ML20128N670

Ack Receipt of 10CFR50.54(a) Submitted on 960625 Re Proposed Changes to QAP Description.Submittal Proposed Changes to Evaluation on Program,Qualification Requirements for Lead Auditors & Record Retention Requirements Submitted

ML20128N670
Person / Time
Site:	Palisades, Big Rock Point  File:Consumers Energy icon.png
Issue date:	10/08/1996
From:	Jeffrey Jacobson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Fenech R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 9610170002
Download: ML20128N670 (2)

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October 8, 1996 l

Mr. R. A. Fenech Vice President, Nuclear Opaations Consumers Power Company 27780 Blue Star Memoria: Highway Covert, MI 49043-9530

Dear Mr. Fenech:

Thank you for your 10 CFR 50.54(a) submittal dated June 25,1996, which proposed

! changes to your Quality Assurance (QA) Program description. The submittal proposed

' changes (1) to your supplier evaluation program, (2) to the qualification requirements for l

lead auditors, and (3) to the record retention requirements for radiation exposure records.

We have reviewed the changes associated with this submittal. The first two proposed changes, i.e., changes to your supplier evaluation program and qualification requirements for lead auditors, are similar to proposals made by the Nuclear Energy Institute (NEI) in a letter dated January 30,1996, to the NRC. The NEl proposals are currently under review.

by the Office of Nuclear Reactor Regulation. As such, these two proposed changes cannot be approved at this time because an agency position has not yet been established.

Based on our review of your dmittal we have concluded that the third proposed change, i.e., changes to the record retention requirements for radiation exposure records, continues to meet the requirements of 10 CFR Part 20 and 10 CFR Part 50, Appendix B; and that the revision associated with the third change is acceptable. Although this change will delete the QA Program description requirement for retention of monthly radiation exposure records, Technical Specification 6.10.2.c for the Palisades Nuclear Generating Plant still requires that monthly radiation exposure records be retained.

if there are changes to OA commitments existing in docketed correspondence outside of the Quality Assurance Program description, you are obligated to notify this office. We appreciate your timely submittal of information required by 10 CFR 50.54(a). Please i

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9610170002 961008 PDR ADOCK 05000155 )

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R. A. Fenech l i

l contact Mr. Ronald A. Langstaff of my staff at (630) 829-9747 with any questions you l

may have regarding this matter.  ;

Sincerely, i Original signed by John M. Jacobson John M. Jacobson, Chief Division of Reactor Safety Docket No. 50-155 Docket No. 50-255

Enclosure:

Ltr dtd 06/25/96, R. Smedley Consumers Power, to NRC w/atts cc w/o enet: T. Palmisano, General Manager, Palisades P. M. Donnelly, Plant Manager Big Rock Point T. C. Bordine, Manager Licensing Department cc w/ encl: James R. Padgett, Michigan Public Service Commission Michigan Department of Public Health Department of Attorney General (MI)

Distribution:

Docket File w/enci DRS w/enct A. B. Beach, Rlll w/enct PUBLIC Ww/enci Rill PRR w/enci Enf. Coordinator, Rllt w/enci OC/LFDCB w/enci SRIs, BRP, Palis w/enci CAA1 (E-mail) w/ encl DRP w/enct LPM, NRR w/enct W. L. Axelson, Rllt w/enci R. Gramm, NRR w/enct R. Latta, NRR w/ encl DOCUMENT NAME: G:\QAPDCPC.DRS To receive e coFy of this document, indicate in the box "C" = Copy without ottachrnent/ enclosure "E" = Copy with attachment / enclosure "N" = No copy f Elli 6 Rill K\

OFFICE Rill F .Rllt , ,

NAME RLangstaff:nh /#g TKozak/jfff WKropp Q) JJacob(oh,l Q DATE 10/$'/96 10/f/96 10/4/96 10$96%[f f OFFICIAL RECOF;D COPY

0 BT POWERING MIENIGAN'S PROGRESS Pahsades Nuclear Plant. 27780 Blue Star Memorial Highway. Covert. MI 49043 J ne 25,1996 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR 6 - BIG ROCK POINT PLANT DOCKET 50 255 - LICENSE DPR-20 PALISADES PLANT REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A)

In accordance with 10 CFR 50.54(a)(ii), Consumers Power Company requests approval for three changes to our CPC-2A report, " Quality Program Description for Operational Nuclear Power Plants" The changes are detailed in Attachment 1 of this letter. The affected pages of CPC-2A are shown in their unrevised form in Attachment 2.

Upon approval of these changes by the NRC, a revision will be made to incorporate the changes into CPC-2A.

