and fiv *
{b)
Palisades Technical Specifications, Section 6.0,
"Administrative Controls."
(c) Palisades Technical Specification Figure 6.2-1,
"Consumers Power Company - Offsite Organization,"
Amendment 75, January 28, 198 {d)
Nuclear Operations Department Standards {NODS):
0
NODS-AOl, "Preparation and Control of Nuclear Operations Department Standards," Revision 1 NODS-P0-8, "Control of Modifications," Revision 1 NODS-All, "Management Overview," Revision 1 (e) Nuclear Assurance Department Procedures (NADP):
0 NADP-V-1, 11 NADP Development, Review, Approval, and Revisions," Revision 1 NADP-V-3, "Review and Revision of NODS and CPC-2A, 11 Revision 4.
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NADP-I-2, "Nuclear Safety Board (NSB) Organization, 11 Revision NADP-XVI-1, "Corrective Action Followup and Trend Analysis, 11 Revision 1 NADP-XVI-4, "Reporting, Evaluation, and Correcting'
Conditions Adverse to Quality, 11 Revision " NADP-XIX-2, "Plant Safety Engineering Assessment Program, 11 Revision NADP-XIX-6, "Plant Safety Engineering (PSE) Support of NSB, 11 Revision NADP-XX-1, "Nuclear Safety Board (NSB) Issues, Meetings and Assignments,".Revision NADP Form 1901, "Palisades Plant Trip/Transient Assessment, Lead Assessor Certification."
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(fj CPCO QA Semi-Annual Review Meeting Minutes, November 18, 1985, and May 22, 198 (g)
Resume of Eight Current NSB Member (h) Nuclear Safety Board (NSB) Organization Chart - NSB Membership Qualifications, June 1, 198 (i) Nuclear Safety Board Membership, September 5 and November 27, 1984, and May 31, 198 (j) Organization Chart F-2, "Nuclear Assurance, 11 Revision of March 198 (k)
CPCO Letter of August 5, 1985, to Director NR (l) Audit Reports QT-85-25and QT-86-0 (m)
NSB Meeting Minutes:
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Preliminary Meeting Minutes, 4th Quarter 1985, 1st and 2nd Quarters 198 NSB Meeting Minutes, 4th Quarter 1985, and 1st Quarter 198 Special NSB Meeting, February 18, 198 (n)
Plant Safety Engineering (PSE) Report to the NSB, Second.
Quarter 1986, dated June 30, 198 *
(2) Results of Inspection (a) The inspector reviewed changes to Topical Report CPC-2A and checked various implementing procedures for accommodation of the change In one case related to design control and design verifications, Section 3.2.9.(3)a of CPC-2A,
Revision 5, was revised to state that the designer's immediate supervisor may perform the verification, provided his review was "(a) approved in advance by the supervisor's management, with documentation of the approval included in the design package, or (b) controlled by a procedure approved by the Nuclear Assurance Departmen Such procedures shall provide specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the
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supervisor performed the design.verification."
The inspector determined that additional revisions were necessary to implement all the details of the changes made to this Section of CPC-2 Pending completion of the required changes in the implementing procedures this is considered an open item (255/86026-001).
(b) Technical Specification 6.5.2.3 requires members of the Nuclear Safety Board (NSB) to be competent and conduct reviews in certain specified area NSB members may possess expertise in more than one of the 5pecified specialities. The individuals should, in general, have had professional experience in their specialty at or above the Senior Engineer leve The NSB Organization Chart listed "NSB Membership Qualifications, the members by name, and areas of technical specialty. The inspector reviewed resumes of the members to verify that the assigned individuals had appropriate professional experience and qualifications to conduct the required safety review The information reviewed by the inspector was not adequate to establish the basis for selections of the NSB member The licensee is reviewing this matter and will provide a more appropriate technical basis for the selections and coverage of the technical and specialty areas of safety revie This is considered an unresolved ite (155/86026-002).
. (c)
The inspector determined that a significant number of the technical reviews and evaluations required of *the NSB were assigned to the Plant Safety Engineering (PSE) staf PSE was established to meet post TMI Independent Safety Engineering Group (ISEG) requirements; however, it was intended that ISEG personnel would provide some assistance to the NS At the time of the inspection the ISEG was
- understaffed by one person and was performing nearly 100%
of the reviews for the NS During the inspection an additional person was added to the ISEG staff. The ISEG may not be able to accomplish independent safety engineering responsibilities if overloaded with work assignments by the NS During the inspection a backlog of ISEG work was note (d) The licensee has proposed a change in the Technical Specification. The change will downgrade the management level of the Chairmanship of the NS The previous chairman was established by the Technical Specification at one management level higher than the proposed amendmen This change may have an impact on the ability of the NSB members to conduct their independent evaluations and
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review This is considered an open item (255/86026-0o'3).
