ML20062E805

Forwards Advance Copy of Util Response to NRC Request 421.2, QA During Operations Phase, FSAR Subsection 17.2 Re Personnel Training,Staff Changes,Cleaning of Fluid Sys & QA Audit.Response to Be Submitted W/Revision 16 of FSAR

ML20062E805
Person / Time
Site:	Midland
Issue date:	12/08/1978
From:	Howell S CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Boyd R Office of Nuclear Reactor Regulation
References
6201, HOWE-264-78, NUDOCS 7812120154
Download: ML20062E805 (11)

Text

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Stephen H. Howell Senior Vice Presalent General offices: 1945 West Pernail Road, Jackson, Michigan 49201 e (517) 788-0453

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11 December 8, 1975

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Director of Nuclear Reactor Regulation

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Mr Roger Boyd, Director Division of Project Management Ud Nuclear Regulatory Cor. mission Washington,p 20555

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f'm MIDLAND P.0JECP-DOC 10.T No 0-32, 50-330 Br.SPOJSE TO a REQUEST 421.2 FILE: 0505.81T SERIAL: 6201 Attached is an advance copy of Consumers Power Canpany's response to 3RC Request 421.2 on the subject of " quality Assurance During the Operations Phase", FSAR Subsection 17 2.

This response is provided to facilitate staff review and enable Q-2's to be issued in this area.

The attached response vill be submitted with Revision 16 to the Midland Plant FSAR vhich is presently planned to be submitted to the NRC in late December 1978.

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17 2 QUALITY ASSURANCE DURING THE OPERATIONS PHASE The quality assurance program at the Midland Plant is described in Consumers Power Company Topical Report CPC-1A, Revision 7.

Progra=matic changes require NRC approval prior to being implemented. Organizational changes are submitted to the NRC for information witnin 30 days after the effective date of the change.

The NRC, through its series of Regulatory Guides has provided guidance on quality s

assurance as applied during the operations phase. Alternatives / clarification to this quidance is presente4 in the following sections. Whenever an alternative or clarification is presented to a Regulatory Guide (or ANSI Standard endorsed thereby) that al?2raative or clarification is construed to apply for that guide or standard in all cases of direct or indirect reference. In addition, where references do not specify a particular revision of a standard, the revision for which discussion is here presented shall apply. Discussion is based on use of industry accepted definitions for the ter=s "shall", "should", and "may" as they appear in :TRC Regulatory Guides and ANSI Standards endorsed therein.

17 2.1 SUPPLE'E;TAL ALTERNATIVES /CIARIFICATIONS OF REGUIATORY GUTEE 1.8 -

REVISION 1-R ( ANSI N18.1 - 1971)

Personnel selections and training are in accordance with ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel, and with Section 13 of this document, except as noted, a.

Regulatory Position C, paragraph 3, discusses recommendatiens for a Radiation Protection Manager (RPM). I t the selection of a RPM (health physicist), exception may be taken to the recom= ended 3 years profes-sional experience in applied radiation protection work at a nuclear facility dealing with radiological problems. Professional experience time involved in design, analysis, environmental, and other radiation protection verk is considered equally valuable and may be substituted for some of the three (3) year experience in applied radiation protec-tion vork.

As c. minimun, hcwever, one (1) year of experience at a nuclear reacter facility, preferably an LWR, remains a requirement.

b.

The following alternatives / clarifications apply to ANSI N18.1-1971:

1.

Section h.1 (Qualifications-General), Paragraph 5 -

In lieu of the one-years credit allowed by N18.1-1971 for training programs, CP Co shall allow up to two (2) years credit.

2.

Section b.1 (Qualification-General), Paragraph o -

In lieu of the one years credit allowed by N18.1-1971 for on-the-job training CP Co shall allow up to two (2) years credit.

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17.2.1 (Contd) b.

(Contd) 3.

Section k.2.h (Technical Manager) -

In addition to consideration of satisfactory completion of academic training up to a maximum of four years credit, CP Co shall. accept related technical training (in lieu of academic ' training) up to four years.

17 2.2 SUPPLD4 ENTAL ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.28, 6/7/72 The guidance provided by Regulatory Guide 1.28. dated 6/7/72, does not apply to the operations phase.