SUMMARY

OF COMMITMENTS This letter contains no new commitments and no revisions to existing commitments.

MT lt2-

Richard W. Smedley Manager, Licensing [

gy CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC l NRC Resident inspector - Palisades Attachment 4607020t64-960625 l PDR ADOCK 05000155 P PDR A CATS ENE7?GYCOMPANY

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l ATTACHMENT 1 CONSUMERS POWER COMPANY BIG ROCK POINT PLANT DOCKET 50-155 LICENSE DPR-6 PALISADES PLANT DOCKET 50-255 LICENSE DPR-20 l

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REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION i FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A)

DETAILS OF CHANGES s

6 Pages 1

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ATTACHMENT 1 - DETAILS OF CPC-2A REQUESTED CHANGES 1

.L REQUESTED CHANGE Add the following exception / interpretation where none ;urrently exists for Regulatory Guide 1.144, Revision 1 (page 74 of CPC-2A):

A. CURRENT WORDING f

None.

B. REVISED WORDING 16.d. RG 1.144. Sec C.3.b(2), second paragraph l I

l Requirement I

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A documented evaluation of the supplier should be performed l

annually. Where applicable, this evaluation should take into l

account (1) review of supplier-furnished documents such as l

certificates of conformance, non-conformance notices, and l corrective actions, (2) results of previous source verifications, [

audits and receiving inspections, (3) operating experience of l identical or similar products furnished by the same supplier, and l

, (4) results of audits from other sources, e.g., customer, ASME or l NRC audits.

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Exception / Interpretation l

l Consumers Power Company will review the information described l in the second paragraph of section C.3.b(2) of Regulatory Guide l 1.144, Revision 1,1980, as it becomes available through its receipt l inspection, operating experience and supplier evaluation l programs, in lieu of performing a specific evaluation on an annual l basis. The results of the reviews are considered immediately for [

effect on a supplier's continued qualification and adjustments made l as necessary.

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C. REASON FOR CHANGE A documented annual evaluation of suppilers is neither necessary nor cost-efficient. The annual review can be eliminated because alternative measures developed through industry initiatives, and through the evolution of utility supplier performance monitoring and evaluation <

programs, provide a more responsive and effective means to identify and correct supplier performance problems.

At Consumers Power Company, supplier-furnished documents are reviewed as part of the receipt inspection process for purchased items and services, and any deficiencies or concerns are documented at that time. The supplier is notified on a real-time basis for correction. The

' results of the receiving inspection process are trended as necessary, and provided to the supplier evaluation process for review and determination of the effect on the supplier's qualification status.

Consumers Power Company personnel perform source verifications and audits as needed to establish procurement acceptability. The results are provided to the supplier evaluation process for review and determination of the effect on the supplier's qualification status. In addition, the supplier evaluation process reviews third party audit reports (NUPIC, ASME, NRC, etc) as they are received and considers their effect on supplier qualification status.

Consumers Power Company personnel perform reviews of operating experience information involving part and equipment failures received from various sources, such as vendor notices, Part 21 reports, INPO notices, NRC notices, and the like. In addition, the industry has established a bulletin board through the Nuclear Procurement issues Committee (Consumers Power Company is a member) to share real-time data regarding supplier performance from audits, surveillances and other information. This information is provided to the supplier evaluation process for review and determination of the effect on the supplier's qualification status.

Thus, in many cases, evaluation of supplier performance is performed more frequently than annually through the routine reviews described, especially when performance problems have been identified. In some cases, the evaluation may be extended.

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D. BASIS FOR CONTINUED COMPLIANCE WITH 10 CFR 50, APPENDIX B The proposed change continues to require that Consumers Power Company perform reviews of information relevant to determining supplier qualification and the adequacy of supplier control of quality. This exception does not relieve Consumers Power Company of the obligation, contained in th_is document through its commitment to other requirements, to assure that material, equipment, and services that are purchased conform to procurement requirements. As required by 10 CFR 50, Appendix B, measures applied to give this assurance include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of l products upon delivery. The approach discussed in this exception '

provides for ongoing source evaluation, in lieu of the annual evaluation recommended in regulatory guidance. This is consistent with 10 CFR 50, Appendix B, Critenon Vll, which requires, in part, that "The effectiveness of control of quality by contractors and subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or services."

