ML20138M669
| ML20138M669 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/20/1997 |
| From: | Bordine T CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9702250474 | |
| Download: ML20138M669 (13) | |
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Consumers Thomas C. Bordine y Manager. Licensing SMO M Palisades Nuclear Plant: 27780 Blue Star Memonal Highway. Covert. MI 49043 February 20,1997 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT DOCKET 50-255 - LICENSE DPR PALISADES PLANT REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A)
In accordance with 10 CFR Part 50.54(a)(3)(ii), Consumers Power Company requests approval for two proposed changes to our report, " Quality Program Description for !
Operational Nuclear Power Plants"(CPC-2A). The changes are detailed in Attachment 1 of this letter. They are based on NRC guidance provided in an October 24,1996, letter to the Nuclear Energy Institute (Suzanne C. Black to Stephen D.
l Floyd). 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 inte. ."PC-2A.
SUMMARY
OF COMMITMENTS l This letter contains no new commitments and no revisions to existing commitments.
AYM 44 ;
Thomas C. Bordine Manager, Licensing j
CC Administrator, Region ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades 2 Attachments 9702250474 970220 PDR ADOCK 05000155 P PDR A CAG ENERGYCOMPANY
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ATTACHMENT 1 a
i CONSUMERS POWER COMPANY l l BIG ROCK POINT PLANT DOCKET 50-155 LICENSE DPR-6 l
. PALISADES PLANT DOCKET 50-255
! LICENSE DPR-20 l
REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A)
DETAILS OF CHANGES 4
i 6 Pages
ATTACHMENT 1 - DETAILS OF CPC-2A REQUESTED CHANGES
_1 2 REQUESTED CHANGE Add the following exception / interpretation where none currently exists for Regulatory Guide 1.144, Revision 1 (page 69 of CPC-2A):
A. CURRENT WORDING None.
B. REVISED WORDING 1
16.d. RG 1.144. Sec C.3.b(2), second paragraph l I
Requirement l l
A documented evaluation of the supplier should be performed l 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, l ,
audits and receiving inspections, (3) operating experience of l 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 j NRC audits). [
l Exception / Interpretation l 2 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 l ongoing receipt inspection, operating experience and supplier l evaluation programs, in lieu of performing a specific evaluation on j an annual basis. The results of the reviews are promptly l considered for effect on a supplier's continued qualification and l adjustments made as necessary (including corrective actions, l adjustments of supplier audit plans, and input to third party l auditing entities as warranted). In addition, results are reviewed l periodically to determine if, as a whole, they constitute a l significant condition adverse to quality requiring additional action. l 1
2 C. REASON FOR CHANGE A documented annual evaluation of suppliers 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. These sources include information such as vendor notices, Part 21 reports, INPO notices, and NRC notices. In addition, the industry has established a bulletin board through the Nuclear Procuremert 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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. j 3 l D. BASIS FOR CONTINUED COMPLIANCE WITH 10 CFR PART 50, APPENDIX B ,
The proposed change continues to require that Consumers Power Company perform reviews of information relevant to determining i supplier qualification and the adequacy of supplier control of quality. ,
This ex.:eption does not relieve Consumers Power Company of the obligation, contained in this 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 Part 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 i examination of products upon delivery. The approach discussed in this ;
exception provides for ongoing supplier evaluation, in lieu of the annual evaluation recommended in regulatory guidance. This is consistent with i 10 CFR Part 50, Appendix B, Criterion Vil, which requires, in part, that !
"The effectiveness of control of quality by contractors and i subcontractors shall be assessed at intervals consistent with the importance, complexity, and quantity of the product or services."
The proposed change does not affect the requirements applicable to the Nuclear Performance Assessment Department as described in the Palisades Final Safety Analysis Report Section 12.1.2.1. Through the ;
provisions described above, Consumers Power Company qualifies i suppliers of components subject to the Quality Program.
