IR 05000255/1991201
| ML18057B382 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/05/1991 |
| From: | Boger B Office of Nuclear Reactor Regulation |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18057B383 | List: |
| References | |
| NUDOCS 9111220236 | |
| Download: ML18057B382 (31) | |
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Docket No. 50-255 Consumers Power Company ATTN:
Gerald General Manager UNITED ST ATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 NOV 0 5 7991 Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043
Dear Mr. Slade:
SUBJECT:
ASSESSMENT OF THE PROCUREMENT AND COMMERCIAL-GRADE DEDICATION PROGRAMS AT THE PALISADES NUCLEAR GENERATING PLANT, REPORT NO. 50-255/91-201
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~:f This letter transmits the report of the assessment conducted May 13 through s*
May 17, 1991, at the Consumers Power Company's (CPC's) Palisades Nuclear f
Generating Plant, by R. L. Pettis, S. 0. Alexander, L. L. Campbell, and B. Rogers of the U. S. Nuclear Regulatory Commission's (NRC's) Vendor Inspection Branch and R. Langstaff and P. Rescheske of NRC Region III. At the conclusion of the assessment, we discussed our findings with your staff as identified in the appendix of the enclosed report.
The staff performed the assessment to review CPC's program for the procurement and dedication of commercial-grade items used in safety-related applications in accordance with the requirements of Appendix B to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR Part 50) and to also determine the extent to which the licensee had implemented the initiatives of the Nuclear Management and Resources Council (NUMARC) in this area.
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The.NRC assessment team concluded that CPC has not made a significant effort to strengthen its commercial-grade dedication program.
The overall program description d-1:4.:c:n_ot appear consistent with the dedication philosophy described in Electric R~:@r: Research Institute (EPRI) Report NP-5652, "Guideline for the Utilization o~f~ommercial Grade Items in Nuclear Safety Related Applications (NCIG-07)," a*s* endorsed by NRC Generic Letter (GL) 89-02, "Actions to Improve the Detection of Counterfeit and Fraudulently Marketed Products," March 21, 1989.
The team also noted that the program description, including most of the pertinent implementing procedures, did not completely address the issues contained in GL 89-02, which specified certain restrictions or conditions concerning the use of EPRI NP-5652 dedication methods as ac*ceptable methods to achieve compliance
. with.. Appendix B._ If_ the program is properly modified, and implemented to.address these issues, it could provide adequate control over the commercial-grade procurement process. Specific strengths and weaknesses are discussed in detail in the enclos~d report.
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Consumers Power Company Gerald At the time of the assessment, CPC was conducting a self-assessment to review the comprehensive procurement initiative improvements suggested in NUMARC 90-13, 11Nuclear Procurement Program Improvements.
The initiative called for the licensee to complete its review by July 1, 1991, and_ to complete implementation by July 1, 1992. Although CPC could not provide documentation during the assessment to support its progress in this area, CPC management stated that_ it would meet these goals.
The assessment team identified weaknesses both in the overall procurement program and its implementation.
In severa_l internal.qua 1 ity assurance (QA)
audits performed since 1989, CPC had identifed concerns similar to those raised by the assessment team.
Despite CPC's procedural revisions to incorporate the philosophy described in EPRI NP-5652, and in response to internal QA audit findings, the program was not substantially improved to correct the fundamental cause of those findings and to align the program with regulatory requirements.
CPC believed that not all the critical characteristics identified needed to be verified, but only those necessary to demonstrate that the item received was,
the item specified. While this position may be consistent with the EPRI _
NP-5652 definition of critical characteristics, we interpret the 11 item specified" to encompass attributes necessary for performance of the item's safety functions.
Generic Letter 91-05, 11Licensee Corrunercial-Grade Procurement and Dedication Programs, 11 April 9, 1991, states that the licensee is responsible for identifying these attributes, establishing acceptance criteria and providing reasonable assurance of conformance to these criteria. The assessment.team also noted that for the majority of dedications performed, procedures did not require that CPC identify and document the safety function and criti ca 1 characteristics-of the item.
In accordance with 10 CFR 2.790(a), the staff will place a copy of this letter and the enclosures in the NRC Public Document Room.
Although no response is required to this report, we expect you to consider the concerns raised herein.- If you have-any questions concerning th-is assessment,-
we will be pleased to discuss them with you.
Thank you for cooperating in this assessment process.
Enclosure:
Assessment Report 50-255/91-201
Sincerely, Bruce A. Boger, Director Division of Reactor Projects III, IV, V Offi_~~ of N_!.i<;lear:, React.pr ReguJation
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Consumers Power Company Gerald
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