ML18059A510
| ML18059A510 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/12/1993 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9311300062 | |
| Download: ML18059A510 (9) | |
Text
POW ERi Nii MICHlliAN"S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Coven. Ml 49043 November 12, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 GB Slade General Manager DOCKET 50-255 - LICENSE DPR PALISADES PLANT - REPLY TO NOTICE OF VIOLATION; NRC INSPECTION REPORT 93013 - REVISION 1 NRC Inspection Report No. 93013, dated September 3, 1993, forwarded the results of an NRC inspection conducted to review the relationship recent events had, if any, with the peer inspection process.
The inspection report identified an apparent violation of NRC requirements where peer inspections were not properly implemented to provide independent verifications.
The reply to the notice of violation was sent in a letter dated October 4, 1993.
Attached is an update to that violation response.
Any changes to the text are denoted by a line in the margin.
~~__,,/-
Gerald B. Slade General Manager CC:
Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachment 3onn.L2 931112.
9311 vvu 05000255
~DR ADOCK PD~:~.
A CMS NC1?GY COMPANY
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ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 REPLY T6 ~OTICE OF VIOLATION NRC INSPECTION REPORT No. 93013 REVISION 1 November 12, 1993 7 Pages
Violation REPLY TO NOTICE OF VIOLATION REVISION I During an NRC inspection on June 14 - July 30, 1993, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy *and Procedure for the NRC Enforcement Actions, "JO CFR Part 2, Appendix C, the violation is listed below:
I JO CFR 50, Appendix X, "Inspection," requires, in part, that a program for inspection activities affecting quality shall be established and executed to verify conformance with documented instructions, procedures, and drawings.
In addition, such inspections are required to be performed by individuals other than those who performed the activity being inspected.
Section 10.2.2 of the licensee's "Quality Program Description for Operational Nuclear Power Plants." CPC-2A, dated June 15, 1993, states inspections are applied to maintenance activities to verify conformance to specified requirements.
In addition, Section _10.2.2 of CPC-2A states independent verification is performed at each oper.ation where it is necessary to verify conformance with NRC requirements.
CPC-2A commits the licensee to Regulatory Guide 1.116, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems," dated June 1976, which in turn, endorses ANSI N45.2.B-1975, "Supplementary Quality Assurance Requirements for Installation, Inspection and Testing of* Mechanical Equipment and Systems For The Construction Phase of Nuclear Power-Plants." Section 4.4 of ANSI 45.2.8-1975, states inspections of work in progress shall be performed to verify that mechanical items are being located, installed, assembled and connected in compliance with the latest approved instructions and procedures.
Section 4.4 of ANSI N45.2.B-1975, further states that "leveling and alignment" is an item for which inspections sha 77 be performed, as appropriate.
Contrary to the abpve, on June 16, 1993, the inspection of an auxiliary feedwater pump alignment, an activity which*affected quality, was performed by the same individual who performed the alignment.
This is a Severity Level IV violation (Supplement I).
Reason for the Violation The reason for the violation was that we did not prbperly translate our inspection commitments into our inspection procedure.
The pl_ant quality verification program procedure allowed a double verification to be performed on a pump alignment activity rather than an independent verification.
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2 Administrative Procedure 5.23 (AP 5.23), "Quality Verification Program," was developed to implement the quality program for the Palisades plant.
The Quality Verification Program uses a combination of non-independent peer inspections called "double verification," and independent peer inspections, called "independent verifications." Independent verifications of certain work activities are performed when required by procedure and when required to meet the regulatory requirements.
Double verifications are used as a management tool to focus on various performance areas and to instill a sense of commitment and ownership in the hands on worker at the plant.
The Consumers Power Company's Quality Program Description for Operational Nuclear Power Plants, CPC-2A, contains the commitments to the Regulatory Guides and ANSI documents which are the basis for Consumers Power Company's quality program.
As an example, CPC-2A commits to Regulatory Guide 1.116, "Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems," which endorses ANSI N45.2.8, "Supplemental Quality Assurance Requirements for Installation, Inspection and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants." Regulatory Guide 1.116 states that the ANSI N45.2.8 requirements provide an adequate basis for complying with pertinent quality assurance requirements of Appendix B to 10 CFR Part 50.
Regulatory Guide 1.116 also states that the requirements of ANSI N45.2.8 are considered applicable during the operations phase as well as the construction phase and should be followed for those applicable operations phase activities that are comparable to activities occurring during the construction phase.
