ML18043A566

Responds to Violations Noted in IE Insp Rept 50-255/78-30. Corrective Actions:Tech Spec Changes Will Be Requested & Obtained Prior to Making Changes;Procedure Requiring Annual Reviews of Training Records Will Be Developed

ML18043A566
Person / Time
Site:	Palisades
Issue date:	02/15/1979
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML18043A562	List: ML18043A566
References
NUDOCS 7903230337
Download: ML18043A566 (5)

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consumers Power company General Off}~e*: ~2 We*t twllchlgan Avenue, jackaon, Michigan 4QOOI

• Area Cocse 1517 788-01550 February 15, 1979 Mr James G Keppler Off ice of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT ~ PERFORMANCE APPRAISAL TEAM INSPECTION - IE INSPECTION REPORT 78-30 0 Consumers Power Company's response to the alleged'items of noncompliance identified in IE Inspection Report 78-30 is as follows:

Item A - Deficiency Technical Specification 6.2.2, "Plant Staff," states in part: "The Plant organization shall be as shown on Figure 6.2-2 .... " Technical Specification Figure 6.2-2 shows the Training Coordinator reporting to the Operations Superintendent and the I&C Engineer/Supervisor reporting to the Maintenance Superintendent.

Contrary to the above:

1. The Training CoolV,inator has reported to the Generating Plant 2::* *.The Superintendent-?fuclear since June 1978.

I&C Engineer/Supervisor has reported to the Senior Engineer-Electrical since at least May 1978.

Response

Corrective Action Taken and Results Achieved Since it was desired that the actual plant organization remain unchanged, a Technical Specification change was requested to update the Plant Organization Chart - Figure 6.2-2. Amendment 46 to the Palisades Operating License, updating Figure 6.2-2 was granted by the NRC on January 19, 1979.

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Corrective Action To Be Taken To Avoid Further Noncompliance In ~e future, Technical Specifications changes will be requested and obtained prior to making plant organizational changes. The recent amendment to our operatin.g license allows more flexibility in plant organization than we originally had, such that this type of incident is not likely to occur again.

Date When Full Compliance Will Be Achieved Full compliance was achieved as of January 19, 1979.

Item B - Deficiency Title 10, Chapter I, Code of Federal Regulations, Part SO, Appendix B, Criterion II, "Quality Assurance Program" requires in part: " *** The program shall provide for indoctrination and training of personnel .*. " and

" .*. Management of other organizations participating in the Quality Assurance Program shall regularly review the status and adequacy of that part of the Quality Assurance Program which they are executing." Consumers Power Company Quality Assurance Program Manual for Nuclear Power Plants, Policy 2, Section 3.4, "Training of Personnel," states in part: ' 1 *** Records are maintained for each trained Consllmers Power Company employee and are reviewed on a periodic basis to assure completeness and determine requirements.for continuing training." Palisades Nuclear Plant Administrative Procedure 13.3, "Departmental Employee Training," Revision 3, dated May 2, 1977, Section 5.5, "Program Evaluation," requires in part: " .*. PersoD:nel participation and lesson plans shall be reviewed at least annually by the responsible individuals."

Contrary to the above, as of December 1, 1978, the required annual review of Maintenance Department personnel training records had not been performed.

Corrective Action Taken and Results Achieved A review of Maintenance Department personnel training records is in progress and will be completed by February 28, 1979.

Corrective Action To Be Taken To Prevent Further Noncompliance

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A 4raft procedure i~q'u.iring the plant's *Training Department to conduct annual re~iews of training records has been developed and is under review. This pro'cedure will provide for documentation of training record review completion ob an annual basis to the Production & Transmission Department Training Administrator. This procedure is expected to be implemented by April 15, 1979.

Date When Full Compliance Will Be Achieved Full compliance with regard to reviewing{faintenance Department personnel training records will be achieved by February 28, 1979 .