I 17.2.3 SUPPLDIENTAL ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.30, 8/11/72 (ANSI Nh5.2.4 - 1972) l a.

Regulatory Position C.3 states that the requirements of ANSI Nk5.2.h-j 1972 are "also to be considered applicable for the installation, inspec-I tion, and testing of eletrical equipment during the operations phase...".

' j During operations phase CP Co considers this standard applicable to i

modification activities only, b.

The following alternatives / clarifications apply to ANSI Nh5.2.h-1972 1.

Section 6.2.1, requires that Items requiring calibration shall be tagged or labelled..." CP Co vill not require tagging /

labelling of installed plant equipment, but vill control cal-ibration of IPI via procedural and record control =echanisms.

17.2.h SUPPLD!ENTARY ALTER:!ATIVES/ CLAP.IFICATIONS OF REGULATORY GUIDE 1.33, REVISION 1 (AUSI N18.7-1976)

The following alternatives / clarifications apply to ANSI N18.7-1976:

Section h.3.1 (5) - The requirement for an individual experienced in a.

Nondestructive Testing to be part of the independent review body may not be met.

However, such individuals are available within CP Co should the need for their services be identified.

b.

Section 5.2.2 - Temporary changes shall as a minimum be approved by two members of the plant staff, at least one of which shall hold a Senior Reactor Operators license on the unit (s) affected.

c.

Section 5.2.6 - Temporary modifications shall be controlled by approved procedurcs which shall include, as appropriate, a requirement for verification by the installing group.

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17.2.k (Contd) d.

Section 5.2.7.1 - Malfunction analysis 'shall be limited to significant and/or abnormal occurences involving safety-related items. Testing or design experience as a requirement for replacement items shall be limited to safety-related items.

e.

Section 5.2.19 - Test procedures shall incorporate or reference the requirements and acceptance limits contained in applicable design documents or technical specifications.

f.

Section 5.3.5 (h) - Supporting maintenance documents shall not require the same level of review as operating procedures, but shall receive at least one level of technical review prior to use.

17.2.5 SUPPLEMENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.37 3/16/T3 (ANSI Nk5.2.1-1973)

Regulatory Position C.2 states that the requirements and recommendations of ANSI Nh5.2.1-1973 are also appropriate to cleaning of fluid systems and associated components during the operation phase, and "... should be used when applicable."

During operations CP Co considers the requirements and recommendations of ANSI Nh5 2.1 when appropriate.

17.2.6 SUPPLEMENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.38, REVISION 3 ( ANSI Nh5.2.2-1972)

The following alternatives / clarifications apply to ANSI Nh5.2.2-1972:

a.

Sections 2.1 and 2.2 - In lieu of a specific list of items to which the requirements of N45.2.2 apply, individual procurement documents address the applicability of Nh5.2.2 requirements.

b *. Section 2 7 - Items shall not be classified according to the requirements of oae level, then packaged, shipped, received, stored or handled accord-ing to a level of lover grade, unless a technical evaluation of a particu-lar circumstance indicat-s that temporary or permanent reclassification may be pemissible without undue risk of degradation.

c.

Section 3.2.3 (1) - Criterion (5) of paragraph 3.2.1 vill be applied to level C items where size, type, veight, or other equipment charact-eristics make such application appropriate.

d.

Section 3.6 - The term "non-halogenated" shall mean a material does not contain halogens in such quantities that harmful ccncentrations could be leached or be released by breakdown or contact vith the item under cxpected environmental conditions.

e.

Section 5.h - Tags used to denote status of items shall be securely affixed to the items when practicable.

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h, 17.2.6 (Contd) f.

Section 6.k.1 - Inspections and examinations shall be performed and documented to assure the. integrity of items and containers is being maintained, based on specific considerations which may require such inspection / examination.

g.

Section 6.h.2, items (5), (6), (7) - Energizing of space heaters; insulation resistance tests, and rotating of shafts shall be adminis-tered as recommended or specified by the manufacturer.

h.

Section 6.h.3 - Any item known to have been he'ated to a temperature over 150 F or subjected to smoke contamination, where such could adversely affect its performance. shall be withheld frcm installation or use until its acceptability has been verified.

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i. Section 7.h - Periodic inspections shall be supplemented with special visual, non-destructive examinations, or dynamic load tests prior to handling of items described in Section T.3.4 of the standard.