CPC-2A also commits to Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operation),"
which in turn endorses ANSI Nl8.7.
ANSI Nl8.7 also endorses ANSI N45.2.8 and states that the ANSI standards provide useful 9uidance concerning design and construction related activities associated with modifications and shall be applied to those activities occurring during the operational phase that are comparable in nature ~d extent to related activities occurring during initial pl~nt design and construction.
ANSI N18.7 further states that considerable care is required in assessing which operational phase activities are comparable in nature and extent to activities normally associated with design and construction.
Administrative Procedure 5.23 (AP 5.23), "Quality Verification Program,"
translates to the Palisades verification planners the direction and guidance of our commitments on when verification of work activities are required and what kinds of verifications are needed. to AP 5.23 is entitled, "Independent Verification Activity List," and contains descriptions of five types of activities which require "independent verifications." Attachment 2 to AP 5.23 is entitled, "Quality Verification Activity List," and contains a list of activities which shall be considered for "verification."
The previous Quality Control Inspection Program inspection lists provided the basis for developing Attachment 1 and Attachment 2 of AP 5.23.
Under the Quality Control Inspection Program there were two inspection lists, one for hold points and one for notification points.
The perceived application of these lists was that hold point inspections were required and would be done
li every time.
Notification points were not necessarily required as the nature and extent of the work would determine when inspections were necessary.
Notification point inspections could be waived in the field by the QC inspector. This philosophy was adopted in the new quality program verification lists, Attachment 1 and 2 of AP 5.23. The.activities identified on Attachment 1 to AP 5.23, were considered required and therefore they were independently verified.
The activities identified in Attachment 2 to AP 5.23 were to be considered for verification based on the nature and extent of the work, but were not necessarily required.
However, certain activities that were translated into Attachment 2 of AP 5.23 should receive independent verifications consistent with our program commitments, and this was not made clear in our program procedure.
The incorrect translation of requirements from the previous quality program to the new quality program through the development AP 5.23 resulted in a situation where something less than an independent verification could be performed for a required inspection.
Therefore, as stated in the example for the above noted violation, following the alignment of an auxiliary feedwater pump the plant quality verification program procedure allowed a double verification to be performed on the pump alignment activity rather than an independent verification.
In spite of this lack of precise guidance in AP 5.23, it is noted that since the implementation of the Quality Verification Program (January 1, 1993),
approximately 600 independent verifications have been performed.
Approximately 325 of those verifications were performed because the procedure directed that independent verifications were required, while the other 275 verifications were~specified because it was judged that the nature and extent of the work was such that an independent verification was warranted.
Corrective Actions and Results Achieved No equipment specific corrective actions were required.
The alignment of the auxiliary feedwater pump was completed properly and the pump was declared operable following successful post maintenance testing.
Notification has been sent to all verification planners, maintenance supervisors, and system engineers that independent verifications are required whenever safety related pump leveling and alignments are made.
Corrective Action to Avoid Future Non-Compliance To correct the deficiency with the Palisades Quality Verification Program we have reviewed and evaluated the quality verification program and identified appropriate changes to AP 5.23, "Quality Verification Program." Revisions have been made to the procedure that will focus on regulatory compliance with respect to application of independent verification.
The revised AP 5.23 was issued on November l~ 1993 with revisions designed to:
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- 1.
Clarify sufficiently that only independent verification can be used to satisfy regulatory requirements for inspection.
The following statement was added in the definition section of the procedure where independent verification is being described (section 5.3 of the procedure).
"Only independent verification satisfies CPCo's commitment to 10 CFR 50 Appendix B Criterion X for inspection."
Also in the implementation section of the procedure where the determination is being made as to what kind of verification will be applied to the work activity, a note has been added as a reminder that"... Only independent verification satisfies CPCo's commitment to 10 CFR 50 Appendix B Criterion X for inspection."
- 2.
Provide additional guidance on when independent verification shall be designated to meet regulatory requirements.
Paragraph 8.1.7 of the procedure now states that the planner should conduct an evaluation to determine if any regulatory requirements warrant independent verifications. This paragraph also gives.guidance for conducting the evaluation by providing a list the planner should consider as a minimum, on when independent verifications are required to meet regulatory requirements.
One of the documents given in the list as a tool for the planner is Attachment 1 to the procedure, "Quality Verification Activity list." Certain sections of Attachment 1 have been annotated to show that they were taken specifically *from ANSI standard N45.2.8, "Supplemental Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants," Section 4.0 Inspection. These activities have also been appropriately referenced in the electrical, I&C, and mechanical areas of the attachment.