No violations or deviations were identified; however, one item was unresolve Offsite Support Staff (40703)
The offsite support staff organization, management functions, and administrative controls which describe the responsibilities, authority and lines of communication for personnel performing offsite support functions in design, technical support, quality assurance, construction/modification, procurement, safety, and operating interfaces were inspected for compliance with technical specifications, commitments, industry guides and standard (1) Reference Documents (a)
(b)
(c)
(d)
(e)
Topical Report, CPC-2A, "Quality Assurance Program Description for Operational Nuclear Power Plants.
Palisades Technical Specifications, Section 6.0,
"Administrative Controls."
Palisades Technical Specification Figure 6.2-1,
"Consumers Power Company - Offsite Organization," *
Amendment 7 Palisades Technical Specification, Figure 6.2-1,
"Consumers Power Company - Offsite Organization, Proposed Amendment. 11 Nuclear Operations Department Standard, NODS-A-01,
"Preparation and Control of Nuclear Operations Department Standards, 11 Revision 12.
(f) Nuclear Operations Department Standard, NODS-A-17,
"Management Overview, 11 Revision 1 *
(g) Nuclear Assurance Department Procedure, NADP-XIX-2, 11Plant Safety Engineering Assessment Program, 11 Revision (h) Nuclear Assurance Department Procedure, NADP-XIX-6, 11 PSE Support of NSB, 11 Revision (i)
NADP Form 1901-5/85, "Palisades Plant Trip/Trahsient Assessment Lead Assessor Certificatio (j)
CPCO Memo to File, November 5, 1985, subject:
Simulator Training Session for PSE Transient Assessor ( k)
CPCO Form 3128 7/85, "Palisades Nuclear Plant - Design Review Checklist - Minor Modifications. 11
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(1)
CPCO QA Semi-Annual Review Meeti~g Minutes, May 28, 198 (2) Results of Inspection (a) The Consumers Power Company offsite organization commitments for the suppor*t of the Palisades Nuclear Generating Plant were included in the Technical Specifications (TS) and shown on TS Figure 6.2-The current NRR approved organization chart (Figure 6.2-1) is included in Amendment No. 75, dated January 28, 198 In November 1984 a change in the organization chart, which would eliminate the position of 11Director of Quality Assurance, 11 was proposed to the NS This proposal was reviewed and accepted by the NSB and submitted to NRR on January 11, 1985, as an amendment to the TS and FSA The proposed change would eliminate the position of Director of Quality Assurance, change the title of Executive Director, Nuclear Activities to Executive Director, Nuclear Assurance, and combine both functions under the position of Executive Director, Nuclear Assuranc This change was implemented/announced November 1, 198 On February 15, 1985 the 1 i cen see revised their Quality Assurance Program Topical Report, CPC-2A, to include this organization chang The Topical Report, Revision 3 of February 15, 1985, was submitted to Region III for review and acceptance, per 10 CFR 50.54(a), on April 30, 198 This Revision was accepted by Region III on June 14, 198 Region III accepted the revision because the Quality Assurance function was operating essentially as before, offsite and independent of plant management, and there was no reason or basis that NRR would not approve the amendment to the T NRR advised Region III that there was no problem with the change; however, at the time of this inspection, approximately 19 months* l*ater, the amendment had not been approve On September 29, 1986,
- the licensee resubmitted a request to NRR to accept the organization change amendment to the T Pending approval by NRR of this organization change amendment this is considered an unresolved item (255/86026-004).
(b)
In the areas of design, engineering, and construction offsite support to the nuclear operations, the licensee has established a Vice President Energy Supply Service at the same level as the Vice President Nuclear Operati6ns, both reporting to the Executive Vice President Energy Suppl The Executive Manager Projects, Engineering, and Construction reports to the Vice President Energy Supply Service This provides a closer. working relationship with the Nuclear Department than existed previously, as offsite suppor * (c)
ANSI N18.7-1976, in Paragraph 5.1, 11Program Description,'i*-
requires that the licensee compile a summary document to identify the source documents such as administrative controls, operating procedures, maintenance procedures, and quality assurance procedures; to index such source documents to the requirements of the quality assurance program for the operational phase; and to provide a consolidated base for description of the progra The licensee had previously developed a matrix, oriented to the requirements of ANSI Nl8.7, to satisfy this requirement; however, a matrix of the same caliber did not exist to index all the requirements and commitments in Topical Report CPC-2 The licensee has initiated development of such a matrix for CPC-2A and expects to have it completed by September 198 Pending completion of this matrix and review by the inspector, this is an open item (255/86026-005).
No violations or deviations were identified; however, one item was unresolve Audit Program Implementation (47074)
Implementation of licensee's audit program was inspected to verify that qualified audit personnel had conducted routine audits to ensure that activities were in conformance with regulatory requirements, commitments, and industry guides and standards..
(1) Reference Documents (a) Topical.Report, CPC-2A, "Quality Assurance Program Description for Operational Nuclear Power Plants",:
Revision (b) Nuclear Operations Department Standard, NODS-Q02, "Audits.
and Surveil l ance 11, Revision 1 (c)
Nuclear Assurance Department Procedures (NADP):
NADP-XVIII-1, 11Audits 11, Revision 1 NADP-XVIII-4, "Certification of Nuclear Assurance Audit Personnel", Revision 1 NADP-XVI-1, "Corrective Action Follow-up and Trend Analysis.
