ML20153D890
| ML20153D890 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 02/06/1986 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8602240286 | |
| Download: ML20153D890 (2) | |
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Company Nud,er Iken,bng General Offees: 1945 West Pernali Road Jackson, MI 49201 e (517) 788-1636 AA 94A is D@
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James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
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DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
CONSUMERS POWER COMPANY TOPICAL REPORT CPC-2A, REVISION #5 (SUPERSEDES OCTOBER 21, 1985 SUBMITTAL)
NRC approval to revise our Topical Report, CPC-2A, Sections 3.2.9 and 18.2 2c, and Exception / Interpretation 15a is requested in accordance with 10CFR50.54.
This request supersedes our earlier request of October 21, 1985 covering the
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same subject. The following changes are proposed:
Change 3.2.9 to read:
"3.2.9 Persons representing applicable technical disciplines are assigned to perform design verifications. These persons are qualified by appropriate education or experience but are not directly responsible for the design. The designer's immediate supervisor may perform the verification, provided that:
- 1) He is the only technically qualified individual available, and
- 2) He lid not specify a singular design approach, rule out certain design considerations, or establish design inputs fer the particular design aspects being verified, and
- 3) His review is either:
a.
Approved in advance by the supervisor's management, with documentation of the approval included in the design pack-age, or b.
Controlled by a procedure reviewed and approved by the Nuclear Assurance Department.
Such procedure shall provide specific limitations regarding the types of design work that may or may not be verified by a designer's supervisor, and shall provide for clear documentation that the supervisor performed the design verification.
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James G Keppler, Administrator 2
Big Rock Point & Palisades Plants CPCo Topical Report CPC-2A Rev 5 February 6, 1986 QA audits cover the frequency, effectiveness, and technical adequacy of the use of supervisors as design verifiers to guard against abuse." Change 18.2.2c to read:
"18.2.2c Controls over plant modifications, including the frequency, effectiveness and technical adequacy of the use of supervisors as design verifiers."
Change Exception / Interpretation 15a to read:
"15a RG 1.64, C2 Requirement "Regardless of their title, individuals performing design verification should not (1) have immediate supervisory responsibility for the individ-ual performing the design..."
Exception / Interpretation CP Co follows the requirements of ANSI N45.2.11-1974, Section 6.1, and the guidance of Section 3E4(a) of the Standard Review Plan, with the exception that use of supervisors as design verifiers may be controlled by a procedure instead of individually approved in advance in each case (see Section 3.2.9).
This approach is necessary to allow small organiza-tional units (having limited numbers of technically qualified staff, or having the only technically qualified staff available in the Company) the flexibility necessary to most effectively accomplish their assigned tasks."
The changes presented prcvides stringent requirements that vill allow the most technically qualified individual available to perform design verification, even if that individual is the designer's supervisor. QA audits will then, annually, assess the frequency, effectiveness and technical adequacy of design verifications performed by designers' supervisors. We believe these changes do not, in fact, reduce the level of control or commitment from that contained in the current revision of CPC-2A.
We nonetheless are requesting your prior review of this change, and will incorporate it into CPC-2A upon receipt of your approval.
GL &&~y Kenneth W Berry Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspectors - Big Rock Pcint & Palisades OC1285-0356-NLO4
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