ML20247D563
| ML20247D563 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 05/19/1989 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| CPC-2A, NUDOCS 8905250471 | |
| Download: ML20247D563 (7) | |
Text
-
CODSumBIS L
POWBr o.vio e no Vice President MER$M Nuclear Operations nlKNWnAN'E Mt0GRl55 General Offices: 1945 West Parnall Road, Jackson, MI 49201 + (517) 788-o453 May 19, 1989 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 AND SUBMIITAL 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 reseanded 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 er 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 DC0589-0016-NLO2 1
Es2gggggggs y g P
' A CAGENG72GYCOMPANY
Nuclear Rsgulatory Commission 2
l Palisades & Big Rock Point Plants i
CPC-2A Response May 19, 1989 more appropriate for that organization to control these activities.
Consumers l
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 2.2.9 1.,
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 CFa-2A will be revised to provide for this review. Attachment 1 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 additional changes, described in Attachment 2.
These changes were presented 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 Standarde 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 OC0589-0016-NLO2 l
Nucisar Regulatory Commission 3
Palisades 6-Big Rock Point Plants CPC-2A Response May 19, 1989 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 Vice President Nuclear Operations CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades & Big Rock Point Document Control Deck, Washington Attachment l
OC0589-0016-NLO2 c
=
a
~
l 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 2.2.91, as follows, "2.2.91 The Quality Assurance Department provides training in quality assurance principles related to procurement for those personnel performing procurement quality assurance actions, including review of procurernent 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.lc 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."
4 OC0589-0016-NLO2
l l'
1 1
ATTACHMENT 3 CllANCES 2D CPC-2A REOUTRING PRIOR NRC APPROVAL PER 10CFRSO.54(A)(3)
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 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 sdequacies.
reflect this requirement. The affected by the procedure change proposed only provides no less frequently than clarification with respect to how 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 Exception / Interpretation by CPC-2A will continue to meet Based on amplification prov-Appendix B.
ided in ANSI /ANS 3.2-1982, section 5.2.15, Consumers Power Company interprets that this requirement for routine followup review can be accomplished in several ways, including (but not limited to): ccrumented step-by-step use of the pro-cedure (such as occurs when the procedure has a step-by-step checkoff associated with it). or detailed scrut-iny of the procedure as part of a documented training program, drill, simulator exercise, or other such act-ivity.
- 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 C4b 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 is consist-Specifications, ions - at least once per 12 ent with the NRC guidance ref-months.
erenced in the change.
OC0589-0016-NLO2 1
.\\
p l
l
(;
Basis for Continued l
l Proposed Change Reason for Change Compliance with Appendix B l
Exception / Interpretation Consistent with guidance
. presented in NRC letters dated March 29, 1983 (RL Spessard to JtGaylor) and January 30, 1984 (JGPartlow to RLSpessard), Consumers Power Company interprets the commitment to audit technic-al specification / license conditions contained in 18.2.2(a) of this QAPD, and in section.6.5.2.8(a) vf l
both Palisades and Big Rock Point technical specific-ations, as follows:-
Consumers Power Company main-tains a matrix that identifies all 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 j
- 8. Containment Systems
- 9. Plant Systems
-10. Electrical Power Systems
- 11. Refueling Operations
- 12. Special Tests
- 13. Onsite Committee 34.' Offsite Committee
- 15. Administrative Controls Audits are scheduled so that
)
all line items are covered j
OC0589-0016-NLO2
.~
Br. sis for Continuzd Proposed Change Reason for Change Compliance with Appendix B within a maximum period of 5 years. The audit period for any of the above elements may be reduced depending on Tech-nical Specification compliance history.
OC0589-0016-NLO2