ML20245H533

Advises That 890519 Changes to QA Program Described in CPC-2A Acceptable.Issues Addressed Listed

ML20245H533
Person / Time
Site:	Palisades, Big Rock Point, 05000000
Issue date:	08/02/1989
From:	Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
References
NUDOCS 8908170161
Download: ML20245H533 (2)

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Docket No. 50-155 AUG - 21983 Docket No. 50-255-

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Consumers Power Company-

' ATTN: David P. Hoffman Vice President Nuclear Operations.

.1945 West-Parnall Road Jackson, MI,49201

SUBJECT:

NRC ACCEPTANCE OF PROPOSED QUALITY ASSURANCE PROGRAM CHANGES We:have completed our review of'your May 19, 1989 letter regarding changes to-the Consumers Power quality assurance (QA) program as described in CPC-2A. The program applies _to both the Big Rock Point Plant'and the Palisades Plant. Our

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review included telephone discussions with personnel of your staff and a 1

comparison of.the proposed QA program with the previously accepted QA program description. Subject to.the clarifications / understandings discussed below, we find the proposed QA program changes acceptable.

Your May 19, 1989Lletter basically addresses five issues:

1.

-Training', qualification, and certification of personnel performing procurement-related QA functions formerly performed by personnel in the QA organization The letter indicates that the QA Department provides training.in QA principles to these people, while qualification,. certification, and the remaining' training is the responsibility of their line organization. We understand that audits / surveillance of this qualification, certification.

and training will be made as part of the Consumers Power ongoing audit /

. surveillance program to ensure that personnel are properly trained, qualified, and certified to perform their assigned duties.

2..

Nonconformance reviews The commitment is.that the QA Department will review "use as is" and

" repair" dispositions, and we understand the review, per procedure, will include the review of the associated acceptance criteria.

3.

Audit and surveillance schedule of procurement related QA functions formerly performed by personnel in the QA organization.

l We understand that Consumers Power will perform audits / surveillance at L

-least semiannually until the new organization's satisfactory performance p

is established.

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2 AUG " 2 1989 4.

Review of plant procedures The commitment to review plant procedures no less frequently than every two: years was clarified to-allow these reviews to be accomplished by:

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(a) a documented step-by-step use of the procedure, or (b) a detailed scrutiny of-the procedure as part of some other activity.

We understand that'your implementing procedure (s) will require that documentation of activities a or b will clearly show whether the question-of revising the' procedure was considered during the activity, with appropriate recommendations being made and followed up.

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Technical Specification audit schedules This proposed change incorporates a previously accepted method of scheduling Technical Specification audits, with only the proposed l

l time period being subject to our review. We understand that each element.of the Technical Specification will be audited at no more than five year 4 intervals.

If an audit uncovers an area of concern or noncompliance, the audit. team will make a recommendation as to the time interval (5 years or less) to the next audit of the element.

.These recommendations will be appropriately considered in the establishment of subsequent audit schedules.

We find, as discussed above, that CPC-2A continues to meet the requirements of 10 CFR 50, Appendix B; therefore the changes are acceptable.

If there are changes to QA commitments existing in docketed correspondence outside CPC-2A, you are-obligated to notify this office.

Any questions you may have concerning this review should be directed to Mr. Monte Phillips of my staff on 312/790-5530.

OMM TGNED BY GE0fffEY C. WNii Geoffrey C. Wright, Chief Operations Branch Division of Reactor Safety Region III cc: Mr. Kenneth W. Berry, Director A. Gody NRR Nuclear Licensing F. Hawkins, NRR Mr. Gerald B. Slade, General Manager J. Spraul, NRR Mr. Thomas W. Elward, Plant Manager L. Tremper, OC/LFMB Mr. Ronald Callen, Michigan PSC A. DeAgazio, LPM, Palisades Plant Michigan Department of Public Health E. Swanson, SRI, Palisades Plant H. Miller, RIII R. Pulsifer, LPM, Big Rock Plant G. Wright, RIII E. Plettner, SRI, Big Rock Plant M. Phillips, RIII 7 T. Vandel, RIII 1

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David P Hoffman l'ke hessdent fiO%fER$NG Nuclear Operatsons ASEN0GAN'S PROGRESS General Offices 1945 West Parnell Road. Jackson, MI 49201. (517) 708 0453 s' PRIORITY ROUT!M May 19, 1989 I'Firtt p[

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H J Miller, Director Division of Reactor Safety Region III 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

CPC-2A, RESPONSE TO NRC LETTER OF APRIL 28, 1989 AhT SUBMITTAL FOR REVIEW OF PROPOSED CHANGES By letter dated October 21, 1988, Consumers Power Company submitted Revision 8 of its Quality Assurance Topical Report, CPC-2A, for NRC review in accordance with 10CFR50.54(A)(3). On February 14, 1989 the NRC reviewer of this submittal requested additional information concerning certain items in Revision 8.