L REQUESTED CHANGE Add the following exception / interpretation where none currently exists (page 77 of CPC-2A):

A. CURRENT WORDING None.

B. REVISED WORDING 18.b. ANSI N45.2.23-1978 Section 2.3.4 l l

Reauirement l l

The prospective lead auditor shall have participated in a minimum l of five (5) quality assurance audits within a period of time not to [

exceed three (3) years prior to the date of qualification, one audit l of which shall be a nuclear quality assurance audit within the year l prior to his qualification. l l

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I The prospective lead auditor shall demonstrate his ability to l properly implement the audit process defined by this Standard and l Consumers Power Company program / procedure, to l l effectively lead an audit team, and to effectively organize and l

. report results.

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l C. REASON FOR CHANGE The process of becoming a lead auditor is defined by ANSI N45.2.23 -

l 1978, " Qualification of QA Program Audit Personnel for Nuclear Power Plants," as endorsed by NRC Regulatory Guide 1.146 of August,1980.

As defined by ANSI N45.2.23, the process consists of essentially the following parts:

1. Evaluation of the candidate's prior education and experience, professional accomplishments, including some management l

discretion regarding the candidate's maturity, etc, to achieve 10 or more points within the system defined by section 2.3.1.

2. Employer certification that the candidate's written and oral communication skills effectively meet its expectations, as described in section 2.3.2.

3. Evaluation of the candidate's knowledge and understanding of quality assurance program requirements, and auditing and audit planning techniques, obtained either through experience or training programs, coupled with on-the-job training to demonstrate understanding of the audit process. Knowledge / understanding

! must be demonstrated through satisfactory completion of a written i examination, as described in section 2.3.3.

4. Demonstration of the candidate's capabilities through participation in the performance of audits as described in section 2.3.4.

Thus, the process of lead auditor qualification is comprised of establishing the candidate's possession of satisfactory knowledge and understanding, prior experience, and demonstrated performance. This

! approach represents a systematic way to ensure on individual has demonstrated their ability to effectively lead audits prior to being certified as a lead auditor. The ANSI requirement for a particular number of audits over a particular time period, however, is unnecessarily restrictive, and 4

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may not, by itself, assure the candidate has demonstrated the required proficiencies. An individual may have related experience and be capable of demonstrating the ability to lead an audit in fewer than five audits, or, may require more on-the-job experience than would be gained through

" participation"in five audits. The objective of this section is that the prospective lead auditor demonstrate the ability to lead audits to the satisfaction of the responsible management. ' Consumers Power Company believes this objective can be met without a numerical restriction regarding audit participation. This is particularly true when considering the rotation into the auditing group of experienced technical and management staff to broaden their experience base, bring current experience to the audit function, and develop an assessment awareness in future managers. These individuals are frequently capable of demonstrating their ability to effectively lead audits in fewer than five audits.

The proposed change in the Quality Program Description would permit Consumers Power Company to assess the performance of prospective lead auditors against the knowledge and performance criteria established in Regulatory Guide 1.146 and ANSI N45.2.23-1978, and to judge whether an individual should be certified as a lead auditor based on demonstrated capability.

D. BASIS FOR CONTINUED COMPLIANCE WITH 10 CFR 50, APPENDIX B The proposed change continues to require that Consumers Power Company follow an established process meeting NRC guidance prior to certifying an individual as a lead auditor, but provides management the flexibility to certify the individual once the requisite skills have been satisfactorily demonstrated. This is consistent with 10 CFR 50, Appendix B, Criterion 11, " Quality Assurance Program," which requires the Quality Program to " provide for the indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained." This is also consistent with Criterion XVill, which requires that audits be performed by

" appropriately trained personnel."

1 REQUESTED CHANGE Revise Appendix E, Record Retention, section E3.c (page 87 of CPC-2A) as follows:

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A. CURRENT WORDING E3. The following records shall be retained for the duration of the Facility Operating License:

c. Records of monthly radiation exposure for allindividuals entering radiation controlareas.

B. REVISED WORDING E3. The following records shall be retained for the duration of the Facility Operating License: i i

c. Records of radiation exposure for allindividuals entering l l radiation control areas, generated on the frequency l l specified by NRC regulations. l l

C. REASON FOR CHANGE This section was placed into CPC-2A late in 1995 in anticipation of its  !

removal from facility Technical Specifications in accordance with NRC Administrative Letter 95-06. A review has identified that exposure records have not been generated on a monthly basis since 1979. The current practice of generating these records on a quarterly basis is consistent  ;

with requirements in 10 CFR 20.401 and 10 CFR 20.2106(b).

D. BASIS FOR CONTINUED COMPLIANCE WITH 10 CFR 50, APPENDIX B The specified records will continue to be retained for the term of the Facility Operating License, even though generated on a different frequency. This is consistent with 10 CFR 50, Appendix B, Criterion XVil, which requires that " sufficient records shall be maintained to furnish evidence of activities affecting quality," and " Consistent with applicable regulatory requirements, the applicant shall establish requirements

! concerning record retention .. "

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• e ATTACHMENT 2 CONSUMERS POWER COMPANY l

BIG ROCK POINT PLANT  !

