ML20147E394
| ML20147E394 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 01/15/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8801210100 | |
| Download: ML20147E394 (5) | |
Text
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
t Ci
/
Oggy Consumers Power Kermeth W Berry Director Nuclear Lkersing Gerwrel Offces: 1945 West Pernall Roed. Jackson MI 49201 e (517) 7881636 January 15, 1988
'7uclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
PROPOSED QUALITY ASSURANCE PROGRAM DESCRIPTION, CPC-2A, CHANGES Englosed for your review and approval are proposed changes to Consumers Power Company's QA Topical Report, CPC-2A.
Included with each charge is the reason and an analysis forming the basis for concluding the program would continue to comply with 10CFR50 Appendix B, if approved. The first change has been discussed with NRC staff and would authorize extension of our Enhanced Performance Incentive Program which has undergone successful pilot testing at Big Rock Point. The other changes relate to using independent audits of the QA organization as the means to biennially assess program effectiveness and to clear up an apparent transposition in an ANSI standard to which we have committed.
We have reviewed these changes and determined they do reduce the effectiveness of our approved QA Topical Report.
In accordance with 10CFR50.54(a)(3), NRC review and approval is therefore required. Pursuant to 10CFR170.11(c) a check in the amount of $150.00 is remitted with this application.
'fbw Kenneth W Berry D! rector, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades NRC Resident Inspector - Big Rock Point Attachment 9
f6kk OC0188-0005. NT 04 o
8801210100 880115 Ag sp
/
PDR ADOCK 05000155 jff P
DCD gegg
?
ATTACHMENT Consumers Power Company Big Rock Point & Palisades Plants Dockets 50-155 & 50-255 PROPOSED QUALITY ASSURANCE PROGRAM DESCRIPTION, CPC-2A, CHANGES January 15, 1988 i
l l
l I
L a
t i
I t
1 i
I l
3 Pages l
l OC0188-0005-NLO4
QUALITY ASS"RANCE PROCRAM t'ESCRIPTICJ (CPC-2A)
CPC-21, Revision 7 CPC-7A, Revision 8 Reason for Change Basis for Conclusien
~
Proposed Compliance with IOCFR50, App B 1
No item 1.2.5, Page 7, add a new item to Approval was received in 1986 to IDC1 '
oppendix B states in Executive Director's authority:
institnte a pilot program, at Criterion one that persons Big Rock Point similar to the performing "quality assurance" Administering an Enhanced the one de crilse-2n the proposed functions must ! ave sufficient Performance Incertlwe P.> gram, revision. The program is similar authaaicy and crganizational in many ways to the NRC SALP Pro-freedom to ef fectively per-2.3, Page 21, Add new Sections gram. The pilot program ctamit-form such functions. Appendix 2.3.1 through 2.3.4:
ted to assess the program's B then goes on tc -stiblish sucetss, report to NRC. and re-many "measures" intended to 2.3 ENHANCED PERFORMANC5 quest: changes to the QA Topical assure quality, but whose
'tNCENTIVE PROGRAM report to allow continued use, performance is not limited or expansion, of the program, to a QA organization, as such.
2.3.1 The Executive Director, if warranted. A meeting was Criteria 10 and 18 do previde Nuclear Assurance evaluates held October 21,*,987.
The pro-limitations on independence performance of organizational gram described here is consis-of inspectors and auditors.
units to determine which, if tent with discussions at the CPC-2A already addresses in-any, may have the level of QA meeting, and would govern spection by non-QA department oversight of in procesa acti-corrent and future activities.
staff in Sections 10.2.3 and vities reduced. Consideration 10.2.7, with appropriate con-is given to the following in trols. The EPI Program des-making the determination:
cribed will continue to be regulatory performance; quall-monitored by audits performed fication, knowledge anc ner-by QA personnel. Thus the QA formance of personnel; internal program established by CPC-2A, audit / surveillance / inspection as modified, will e,ntinue to results; results of assessmer.ts comply with Apper.1x B, both ty other independt organt s-with respect te the measures tions; oversll conic. -uce to intended to assure quality, established requirements; and and as regards involvement corrective actio:. perfcrmance, of an independent assuraoce organization.
2.3.1 Those organizational units selected may receive reduced QA/QC attention in areas such as direct reviews (for examnle, mair.tenance/
vork order or procedure review),
inspection coverege, or sur-veillance, as warranted. Audit frequency is not subject to re-duction.