17.2 T SUPPLDIENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.39.

REVISION 2, (AUSI 345 2.3-1973)

Regulatory Position C.3 states that the requirements included in ANSI Nh5 2.3-1973 are considered to be applicable for housekeeping activities during the operations

. phase that are comparable to those during the construction phase, C? Co applies the requirements of A'!SI Uh5.2.3 to such operations phase activities except that in lieu of five zones required by paragraph 2.1, CP Co utilizes four zones for cleanness control. These are classified as:

Class I -

Shall be utilized when opening systems requiring an extraordinarily high level of cleanliness. A posted boundary shall te established to isolate the critical work area, and an interface region shall be set up to pro-vide an interface area where protective clothing is donned and removed.

An access watch shall be stationed and maintained for tool and equipment accountability, if designated. A source of filtered air or other atmos-phere control equip =ent shall be delied (if practical). No eating, drinking or smoking shall be permined inside the interface region or beyond. Personnel entering the area shall remove all loose articles and don protective clothing as required. Coveralls., shoe covers, head covers and gloves are required where no conflicting radiological pre-cautions are prescribed. The area shall be kept free of dirt and extra-neous material generated from any source.

Class II -

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Shall be utilized when opening the Reactor Coolant System and other system, such as !!akeup and Purification, whi.:h have Class I system cleanliness re-quire =ents.

The restrictions involved are essentially the same as Class I except that: Street clothes may be removed, special ventilatien supply =ay be unfiltered, tools and equipment brought into the area are not ' required to meet the cleanliness level of the open systems inside the boundary, and access watch may be used.

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l 17.2 7 (Contd)

Class III -

Shall be utilized when working on Class II or Class III system where only a nominal degree of area cleanliness is required. Areas should be maintained reasonsble free of foreign materials (such as, trash and scrap materials that can be removed by hand) and should have orderly placement of work materials. Additional measures such as establishment of specific boundaries, use of shoe covers and tools accountability may be required at the direction of the co6nizant department head.

Class IV -

Shall be utilized in work areas and general plant areas which must be kept sufficiently clean and orderly so that activities can proceed in an efficient manner that maintains quality and safety. When accumulations of materials occur, such as during =ajor maintenance periods, the materials should be neatly and promptly stered. Trash, scrap, litter and other excess materials should be collected and disposed of regularly to prevent undue accu =ulation.

Smoking restrictions shall be invoked where posted.

The restriction list of paragraph 2.1 is therefore also modified as-RESTRICTION LIST I

77 777 77 Clothing change YES NO NO NO Clean gloves, shoe covers, YES YES NO No head covering, coveralls Filtered air NO NO NO

}faterial preeleaning NO N0 30 Material accountability NO Personnel accountability NO No use of tabacco or YES YES YES (where posted) eating l

eDesignated if required l

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17 2.8 - SUPPLE 4ENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDF 158 8-73 (ANSI Nh5.2.6-1973)

The following alternatives / 'arifications apply to ANSI Nh5.2.6-1973:

s.

Section 1.1 - The qualification requirements of Nh5.2 6 are not inter-preted as applying to personnel who merely handle, read, use or file -

l test reports and test data (eg, as records). Control and handling of reports and records may be accomplished by non-certified personnel, provided that other phases of the activity, including evaluation of results, are accomplished by appropriately certified personnel, f

b.

Section 1.2 - CP Co interprets 1.2 to allow that personnel selected and qualified in accordance with Regulatory Guide 1.8 (318.1-1971),

as implemented by CP Cc, need not also be certified under the require -

ments of Nh5.2.6.

c.

Section 2.2 3 - In lieu of the 2 year evaluation of perfor ance required by Nh5.2.6, CP Co shall provide evaluations of performance to coincide -

with the period of valid certification.

d.

Table 1 - When so trained and qualified Level I individuals may be certified to report inspection / test results (but not to evaluate or disposition).