Those activities that the planner has determined ar~ comparable in nature and extent to the construction activities are also independently verified.
(see Number 5 below)
Paragraph 8.1.10 of the procedure provides a table which serves as a method for the planner to check their thought process used in making the determinations for independent verification.
- 3.
Clarify when double or self verifications may be used to enhance the overall effectiveness of the quality verification program and to ensure that these verifications will not be used in place of independent verification.
In the definitions section of the procedure (Section 5), the following statements have been added to the definitions of both worker verification and double verification (Paragraphs 5.4 and 5.5 respectively), "... Double Verification or Worker Verification should be used to supplement the quality program and shall not be designated in place of a required Independent Verification."
5 In the responsibilities section of the procedure (Section 6.0),
under the listing of responsibilities for the verification planner, a requirement has been added that the planner determine non-regulatory double or worker verifications necessary to enhance the overall effectiveness of the quality verification program.
Both the definition and responsibility area of the procedure reinforce that worker or double verifications only enhance the overall effectiveness of the program.
Much of the procedure ensures that the planner knows that independent verifications must be used to satisfy regulatory guidance, and helps determine which activities regulatory guidance applies to. If the planner determines that independent verification is not required, then, based on the guidance given in the procedure and by management, the planner should decide which*
activities will have worker or double verifications applied.
- 4.
Reference and identify applicable ANSI standards that we are committed to by CPC-2A "Consumers Power Company's Quality Program Description for Operational Nuclear Power Plants."
The procedure now acknowledges the following additional ANSI documents as source or reference documents:
ANSI N45.2.4-1972, "Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations,"
ANSI N45.2.5-1974, "Supplemental Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," and ANSI N45.2.8-1975, "Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants."
- to the procedure is entitled, "Quality Verification Activity List." This attachment lists typical areas where verification may be needed and specifically annotates those items on the ~ctivity l.ist which were taken directly from ANSI N45.2.8.
6Property "ANSI code" (as page type) with input value "ANSI N45.2.8.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.
- 5.
Provide guidance for determining when maintenance activities are comparable in nature and extent to that of original construction phase activities and on the application of construction phase ANSI standards.
Section 8.0, "Quality Verification Activities," paragraph 8.1.4 cautions the planner that maintenance and modification activities or tasks should be carefully evaluated to determine if they are comparable in nature and extent to that of the original design and construction to ensure that appropriate independent verifications are performed.
Examples of major maintenance or modification activities that are and are not comparable in nature to construction activities are provided following the caution statement.
The procedure also states that if the verification planner has trouble in determining if an activity is comparable in nature and extent to a construction activity, then they should consult with the appropriate maintenance superintendent for help in making that determination.
- 6.
Clarify the application of generic verification activities such as those contained in the quality verification program implementation procedure, AP 5.23, Attachment 1, "Independent Verification Activity List," and Attachment 2, "Quality Verification Activity List," by combining them into one attachment and providing additional guidance
- in their application.
The procedure now contains one attachment that is entitled "Quality Verification Activity List." The attachment contains two sections. Section 1.0 is a listing of typical work activities where verifications may be needed.
Typical work activities that were taken directly from the ANSI standard N45.2.8 are so noted.
Section 2.0 of the attachment is entitled, "Specific Activities or Tasks Where Independent Verification Applies." This is an expanded list of specific activities that we have pre-determined to always require independent verification and includes *activities taken from the ANSI guidance such as"... torquing of pressure retaining boundaries and alignment of safety related pumps."
Training on the.procedure revisions for the majority of the electrical, instrument and control, and mechanical maintenance work order planners, who are also qualified verification planners, has been completed.
Training for the remaining work order planners will be completed in November 1993.
Training on the procedure rev1s1ons for all currently qualified quality verification planning personnel other than the maintenance verification planners will be completed in April 1994.
Date of Full Compliance Full compliance has been met.
Notification was sent to all verification planners, maintenance supervisors, and system engineers to inform them that independent verifications are required whenever safety related pump leveling and alignments are made.
This notification was completed to assure that compliance would be maintained as work continues under our maintenance and modification programs.
7 Follow-up programmatic changes resulting from our reviews of this event were also identified to strengthen the overall independent inspection process for.
the Palisades Plant. The revised AP 5.23, issued on November 1, 1993, contains these changes.