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4 L - REQUESTED CHANGE Add the following exception / interpretation where none currently exists (pages
- 71-72 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 I of five (5) quality assurance audits within a period of time not to l 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
Exception /Interoretation l
l The prospective lead auditor shall demonstrate his ability to l properly implement the audit process defined by this Standard l and Consumers Power Company program / procedure, to l effectively lead an audit team, and to effectively organize and l l report results, including participation in at least one nuclear l j quality assurance audit within the year preceding date of l l certification. l l l l C. REASON FOR CHANGE l l
The process of becoming a lead auditor is defined by ANSI N45.2.23 - i 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 discretion regarding the candidate's maturity, etc, to achieve 10 ,
or more points within the system defined by section 2.3.1. I
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- 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 a 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 ;
j understanding of the audit process. Knowledge / understanding ;
must be demonstrated through satisfactory completion of a written '
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.
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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 an 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 l 5
restrictive, and may not, by itself, assure the candidate has j demonstrated the required proficiencies. An individual may have related
! experience and be capable of demonstrating the ability to lead an audit l in fewer than five audits, or, may require more on-the-job experience i
than would be gained through " participation" in five audits. The i objective of this section is that the prospective lead auditor demonstrate j the ability to lead audits to the satisfaction of the responsible
- - management. Consumers Power Company believes this objective can be met with a smaller specified minimum 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 j- function, and develop an assessment awareness in future managers.
j These individuals are frequently capable of demonstrating their ability to i
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. It l would also permit Consumers Power Company to judge whether an j individual should be certified as a lead auditor based on demonstrated i
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capability, with participation in at least one recent nuclear quality assurance audit. The qualification / certification process to implement these requirements is provided in written procedures (in compliance with Criterion V) which requires evaluation results be documented and retained.
D. BASIS FOR CONTINUED COMPLIANCE WITH 10 CFR PART 50, APPENDIX B l l
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 Part 50, Appendix B, Criterion ll, " 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."
The proposed change has no impact on any requirements applicable to the Nuclear Performance Assessment Department as described in Chapter 12 of the Palisades Final Safety Analysis Report.
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a ATTACHMENT 2 CONSUMERS POWER COMPANY I
BIG ROCK POINT PLANT l DOCKET 50-155 1 LICENSE DPR-6 I PALISADES PLANT I DOCKET 50-255 ;
LICENSE DPR-20 ;
REQUEST FOR APPROVAL OF CHANGE TO THE QUALITY PROGRAM DESCRIPTION FOR OPERATIONAL NUCLEAR PLANTS (CPC-2A) -
AFFECTED PAGES (UNREVISED) OF CPC-2A 4 Pages
l Paga 68 Rev 17
, . Date: February 1,1997 3
Exceotion/Intercretation Rules are established governing access to and control of files as provided for in ANSI l N45.2.9, Section 5.3, item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or l microforms exist for general cue and backup.
14c. RG 1.88 C2 Reauirement 3 "Two methods of protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974. ' NFPA No 232-1975...also contains 1
! provisions for records protection equipment and records handling techniques that provide '
protection from the hazards of fire. This standard, within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the fire protection provisions listed in Subdivision 5.6...When NFPA 232-1975 is used, quality assurance records should be classified as NFPA Class 1 records...."
4 Exceotion/Interoretation CPCo adheres to ANSI N45.2.9-1974, Subdivision 5.6 for the facility for permanent storage of non-duplicated records. Temporary storage of documents after completion and during processing as records is in file cabinets selected in accordance with provisions of NFPA 4
232-1975 for Class 1 records (usually NFPA Class C,1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or UL-Class 350).
15a. RG l.64. C2 Reauirement "Regardless of their title, individuals performing design verification should not (1) havo j immediate supervisory responsibility for the individual performing the design...."
- Exceotion/Interoretation CPCo follows the requirements of ANSI N45.2.11-1974, Section G.1, and the guidance of
, Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as
! design verifiers mey be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9, herein). This approach is necessary to allow small organizational units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility needed to most effectively accomplish their assigned tasks. l
- I j 16 8. RG 1.144. Sec C3a(l) i Reauirement This section requires that for operational phase activities, RG l.33 " Quality Assurance l l
Program Requirements (Operations)" are to be followed. One of the RG l.33 requirements
! is that the results of actions taken to correct deficiencies that affect nuclear safety and CPC-2A.R17
l PIga 69 Rev 17
, . Date: February 1,1997 j occur in facility equipment, structures, systems, or method of operation are to be audited at i least once per six months. j i
Exceotion/interoretation See Item 3a for the exception to this requirement.
