ML20205M332

Updates 850830 Response to NRC Re Violations Noted in Insp Rept 50-155/85-10.Nuclear Operations Dept Stds Changed to Delete Obsolete Refs Approved by Stds Mgt Steering Committee on 850926

ML20205M332
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/26/1985
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8604150187
Download: ML20205M332 (3)

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Company a-Nuclear Ucensing General Offees: 1945 West Parnall Road. Jackson. MI 49201 e (517) 788-1636 December 26, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

UPDATE TO RESPONSE TO IE INSPECTION REPORT 85-10 Inspection Report 50-155/85-10 dated August I, 1985 identified one Unresolved Item, No 155/85010-03, resulting in three recommendations. Consumers Power Company's response was contained in our August 30, 1985 letter. This letter updates progress with regard to commitments made therein, and identifies additional actions that further consideration has shown would be beneficial.

NRC recommendations resulting from unresolved item 155/85010-03 and our original and updated responses are as follows:

NRC Concern

1. The licensee should perform an immediate and in-depth review to identify any case where a cancelled Nuclear Operations Department Standard (NODS) is required as a "use" reference. In those cases, immediate corrective action should be taken.

l August 30, 1985 Response To date, all N0D Standards have been thoroughly reviewed for references to cancelled NODS. As of August 8, 1985, all sponsors of those NODS identified above have been contacted both verbally and by memo to delete the obsolete i references and to revise their standards accordingly within 30 days. Upon approval of the resultant changes (anticipated to be prior to November 1, 1985), subsequent notices will be sent to all departments / plants to delete the noted references from all department / administrative procedures.

8604150187 851226 FDR G

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Jame's G Keppler, Administrator 2 Big Rock Point Plant Update to Response to IEIR 85-10 December 26, 1985 The necessary revisions to remaining NODS which may have been impacted by the addition of QA Program requirements from cancelled NODS, and a verification that the Big Rock Point Plant APs include the QA Program requirements of cancelled NODS, will be completed by January 1, 1986.

Updated Response The changes necessary to NOD Standards to delete obsolete references were approved by the Standards Management Steering Committee (SMSC) on September 26, 1985, and were issued November 1, 1985. Notices were then sent to departments / plants to delete the cancelled Standards as references in department / administrative procedures. Revisions to the remaining NODS impact-ed by addition of QA Program requirements from cancelled NODS were approved by SMSC on December 10, 1985, and will be issued by January 1, 1986.

The updated response to the second NRC Concern, below, identifies the status of actions regarding Big Rock Point Administrative Procedures.

NRC Concern

2. The revision to the Quality Assurance Requirements Matrix (QARM) should be given a high priority.

August 30, 1985 Response As indicated in discussions with the members of your staff, Consumers Power believes that the QA Program requirements contained in the cancelled N0D Standards are, and continue to be, addressed in the appropriate Big Rock Point APs. However, to provide additional assurance that this is so, the following actions have been or will be taken:

1. The QARM data for each cancelled NODS will be reviewed by October 1, 1985 and the requirements re-indexed, either to another NODS, or the APs.

2. A review will be made of the Big Rock Point APs relative to the QA Program requirements identified from the cancelled NODS, to specifically identify the AP which satisfies each of these requirements. This data will be included in the QARM which will be revised by January 1, 1486.

Updated Response

1. The QARM data for each cancelled NODS was reviewed, reindexed as indicat- )

ed, and re-entered into the data base by October 1, 1985. This data was i then used to assist in preparation of the NODS revisions that were ap- l proved on December 10.

2. At the time this commitment was made Big Rock Point had also started a program to completely reorganize its APs into a more useable structure.

It was hoped this task could be completed by January 1, 1986. However, the length of the refueling outage, and the forced outages thereafter have significantly affected the plant's ability to devote resources to the AP OC1285-0355-NLO4 I

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Jamds G Keppler, Administrator 3 Big Rock Point Plant Update to Response to IEIR 85-10 December 26, 1985 program. In addition, since the number of requirements involved in the original response is less than 12% of all requirements in the QARM, Plant Management has determined that a more appropriate response should involve verification that the reorganized APs meet all applicable requirements identified in the QARM. .Therefore, the QARM will not be updated by January 1, 1986 to include data regarding Big Rock Point APs. Instead, the QARM will be used during the preparation and review of the reorganized APs, and will be updated as procedures are approved for use. Reorganized APs will be completed and issued, and the QARM will be updated by August 1, 1986.

NRC Concern

3. The licensee's audit and trending programs should be augmented on a temporary basis to focus on these changes to determine if they have impacted the safety of facility operation.

August 30, 1985 Response Each Lead Auditor has been instructed to pay particular attention to deleted j NOD Standards as they relate to assigned audit subject matter. The audit i

teams will verify the inclusion of necessary program requirements in other 1 program documents (ie, Plant Admins, other NODS). This review will be done on a sample basis during the normal cycle of audits for each scheduled audit impacted by a deleted NOD.

Updated Response There is no change to this response.

These additional actions regarding Big Rock Point APs provide even greater assurance than our original response that QA requirements will continue to be properly addressed within the system for administrative controls.

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Kenneth W Berry l Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point 1

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