Consumers Power Company responded to these questions in a meeting on February 22

- in the Region III offices, and by telephone discussions thereafter, including a discussion on April 19 during which the probable content of the NRC's April 28, 1989 letter was discussed.

The April 28, 1989 letter describes the changes made in Revision 8 of CPC-2A as affecting four broad areas, and indicates that two of the areas are acceptable, provided that the Quality Assurance organization continues its involvement at previous levels in the other two.

One of these latter areas is the training, qualification, and certification of persons performing " quality related functions" related to procurement, whether they are part of the QA or plant organizations.

The other is the review of procurement nonconformance dispositions to assure acceptability.

With regard to the training, qualification and certification of persons performing procurement quality assurance functions, Consumers Power Company has determined that it is not appropriate for the QA organization to retain complete control of the training, qualification or certification of persons not within that organization. Given that CPC-2A establishes the training, qualification and certification requirements that the line (plant) organization must meet, it is OC0589-0016-NLO2 g g g gggg

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Nuclear Regulatory Commission 2

1 Palisades & Big Rock Point Plants CPC-2A Response May 19, 1989 more appropriate for that organization to control these activities. Consumers Power Company believes that the proper supervisory evaluation of intitial qualifications and continued performance, especially as related to certification and decertification, can best be done by the organization within which each individual reports, and which has responsibility for successfully carrying out the procurement function. However, Consumers Power Company recognizes and shares the reviewer's concern that individuals performing procurement quality assurances functions, in whatever organization they reside, should be made aware of the quality assurance principles related to procurement that form the basis for their decisions and actions. Consequently, Consumers Power Company proposes that CPC-2A be revised to include a new section 2.2.91., that will require the QA organization to provide training in such principles to persons performing procurement.QA functions as part of their initial qualification process. The control of the remaining training, qualification and certification of such individuals will be the responsibility of the organization of which they are part. Attachment I contains the proposed wording of this new section.

With regard to the QA Department review of the disposition of nonconformances, Consumers Power Company agrees that it is appropriate to retain the QA Department review when the disposition recommended is either "use as is" or " repair" and results in deviation from original design or specification requirements.

Accordingly, section 15.2.1 e. of CPC-2A will be revised to provide for this review. Attachment I contains the proposed wording of this section.

Your April 28 letter also indicated that you feel auditing and surveillance of transferred activities should occur no less frequently than semiannually.

Consumers Power Company agrees that such frequency is appropriate, at least until the new organization's satisfactory performance can be established. At that time, the audit and surveillance frequencies would be returned to normal. We have already performed the first of two audits scheduled for 1989, and will continue to perform surveillance of these activities at appropriate intervals.

However, it is our position that CPC-2A need not be changed to require the recommended frequency, since section 18.2.5 already provides for performance of special audits under the conditions involved in these organizational changes.

In addition to the above changes, and in accordance with 10CFR50.54(A)(3),

Consumers Power Company requests the approval of two cdditional changes, described in Attechment 2.

These changes were preser.ted in draft form to the NRC reviewer at the February 22 meeting. The first change concerns periodic procedure reviews, and is based on clarifications included in ANSI Standards published later than those to which Consumers Power Company is committed in CPC-2A.

The second change concerns the frequency and scope of audits conducted to assure compliance with plant Technical Specifications, and is based on guidance l

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Nuclear Regulatory Commission 3

I Palisades & Big Rock Point Plants CPC-2A Response May 19, 1989' j

-contained in NRC correspondence. Attachment 2 presents each change, its reason, and the basis for concluding that the topical report will continue to meet 10CFR50. Appendix B.

David P Hoffman (Signed)

David P Hoffman Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades & Big Rock Point Document Control Deck, Washington Attachment OC0589-0016-NLO2

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ATTACHMENT 1 CPC-2A CHANGES IN RESPONSE TO NRC APRIL 28, 1989 LETTER The following changes or additions are proposed for Consumers Power Company's topical QA report, CPC-2A, to resolve concerns raised in the NRC letter of April 28, 1989 :

1.

Add a new section 2.~.71, as follows, "2.2.91 The Quality As surance Department provides training in quality assurance priaciples related to procurement for those personnel performing procurement quality assurance actions, including review of procurement documents, source verification, and receipt inspection."