17 2.9 SUPPLE 4ErfARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.6h, REVISION 2, (ANSI Nh5.2.ll-197k)

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Regulatory Position C.2 provides several guidelines regarding personnel who per-form design verification. At CP Co design verification may be performed by the originator's supervisor provided the supervi'aor did not specify a singular design approach, did not rule out certain design considerations, and did not establish the design inputs, or if the superviser is the only individual in the organization competent to perfor= the verification. Justification for use of superviscry verification shall be documented alcng with the extent of the supervisors input into the design aspect being verif.tl.

l 17.2.10 SUPPLE 4ENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.Th, 2-7h (ANSI Nh5.2.10-1973)

CP Co co= nits to the guidance provided by Regulatory Guide 1.7h, dated February I

1974, except as modified by CPC-TA Policy 2.

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17.2.11 SUPPLE 4ENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.88, REVISION 2, ( ANSI Nh5.2.9-1974)

The following alternatives / clarifications apply,to ANSI Nh5.2.9-197h:

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17 2.11 (Contd')

Section h.3 - Control of temporary storage vill not incorporate a a.

formal receipt control system for those records not transmitted outside the organization originating the record being temporarily stored.

b.

Section 4.3 (1) and 5.3 (h) - Procedures shall designate records that,

may be required to document particular activities, and provisions shall l

be made in such procedures to verify completion of required records E

prior to transmittal to the storage facility.

Section 5.3 (3) - Provisions for receipt verification are included in c.

procurement documents when externally generated (supplier) records are required. Internally (CP Co) generated records are transmitted via in-ternal mail systems nos requiring formal rpeeipt verification.

d.

Section 5.6 - In lieu of the four ' hour minbnwn fire rating required by Nh5.2 9, the CP Co permanent record storage facility has a two hour 7

fire rating.

e.

Section 5.7 - This section discusses " audits". It is, hcVever, clear that the activities discussed are not audits as defined by Nh5 2.10, but rather constitute a type of surveillance. As such, the activities required by Section 5 7 may be carried out by other than independent or Quality Assurance personnel. Periodic audits, as defined in Uh5 2.10, shall be performed cf the records management system.

17.2.12 SUPLE!C;TARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.9h, REVISION 1 (ANSI Nh5 2 5 1974)

Regulatory Position C states the requirements and guidelines of ANSI Uk5.2 5-197h are applicable to the construction phase of nuclear power plants. During the operations phase CP Co applies these requirements as appropriate to safety-related modifications involving activities similar in scope and extent to those I

covered by Nh5 2 5 I

17 2.13 SUPPLE:ErrARY ALTERNATTIES/ CLARIFICATIONS OF REGULATORY GUIIE 1.116 REVISION 0-R (ANSI Nh5.2.8 - 1975)

Regulatory Position C.2 states that the requirements of ANSI Nh5.2.8-a.

1975 "should be followed for tho=e applicabic operatiens phase activities that are comparable to activities occurring during the construction phase,"

CP Co considers applicable operations phase activities to be =odifications involving installation, inspection and testing of safety-related =ech-anical equipment.

b.

The following alternatives / clarifications apply to ANSI N45.2.8-1975:

1.

Section 2.8.2 - Where size or functional characteristics of measuring and test equipment preclude labelling, appropriate alternato measures shall be developed and documented.

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'2.

Section 2 9 (d) - Engineering limitations, as applicable, shall have been incorporated or referenced in procedures and instructions pr'ior to applying the requirements of Nh5.2.8.

3.

Section 2.9 (e), (2), (3), and (k) - The applicability of requiring equipment specifications or installation instructions and procedures is dependent on the complexity, degree of stand-ardization and importance to safety of the item being installed.

h.

Section 2 9 (e) (5) - Evidence of com'pliance by manufacturer with purchase requirements, including quality assurance requirements, shall be required prior to use of the item, but not prior to applying the requirements of Nh5.2.8.

5 Section 3.5 - Inspections or checks shall be performed to

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verify items a. through h., as appropriate to the system, component, or item being installed. Other appropriate con-cerns may also be verified.

6.

Section 5 1 - Checks or inspections shall be performed to verify items a. through 1., as appropriate to the system, component, or item being installed. Other appropriate concerns may also be verified.

7 Section 5.2 - Preoperational testing shall include items a.

through o., as appropriate. Other appropriate testing may also be performed.

8.

Section 5.h - Hot functional testing following modification activities shall verify items a. Through s., as appropriate to the system, component, or item installed. Other appropriate parameters may also be verified.