Mill 87-0001A-QA06 1
QUALITY ASSURANCE PROGRAM DESCRIPTION (CPC-2A) y CPC-2A, Revision 7 CPC-2A, Revision 8 Reason for Change Basis for Conclusion Proposed Compliance with 10CFR50, App B
.a-2.3.3 An Enhanced Performance Incentive Program Plan is de-veloped for each organizational unit entering the Program to de-fine the perfrimance criteria to be maintained, the 1reas where QA/QC w 31 be reduced, and the intervals at wh'ch performance will be assessed and reported.
2.3.4 Performance of organiza-tional r-its in the Program is monitore and reported to'the Executive Ditettor, Nuclear Assurance, at intervals estab-lished as part of the entry con-ditions. Declining performance results in return to normal or increased QA/QC attention.
2 4
2.2.10c, Fage 21 2.2.10c Hanagement teams sadependent from Management teams independent from Contact with other utilities in-
'Ihe CPC-2A statement is derived the Quality Assurance organiza-the Quality Assurance organiza-volved in a Joint l'tility from 10CFR50, Appett.ix B re-tton, but knowledgeable in tion, but knowledgeable in andit-Management Audit (J/wi) program, quirement that the "applicact auditing and quality assurance, ins and quality assurance, bienni-of which CP Co is an active mem-shall regularly review the biennially review the ef fective-ally review the eafectiveness of ber, and rt.riew of results of JUMA stMus and adequr.cy of the ness of the Quality Assurance Pro-the Quelity Assurance Program for audits o.' CJ Co, has led to the quality : assurance program."
gram for Operational Nuclear Power Cperational Nuc' ear Power Plants. conclusior that JUMA audits satis-Other CPC-2A startments Plaots. Conclusions and recor-This review may be perfonsed as fy the intent of this program ele- (2.2.10a and b) also address mendations are reported to the part of independent audit of the ment. The effectiveness of the how this regsirement is met.
I Senior Vice President, Energy Quality Assurance organization.
QA c.tanization is related to 611ettive'y, the require-1 Supply.
Conclusions and recommendations overall program effectiveness, ments of CPC-2A, as modi-4 are reported ts the Senior and is determinable through fled, continue to meet 10CFR50s Conective actions ir response to Vice President, Energy Supply.
recognized audit and assessment Appendix B, in that a program reco m dations are cracked in techniques employed by JUMA (or of independent assessments, the regular torrective action C erective actions in response to employable by any other selected regular c.eetings and dis-4 tracking system (see Section 16.0, recommendations are tracked in team). This change clarifies tribution of audit results is CORRECTIVE ACTION).
the regular corrective action the scope of the biennial assess-established, tracking system (see Section 16.0, ment in order to better focus its CORRECTIVE ACTION).
performance on available indica-tors of effectiveness.
MI1187-0001A-QA06 2
.~
[
QUALITY ASSURAltCE PROGRAM DESC4IPIf0N (CPC-2A)
CPC-2A, Revinton 7 CPC-2A, Revision 8 Reason for Change Basis fer Conclusion....
+
Proposed Compliance with 10CFR50, App B 3
No item Add a new item 7c, renumber Analysis of requirements Since 10CFR50, Appendix B exieting 7c through 7g and committed to in CPC-2A disclosed does not specifically address retain.
this apparent transposition of this requirement, but does wording in the 1972 version of generally require that measures 7c. Sec 3.4.1 and Appendix A ANSI N45.2.2.
CP Co desires to 3 be established for' control and 3.4.1(4) and (5) clarify these requirements to protection of materials and facilitate implementation.
equipment, it can be seen that Requ rement the program described by CPC-2A.
continues to comply with
"(4).. 11cwever, preservatives Appendix B.
for inaccessible inside surfaces containing reactor coolant water shall be indicated to facilitate touch up.
(5) The F.sme of the preservative used shall be the water flushable type.6*
Exception / Interpretation Based on comparison of these statements to ANSI /ASME NQA-2 1983, CP Co believes the intent was to estabish the following as requirements:
I (4)... Ilowever, preservatives for inaccessible inside surfaces of pumps, valves and pipe for systems containing reactor coolant water shall be the water flustable Ehenameoftt.tpreservative used shall be provided to facili-tate touch up.
e MI1187-OO01A-QA06 3
2-w we e,y
= e r
m
,-w-w-=w--
w wis u
v-- ' -
-Tv--
rr-*
e s
w~-
c T-w
-7e-'v 4
T-