2.

Change section 15.2.le, which currently reads:

"15.2.le The Quality Assurance Department verifies through audit or surveillance that, when it is not the original inspection planning authority, the dispositions of 15.2.lb and the alternate acceptance criteria of 15.2.1c are being properly performed and reviewed."

to read:

"15.2.le The Quality Assurance Department reviews "use as is" or " repair" dispositions which result in deviation from original design or specification requirements."

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'AITACHMENT 2

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CHANCES TO CPC-2A REQUIRING PRIOR NRC APPROVAL PER 10CFR50.54(A)(3)

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Basis for Continued Proposed Change Reason for Change Compliance with Appendix B In Appendix A, Part 2:

1) Add a new item 2m., and re-The change is requested to The QA Program, as amended, will number existing 2m through o allow greater flexibility in continue to comply with Criterion

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2m. Sec 5.2.15 how the biennial review req-VI of Appendix B, which requires uirement can be met. It will "... documents, including changes, Requirement allow for followup reviews to are reviewed for adequacy..."

Plant procedures shall be

.be done by persons most like-Section 6.1 of CPC-2A has not reviewed by an' individual ly to notice procedural.in-been changed, and continues to knowledgeable in the area-adequacies, reflect this requirement. ' The i

affected by the procedure change proposed only provides no less frequently than-clarification with respect to bow every two years to deter-a particular ANSI Standard mine if changes are necess-requirement, committed to by ary or desirable.

reference in CPC-2A, can be met.

Thus the QA Program represented 9

by CPC-2A will continue to meet Exception / Interpretation.:

Based"on amp 11fication prov-T Appendix B.

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gidedin. ANSI /ANSj3.2-1982ig4 sseetion,5.2.15, Consumers Power Company interprets that this requirement.for routinefollowupreview'danN b'e[acEi$ipiistiedlitfsev' ra'Ib e

@ys',] including)(Sutlnht[ ?-3 timited toh-documenteda 3 step'-bhstep use'of t1[e pro-u g

[dedur((such'as3Acurswhen theprocedure;hasastep-by step checkoff associated 4<y

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2) Add a new item 3b The change is requested to The QA Program, as amended, will establish scope and frequency continue to meet Criterion XVIII 3b. RC 1.33, Sec Cab controls for audits of plant of Appendix B in that a compre-Technical Specification require-hensive system of planned and Requirement ments. It provides for the periodic audits will be carried The conformance of facility division of Tech Spec require-out to verify compliance, not operations to provisions ments into specific areas, and only with requirements of the QA contained within the tech-the complete coverage of the program, but also with require-nical specifications and entire Tech Specs over a 5 year ments of each plant's Technical applicable license condit-span (maximum). It la consist-Specifications.

ions - at least once per 12 ent with the NRC guidance ref-

months, erenced in the change.

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IBasis for Continued

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Ul Proposeb Change.

. Reason for Change Compliance with Appendix B IO 1

x 1I Exception / Interpretation -

Consistent.with guidance presented in NRC letters

? dated March 29,'1983 (RL-

"Spessard to JMTaylor) and January 30, 1984'(JGPartlow

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..to RLSpessard),LConsumers

• Power Company. interprets the' cormiitment to' audit technic-al specification / license conditions contained in~

18.2.2(a) of this QAPD, and s

,in section 6.5.2.8(a) of-both Palisades and Big Rock 1 U

Point. technical specific-ations, as follows:

. Consumers Power Company main-tains a matrix that identifies alt' applicable Technical Spec-ification line items to be audited. -The matrix is up-dated annually to' conform to approved Technical Specific-

ation changes. During each :

12 month period, a selected sample of line items in each of the following elements is audited --

~ 1. Limiting Conditions for.

Operation

2. Limiting Safety System Settings.

' 3. Reactivity Control Systems

.4. Power Distribution Limits

5. Instrumentation

6. Reactor Coolant System

7. Emergency Core Cooling System

8. Containment Systems

9. Plant Systems

10. Electrical Power Systems

11. Refueling Operations

12. Special Tests

13. Onsite Committee

.14. Offsite Committee 15.~ Administrative Controls Audits are scheduled so that all line' items are covered OC0589-0016-NLO2

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Basis for Continued j.-

Proposed Qunwe Reason for Omnge Compliance with Appendix B

. within a enxian period of 5 years. 'Ihe adit period for any of the above elanents may be reduced depending on Tech-trien1 Specification cocpliance history.

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