ML18059A418

Responds to NRC 930903 Ltr Re Violations Noted in Insp Rept 50-255/93-13.C/As:licensee Has Reviewed & Evaluated Quality Verification Program & Identified Appropriate Changes to AP 5.23

ML18059A418
Person / Time
Site:	Palisades
Issue date:	10/04/1993
From:	Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9310120355
Download: ML18059A418 (6)

Text

consumers Power GB Slade General Manager l'OWERINli MICHlliAN'S l'ROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 October 4, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT 93013 NRC Inspection Report No. 93013, dated September 3, 1993, forwarded the results of an NRC inspection conducted to review the relatian~hip.recent -

events had, if any, with the peer inspection process .. The in~pection report identified an apparent violation of NRC require~ents where peer inspections were not properly implemented to provide independent* verifications. The reply*

to the notice of violation is attached. *

• The letter transmitting the notice of violation also requested that we pr_ov.ide a written response to an unresolved item (93013-02) pertaining to a perceived design control ~rror associated with an inadvertent start of one emergency diesel generator, along with the violation response. As discussed in a September 30, 1993 exit meeting, (93-021) a future onsite NRC Inspection will be scheduled to further address this*unresolved item and other similar issues.

Therefore, as discussed with Bruce Jorgensen on October 1, 1993, this letter does not contain a response to unresolved item 93013-02. We have formed a multi-discipline group to review this event and others involving electrical .

design or modificatfon issues. Information pertaining to the unresolved item will be av~ilable onsite following the completion.of our review efforts.*

Results and recommendations from this group review should be available by October 22, 1993 for your review. *

.XS~

Gerald 8. Slade General Manager CC: Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment

• 9310120355 931004

DR ADOCK O~~S ll 1200 2 (~

.ACMS'ENERGYCOMPANY

,~

~ -.

ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REPLY TO NOTICE OF VIOLATION NRC INSPECTION REPORT No. 93013 October 4, 1993

• 4 Pages

1 REPLY TO NOTICE OF VIOLATION Violation During an NRC inspection on June 14 - July 30, 1993, a violation of NRC .

requirements was identified. In accordance with the "General Statement of Policy and Procedure for the NRC Enforcement Actions,"10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR 50, Appendix X,"lnspection," requires, in part, that a program for inspection activities affecting quality shall be established and executed to verify conformance with documented instructions, procedures, and drawings. In addition, such inspections are required to be performed by individuals other than those who performed the activity being inspected. *

• Section 10.2.2 of the licensee's "Quality Program Description for Operational Nuclear Power Plants." CPC-2A, dated June 15, 1993, sta~es inspections are applied to maintenance activities to verify conformance to specified requirements. In addition, Section 10.2.2 of CPC-2A states independent verification is performed at each operation where it is necessary to verify conformance with NRC requirements.

CPC-2A commits the licensee to Regulatory Guide 1.116, Quality Assurance Requirements for lnsta77ation, Inspection, and Testing of Mechanical Equipment and Systems," dated June 1976, which in turn, endorses ANSI N45.2.8-1975,"Supp,1ementary Quality Assurance Requirements for lnsta77ation~ Inspection and Testing of Mechanical Equipment and Systems For The Construction Phase of Nuclear Power Plants." Section 4.4 of ANSI 45.2.8-1975, states inspections of work in progress sha77 be * -, J performed to verify that mechanical. items are being located, insta77ed, assembled and connected in compliance with the latest approved instructions and procedures. Section 4.4 of ANSI N45.2.8-1975, further states that "leveling and alignment" is an item for which inspectforis shall be performed, as appropriate. ..

Contrary to the above, on June 16, 1993, the inspection of an auxiliary feedwater pump alignment, an activity which affected quality, was performed by the same individual who performed the alignment.*

. This is a Severity Level IV violation (Supplement I).

Reason for the Violation

• The reason for the violation was that we did not properly translate our inspection commitments into our inspection procedure. The plant quality verification program procedure allowed ~ double verification to be performed on a pump alignment activity rather than an independent veri fi cation. ** ...

.\ .

I~ 2.