DOCKET 50-155 LICENSE DPR-6 PALISADES PLANT DOCKET 50-255 LICENSE DPR-20 )

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REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A) -

AFFECTED PAGES (UNREVISED) OF CPC-2A 3 Pages

Pcg31 Rev 16 Date: 12/1/95 16b. Sec C3a(2)

Reauirement Applicable elements of an organization's quality assurance program (for " design and construction phase activities") should be audited at least annually or at least once within the life of the activity, whichever is shorter.

Exception /interoretation Since most modifications are straightforward, they are not audited individually. Instead, selected controls over modifications are audited periodically.

16c. Sec C3b(1) '

Reauirement This section identifies procurement contracts which are exempted from being audited.

Exceotion/interoretation in addition to the exemptions of RG l.144, CPCo considers that Authorized Inspection Agencies, National Institute of Standards and Technology or other State and Federal Agencies which may provide services to CPCo are not required to be audited.

17a. N45.2.13. Sec 3.2.2 Reauirement N45.2.13 requires that technical requirements be specified in procurement documents by reference to technical requirement documents. Technical requirement documents are to be prepared, reviewed and released under the requirements established by ANSI N45.2.ll.

Exception /Interoretation For replacement parts and materials", CPCo follows ANSI NI8.7, Section 5.2.13, Subitem I, which states: "Where the originalitem or part is found to be commercially 'off the shelf or without specifically identified QA requirements, spare and replacement parts may be similarly procured, but care shall be exercised to ensure at least equivalent performance."

CPC-2A.R16 1

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Date: 12/1/95 i

tion 20a, is used to determine what systems and equipment included in the Quality 1

Program.

t 19a. Branch Technical Position ASB9.5.1 and 10 CFR 50 Accendix R.

Sections lil G.. ill J. and lli O.. General Exceotion/Interoretation Fire protection measures, equipment and the individual plant Fire Protection Plans are in compliance with the NRC Safety Evaluation Reports and the required sections of 10 CFR 50 Appendix R except for the specific exemptions approved by the NRC.

l 20a. RG 1.29. Sec C, Regulatory Position Reauirement The Regulatory Position states that the identified structures, systems, and components are to be designated Seismic Category I and should be designed to withstand the SSE.

Exception / interpretation l

Both CPCo nuclear plants (Big Rock Point and Palisades) were designed, constructed and licensed based on criteria available prior to Revision 3 of this Regulatory Guide being l issued. The specific design criteria and seismic designations are reflected in the FHSR and FSAR, respectively, and in other docketed analysis. Thus, the design bases and I seismic designations do not correspond to those of Regulatory Guide 1.29.

The criteria of this Regulatory Guide are used at CPCo primarily in the identification of systems, structures, and components to which the Quality Program is applied (see 20b, below).

i l 20b. RG l.29. General j Reauirement l

Apply pertinent Quality Assurance requirements of10 CFR 50, Appendix B.

Exception /Interoretation The pertinent quality requirements for these systems, structures and components will be  ;

determined in a graded manner using tools such as the plant specific Probabilistic Risk l Assessment and the Technical Specifications, and other docketed analyses to determine l the degree which Appendix B of10 CFR 50 applies.

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CPC-2A.R16 77 1

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Pags 87 ,

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Rev 16 Date: 12/1/95 QPD MANUAL APPENDIX E RECORD RETENTION E1. In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated:

E2. The following records shall be retained for at least five years:

a. Records and logs of facility operation covering time interval at each powerlevel.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principalitems of equipment related to nuclear safety.

c. All reportable events as defined in 10 CFR 50.72 and 50.73.

d. Records of surveillance activities, inspections and calibrations required by Plant Technical Specifications.

e. Records of changes made to the procedures required by Plant Technical Specifications.

f. Records of radioactive shipments.

g. Records of sealed source leak tests and sesults.

h. Records of annual physicalinventory of all source material of record.

E3. The following records shall be retained for the duration of the Facility Operating License:

a. Record and drawing changes reflecting facility design modifications made to systems and equipment described in the Palisades Final Safety Analysis Report or l Big Rock Point Final Hazards Summary Report.

l b. Records of new and irradiated fuelinventory, fuel transfers and assembly bumup histories.

c. Records of monthly radiation exposure for allindividuals entering radiation control areas.

d. Records of gaseous and liquid radioactive material released to the environs.

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i j CPC-2A.R16 87 I

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