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9 Section 6 - Nh5.2.8 seems to require a separste report of data analysis and evaluation in support of docenented test results (which include determination of acceptability) and inspection and test data. CP Co shall provide inspecticn and test results, and evaluation thereof as required by Section 7.

Separate data analysis may also be provided, as appropriate.

17.2.1h SUFFLDIENTARY ALTERNATIVES / CLARIFICATIONS OF REGULATORY GUIDE 1.123, REVISION 1 (ANSI Nh5.2.13-1976)

The following alternatives / clarifications apply to AN3I Nk5.2.13-1976:

Section 3 2.2 of ANSI Nh5.2.13-1976 requires that, "all such technical re-a.

quirement documents shall be prepared, reviewed and released under the requirements established by ANSI Nh5.2.ll."

This is interpreted to apply to equi; ment specifications and drawings. The procurement of spare parts vill also require the stecification of technical requirements. In some cases 9

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17.2.14 (Contd) a.

(Contd) this vill be accomplished via referencing the oriSinal equipment specifica -

tions and drawings. Where adequate specific information is not available for a particular spare part, an engineering evaluation vill be made in accordance with ANSI N18.7-1976, Section 5.2.13, and a review will be per-formed for adequacy of the procurement requirements as specified in Section 3.3a.

An independent technical review as required by ANSI N45.2.ll vill not be' performed.

b.

Section 3.2 3 of ANSI Nh5.2.13-1976 states that, " Procurement documents shall require t.ac the Supplier have a documented quality assurance pro-gram that implements portions or all of ANSI Nh5.2 as well as applicable quality assurance program requirements of other nationally recognised codes and standards". The preceeding statement infers a =inimum require-ment of involving a portion of ANSI Nh5.2. Where the original item or part is found to be commercially "off the shelf", or without specifically identified QA requirements spare and replacement pcrts may be similarly' procured but care shall be exercised to assure at least equivalent per-formance. In those cases where the QA requriements of the original item cannot be determined, an engineerin6 evaluation shall be conducted.

c.

Section 10.3.h - CP Co shall establish post-installation test requirements as appropriate, and shall consider recommendations of suppliers, 17 2.15 SUPPLDENTARY ALTERNATIVES /CLARIFICATICNS OF ANSI Nh5.2.12, DRAFT h, REVISION 1, twIDGER 197h a.

ANSI N18.7-1976 refers to Draft h,* Revision 2 of Uh5.2.12 for require-ments for auditing. In lieu of this draft, CP Co has previously

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committed to Draft k, Revision 1, and retains said commitment.

b.

The following alternatives / clarifications apply to Uh5.2.12, Draft h, Revision 1:

1.

Sections 2.2, 2.3 and 2.h-The qualification, training, and certification of CP Co QA audit personnel are performed in accordance with ANSI Nh5 2.23, Draft 3. Revision 1,14ay 1975 2.

Section 3 5.2 - In lieu of annual audits, CP Co complies with the requirements of ANSI U18.7-1976, Section h.5, for audit frequency. In addition,' technical specification requirements j

may affect frequency of audits of selected program elements.

3 Section h.2.1 - The requirements identified in the individual audit plan may not be specified in detail, but adequate reference to their source shall be provided. Checklists are normally developed after the individual audit plan is finalised, and using it as cuidance.

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17 2.15 (Contd) h.

Section h.5 1 and h.5.2 discuss written responses to the audit report and assuring the corrective action is identified, scheduled and completed as scheduled. Identification, schedul-ing and completion of corrective action associated with audit findings is accomplished via the Deviation Reporting and Correc-tive Action system. Efforts to close out an Audit Report based upon close out of the associated Deviation Reports is not current-ly required by the CP Co QA Program. Confirmation of corrective action is accomplished during the next scheduled audit of that area and activity.

Revise the following Sections in Appendix 3A to read as below:

1.8 page 3A-10 1.28 sge 3A-37 1.30 Page 3A k0 1.33 page 3A h5-1 74 page 3A-106 BespT.s e The degree of ecmpliance with Regulatory Guide 1.XX for Midland Units 1 and 2 is as contained in Section 17.

E' Revise paragraph 13.2.1 (a) (2) on page 13.2-1 to add:

" Individuals in training or apprentice positions are permitted to perform vork for which qualification has baen demcnstrated."

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