(d) Auditor/Lead Auditor Qualification Record (e) Glossary - Nuclear Assurance Department Procedure (f) Consumers Power Company NAO Internal Audit Plans, dated March 30, and-September 30, 198 '***.
(g) Audit Reports QT-85-25, QT-86-05; QT-86-08, and QT-86-1 (h) Audit Checklist for Audit No. QT-86-2 (i) Audit Exit Meeting Synopsis for Audit No. QT-86-2 (j) Computer Print-Out:
Corrective Action System, Audit Related Corrective Action Documents, September 17, 198 (k)
Status Guidelines for Corrective Action (1)
Corrective Action Status; Semi-Annual QA Meeting, May 14, 198 (m)
Technical Specification, Section 6.5.2.8.2, Audits, Amendment 8 (2) Results of Inspection (a) The inspector witnessed part of an audit conducted by QA personnel (Audit No. QT-86-20), reviewed the checklist and exit meeting synopsis, and observed the exit meeting conducted by the lead audito The audit subject was Palisades Plant Chemistr In addition to good programmatic compliance the audit included a
"Vertical Slice" (VS) concept originated by the license The Vertical Slice included an expanded approach to sampl~
hardware associated with the area being audite In this case it was the T-102 Iodine Removal Syste This VS concept included a look at equipment, documents, logs, physical condition, deficiency reports, maintenance work, TS compliance, interrelations between departments,
- problems, controllers, instruments, valves, system engineering support, and management control The records and certifications of the auditors in this audit were reiiewed and found to be in accordance with requirement (b) The inspector reviewed the licensee's long range audit schedules and several audit reports; all were in compliance with program commitments and requirement The audits effectively identified problem areas and, when appropriate, corrective actions were initiated and corrective action trend reports were generate (c) The inspector reviewed results of the corrective action system, trend reports, Action Item Request (AIR) status,
.Deficiency Report (DR) status, and Event Report (ER)
statu The inspector determined that several items have remained open for a substantial period of tim They were:
ITEM MONTHS OPEN SUBJECT D-QG-83-106
Deficiencies in Maintenance order documentatio D-QG-84-92
Dosimeter Certification Records not transmitted to DCC within time limi D-QG-84-123
Training matrices for Maintenance and.Chem/HP departments do not delineate required trainin Admin. Dept. does not have training matri D-QG-84-119
Fire Brigade training program maintained by prop. prot. instead of Plt Training Coordinator as per procedur D-QG-85-1
Deficiency in listing of valves on TS Surv. Test Procedure EM-98-0 D-QG-85-18
NMRs not generated for onsite repair of installed plant equipmen Files indicate lack of documentatio D-QG-85-24
11 Lack of Software QA plans for Palisades Software as required in Admi n. Proc. 10.. 11, Sections 4.2. and 5.2.
- D-QG-85-35 D-QG-85-348 D-QG-85-33A D-QG-85-48 D-QG-85-60 D-QG-85-64 D-QG-85-68 D-QG-85-70 D-QG-85-77 D-QG-85-71
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- 10 EEQ Equipment lacks maintenance and surveillance progra Prepare Microfiche copies of completed EE Review files to insure information has been microfilmed and properly indexe Write Administrative Procedure to control content and format for EEQ qualification documentatio Use of 11 NQ 11 Chemical Analysis for upgrading consumable The breakers in MCCS 21, 22; 23*~
and 24.are locked ope Chemistry Program Manual, Plant Administrative Procedures, and Chemistry Department procedures have not been implemente Procedures are knowingly not being followe Personnel lacking training called for in department matrices as required by Admin. 11.00, Revision Violation of NODS-A0 Requirement violation of NODS A-12, Revision *This item was signed off during the NRC inspection, on September 30, 198 Several other items, requ1r1ng corrective action, were open from one to nine months, one of which was signed off during the NRC inspectio CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and correcte The status of the above listed
- items indicates that the licensee has not taken prompt and timely corrective action to resolve the issue This is considered a violation of 10 CFR 50, Appendix B, Criterion XVI (255/86026-006). Unresolved Items Unresolved items are matters about which more information is *required in order to ascertain whether they are acceptable items, violations or deviation Unresolved items disclosed during the inspection are discussed in Paragraphs 3.a.(2)(b) and 3.b.(2)(a). Open Items Open items are matters that have been discussed with the licensee, wi 11 be reviewed further by the inspector, and i nvo 1 ve same action on the part of the NRC or licensee or bot Open items disclosed
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during the inspection are discussed in Paragrapns 3.a.(2)(a), 3.a.(2)(d),
and 3.b.(2)(c). Exit Interview The inspector met with licensee representatives at their General Office on October 1, 1986, at the site on October 3, 1986, and by telecon on October 20, 1986; and summarized the purpose, scope, and findings of the inspectio The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any documents, processes, or information as proprietary.