. **. ~ .. : '

• .Administrative Procedure 5.23 (AP 5.23), "Quality Verification Program," .

translates to the Palisades verification planners the direction and guidance of our conunitments on when verification of work activities are required and what kinds of verifications are needed. Attachment 1 to AP 5.23 is entitled, "Independent V~rification Activity List," and contains descriptions of five types of activities which require "independent verifications." Attachment 2 to AP 5.23 is entitled, "Quality Verification Activity List," and* contains a list of activities which shall be considered for "verification."

The previous Quality Control Inspection Program inspection lists provid~d the basis for developing Attachment I and Attachment 2 of AP 5.23. Under the Quality Control Inspection Program there were two inspection lists, one for hold points and one for notification points. The perceived application of these lists was tha~ hold point inspections were required and would be done

,,;,~

3 every time. Notification points were not necessarily. required as the nature and extent of the work would determine when inspections were necessary.

Notification point inspections could be waived in the field by the QC inspector. This philosophy was adopted in the new quality program -

verification lists, Attachment 1 and 2 of AP 5.23. The activities identified on Attachment 1 to AP 5.23, were considered required and therefore they were independently verified.* The activities identified on Attachment 2*to AP 5.23 were to be considered for verification based on the nature and extent of the work, but were not necessarily required. However, certain activities that were ~ranslated into Attachment 2 of AP 5.23 should receive independent verifications consistent with our program conunitments, and this was not made clear in our program procedure. _ The incorrect translation of requirements from the previous quality'program to the new quality program through the development AP 5.23 resulted in a situation where something less than an independent verification could be performed for a required inspection.

Therefore, as stated in the *xample for the above noted violation, following_

the alignment of an auxiliary feedwater pump the plant quality verification program procedure allowed a double verification to be performed on the *pump -

alignment activity rather than an independent verification.

In spite of this lack of precise guidance in AP 5.23, it is noted that since the implementation of the Quality Verification Program {January 1, 1993}, -

approximately 600 independent verifications have been performed.

- Approximately 325 of those verifications were performed because the procedure directed that independent verifications were required; while the other 275-verifications were specified because it was judged that the nature and extent of the work was such that an independent verification was warranted.

• Corrective Actions and Results Achieved No equipment $pecific corrective actions were required. The alignment of the auxiliary feedwater pump was completed properly and the pump was declared operable following successful post maintenance testing. -

Notification has been sent to -all verification planners, maintenance supervisors, and system engineers that independent verifications are required whenever safety related pump leveling and alignments are made.

Corrective Action to Avoid Future Non-Compliance To correct the deficiency with th_e Palisades Quality Verification Program we have reviewed and evaluated the quality verification program and identified appropriate changes to AP 5.23, "Quality Verification Program." Revisions will be made to the procedure that will focus on regulatory compliance with respect to application of independent verification. AP 5.23 will be revised to:

4

1. Clarify sufficiently that only independent verification can be used to satisfy regulatory requirements for inspection.

2. Provide additional guidance on when independent verification $hall be designated to meet regulatory requirements.

3. Clarify when *double or self verifications may be used to enhance the overall effectiveness of the quality verification program and' to ensure that these verifications will not be used in place of.

independent verification. *

4. Reference and identify applicable ANSI standards that we are cormnitted to by CPC-2A "Consumers Power Company's Quality Program Descripti9n for Operational Nuclear Power Plants."

5. Pro~ide guidance for determining when maintenance ~ctivities are*

comparable in nature and extent to that of original construction phase activities and on the application of construction phase ANSI standards. *

6. Clarify the application of generic verification activities such as those contained in the quality vefification program implementation procedure, AP s:23, Attachment 1, "Independent *verification

• Activity List" and Attachment 2, "Quality Verification Activity List," by combining them into one attachment and providing additional guidance in their application.

When the procedure is revised personnel responsible for its implementation will be re-trained in their area of responsibility. Personnel which will receive this training will* include:

• Maintenance Supervisors

• Quality *Verification Planners

• System Engineers .~ . ~-

Date of Full Compliance  :  ; ~* ;..

Full compliance has been met. Notification has been sent to all ~erification planners, maintenance supervisors and system engineers that independent verifications are required whenever safety related pump leveling and alignments are made. *

.' *~ . :* .

.~

' .