16b. RG 1.144, Sec C3a(2) l ;
Reauirement Applicable elements of an organization's quality assurance program (for " design and !
construction phaso activities") should be audited at least annually or at least once within :
the life of the activity, whichever is shorter. '
Exceotion/Interoretation Since most modifications are straightforward, they are not audited individually. . Instead, selected controls over modifications are audited periodically.
l 16c. RG 1.144. Sec C3b(1) l i
Reauirement This section identifies procurement contracts which are exempted from being audited.
Exceotion/Interoretation
- t in addition to the exemptions of RG 1,144, 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. ,
i 17a. N45.2.13. Sec 3.2.2 Reauirement N45.2.13 requires that technical requirements be specified in procurement documents bv reference to technical requiiement documents. Technical requirement documents are to l be prepared, reviewed and released under the requirements established by ANSI N45.2.11. l Exceotion/Interoretation i
For replacement parts and materials", CPCo follows ANSI N18.7, Section 5.2.13, Subitem I, 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 j similarly procured, but care shall be exercised to ensure at least equivalent performance." l CPC-2A.R17
- Pigs 71 Rev 17
, Date: February 1,1997 I Exceotion/Interoretation l
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Consumers Power qualifies audit personnel according to N45.2.23. Thus, personnel l performing source verification audits may not be certified according to N45.2.6. Personnel l performing inspection as part of source verification will be certified to N45.2.6 or qualified i in allowance with Paragraph 10.2.7. However, personnel performing source surveillances l l may not be certified to any of those requirements.
i 17f. N45.2.13. Sec 10.1 l l l
Reauirement ,
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"Where required by code, regulation or contract requirement, documentary evidence that j items conform to prneurement documents shall be available at the nuclear power plant site ;
prior to installation or use of such items, regardless of acceptance methods."
Excention/Interoretation Refer to item 2m.
17g. N45.2.13. Sec 10.3.4 (as modified by RG 1.123, C6e) l Reouirement i
" Post-installation test requirements and acceptance documentation shall be mutually established by the purchaser and supplier."
Excention/Interoretation in exercising its ultimate responsibility for its quality program, CPCo establishes post-installation test requirements, giving due consideration to supplier recommendations.
18a. RG 1.26. General Reauirement RG l.26 establishes a system for classifying pressure boundary items into four quality groups, which are then correlated with ASME B&PV Code and ANSI Standards requirements. (However, RG 1.26 does not indicate which of the four quality groups are safety-related, and which are not.)
Exceotion/Interoretation RG l.26 was used as a reference to establish piping system boundaries, but not for defining specific quality groups or making safety related determinations. Regulatory Guide 1.29, subject to Exception / interpretation 20a, is used to determine what systems and equipment included in the Quality Program.
CPC-2A.R17
Pign 72 Rev 17
, Date: February 1,1997 19a. Branch Technical Position AS89.5.1 and 10 CFR 50 Anoendix R.
Sections Ill G.. !!! J.. and til 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.
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.
Exceotion/Interoretation 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 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 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).
20b. RG l.29. General Reauirement Apply pertinent Quality Assurance requirements of 10 CFR 50, Appendix B.
Excention/Interoretation The pertinent quality requirements for these systems, structures and components will be l determined in a graded manner using tools such as the plant specific Probabilistic Safety Assessment and the Technical Specifications, and other docketed analyses to determine the degree which Appendix B of 10 CFR 50 applies.
21, ANSI /ANS 3.1 -1987 Execotion/Interoretation The commitment to ANSI /ANS 3.1-1987 is limited to requirments that apply to persons performing the independent safety review function as specified in Appendix C to this QPD.
CPC-2A.R17