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• Item C - Deficiency Technical Specification 6.5.2 requires that the Safety and Audit Review Board (SARB) responsibilities and authority be in accordance with the Technical Specific~tions and ANSI NlS.7-1972. Section 4.2.1 of ANSI NlS.7-1972 requires that the off-site committee charter shall contain (1) the subjects to be reviewed and audited, (2) the mechanism for initiating audit activities, (3) the identification of--the management positions to whi*ch reviewers and auditors _

report, and (4) provisions for assuring that personnel responsible for review and audit are ~ept informed on a timely basis of matters within their scope'of responsibility. TS 6.5.2.8 requires a technical audit of the Facility Fire Protection Program and implementing procedures every two years*and TS 6.5.2.7 requires that SARB review technical audit reports ..

Contrary to the above, the SARB Charter (Production & Transmission Department Procedures 19-51) did not contain a requirement to review the reports of the technical audits of the Fire Protection Program and its implementing procedures. The charter also failed to address the other requirements listed above.

Response

Consumers Power Company concludes that the items identified above (Item C) are not deficiencies for the following reasons:

( General Consumers Power Company's off-site review and audit functions are conducted separately. We conclude that this relationship may not have been adequately explained to the PAT inspector during his visit. To clarify this relationship, we note the following:

a. Section 4.1 of ANSI N-18.7-1972 clearly states that "This standard does not specify an organizational structure for meeting the review and audit functions ..*. "

b. SARB serves a review fun.ction as stated in Technical Specification 6. 5. 2. 1 and is not responsible for the specific conduct of audits. Therefore, the SARB Charter need\bnly address review responsibility .

c.:: Technical Specifit:ation 6.5.2.8 states that "Technical audits are the

• responsibility of the Operating Services Department and shall be reviewed by SARB." Therefore, OSD procedures contain the specific requirements regarding conduct of technical audits. In addition, QA audits are performed by QA personnel and the conduct of these audits is contained in the Quality Assurance Program Procedures (QAPPs).

d. We interpret the term "Written Charter" as used in Section 4.2.1 of ANSI NlB.7-1972 to be the SARB Charter and other written Company procedures necessary to meet the requirements of".ANSI NlB.7-1972 .

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• Specific Sub Item 1 - The SARB Charter did not contain a requirement to review the reports of the technical audits of the Fire Protection Program and its implementing procedures.

Response

Section 5.3.1.7 of the SARB Charter states in part: "SARB shall have the responsibility to review .*. Technical Audit reports .

including audits of": We conclude that this is a requirement to review the technical -audits of the Fire ~rotection Program and its implementing procedures as well as other technical audits specifically listed in Section 5.3.1.7.

Sub Item 2 - The SARB Charter shall contain the mechanism for initiating audit activities.

Response

SARB does not perform audits, therefore, the SARB Charter does not ..contain a mechanism for initiating audits.

The Operating Services Department Procedure OSD-26 contains the 0

• -mechanism for initiating technical audits. Quality Assurance Program Procedure (QAPP) 18-51 conta1ns the mechanism for initiating QA audits.

Sub Item 3 - The SARB Charter shall identify the management positions to which reviewers and auditors report.

Response

The identification of the management position to which "reviewers" report is contained in Section 5.4.1 of the SARB Charter.

The ideneiification of the management position to which "auditors" report ik.denoted in Sections 5.4.3 and 5.6 of Procedure OSD-26 for tecP.nical audits and Section 5.4 of QAPP-18-51 for QA audits.

S~b **Item 4 - The SARB Charter shall contain provisions for assuring that personnel responsible for review and audit are kept informed on a timely basis of matters within their scope of responsibility.

Response

Personnel responsible for review are kept informed on/a timely basis in accordance with Section 5.3 of the SARB Charter.

Personnel responsible for technical audits are kept informed on a

• timely basis in accordance with Sections 5.0 and 5.1 of Procedure

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• OSD-26. Personnel responsible for QA audits are.kept informed on a timely basis in accordance with Section 5.1.1 of QAPP-18-51.

In addition, we conclude that our program of utilizing auditors knowledgeable in the technical area being audited and the QA Auditor Training Program (QAPP-2~53), adequately assure that-the auditors are properly informed.

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David P Hoffman Assistant Nuclear Licensing Administrator CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement

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