IR 05000315/1986043

Ack Receipt of Informing NRC of Actions Taken to Correct Violations Noted in Insp Repts 50-315/86-43 & 50-316/86-43.Violation 1 Re Storage of Radiographs Retracted

ML20212M043
Person / Time
Site:	Cook
Issue date:	03/04/1987
From:	Chrissotimos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Dolan J AMERICAN ELECTRIC POWER SERVICE CORP., INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
References
NUDOCS 8703110040
Download: ML20212M043 (2)

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MAR 4 1987 Docket No. 50-315 Docket No. 50-316 American Electric Power Service Corporation Indiana and Michigan Electric Company ATTN: Mr. John E. Dolan Vice Chaiman Engineering and Construction 1 Riverside Plaza Columbus, OH 43216 Gentlenen:

Thank you for your letter dated February 3,1987, informing us of the steps you have taken to correct the violations that we brought to your attention in our letter dated December 24, 1986. We have reviewed your response and have the following coments about Violation No.1.

1. We agree with your detemination that Violation No. I was not a repetition of a significant condition adverse to quality; however, if during inspection 50-315/86019 and 50-316/86019 we had been cognizant of your decision to procure services for storage of radiographs of safety-related components as non-N, we would have included that finding in the violation as another exacple when procurement of services was misclassified.

2. We believe that 10 CFR 50, Appendix B includes the introduction as well as all 18 criteria. Like you, we also believe that based on the safety significance of an item or activity, certain judgments can and should be made about the actual level of quality needed to assure high quality perfomance or results. In the case of QA records, we believe that Criterion XVII " Quality Assurance Records" certainly applies to storage of radiographs, as well as ANSI N45.2.9-1974 " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," to which you are contaitted. We believe that as a minimum sections 1.3, 5, 6, and 8 of ANSI h45.2.9 specifically apply to the procurement of services for records storage. During inspection 50-315/86C43; 50-316/86043, although not stated in the report, our inspector correctly concluded that your evaluation of the vendor who supplied the service for records storage did not satisfy the elements described in the sections of ANSI N45.2.9 previously discussed.

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3. We agree with your decisions to reclassify radiographs of- safety-related components as being safety-related, and to _ properly review and qualify the services vendor. We also believe the requirements described in Section

'2.5 of your "AEPSC General Procedure No. 4.0" would have been adequate for

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procurement of services if you had assured that the specific sections of ANSI N45.2.9, described above, had been imposed on your vendor.

We retract Violation No.1 described in the Notice of Violation enclosed with Inspection Reports 50-315/86043 and 50-316/86043. As stated in those reports, folicwup of your actions for proper. classification and storage of radiographs will be reviewed in accordance with item 3. above during a future-inspection of-Violation 315/85026-01 and 316/85026-01.

We acknowledge the intense interest that you had in this natter as well .as our mutual telephone and other conversations. We appreciate your cooperation in satisfactorily resolving this matter and we will gladly discuss any questions you may have about the resolution.

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Sincerely, l Original signed by J. J. Harrison (for)

N. J. Chrissotimos, Acting Director Division of Reactor Safety

cc: W' G. Smith, Jr., Plant Manager

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cc w/ltr dtd 02/03/87:

DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Ronald Callen, Michigan Public Service' Connission EIS Coordinator, USEPA

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Region 5 Office

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Nuclear Facilities and Environmental Monitoring Section l

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k-INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 February 3.1987 AEP:NRC:1019 10 CFR 2.201 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 NRC INSPECTION REPORT NOS. 50-315/86043 (DRS)

AND 50-316/86043 (DRS)

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sirs:

This letter is in response to Mr. C. J. Paperiello's letter dated December 24, 1986, which forwarded the report on the routine safety inspection conducted by members of your staff. This inspection was conducted from December 1 through 5, 1986 on activities at the D. C. Cook Nuclear Plant Units 1 and 2. The Notice of Violation attached to Mr. Paperiello's letter identified two violations. The two violations are addressed in the attachment to this letter.

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the signature.

Very truly yours,_

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}) '1-a! t...?tt M. Alexich Vice President SA 4 M3 cm Attachment ec: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman J. G. Keppler, Region III FE85 1987; t

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Atttchment to AEP:NRC:1019 'Page'l

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Inspection Report 50-315/86043; 50-316/86043 NRC Violation No. 1

"10 CFR 50, Appendix B, Criterion XVI, as implemented by the D. C. Cook Operations Quality Assurance Program, requires that conditions' adverse to quality be promptly identified and corrected, and that for significant conditions the cause of the conditions be determined and corrective action taken to preclude repetition.

Contrary to the above, corrective action has not been effective in precluding the repetition _of a significant condition adverse to quality in that procurement of safety-related services was not properly controlled.

Purchase Order No. 90407-040 6N for services to store' radiographs of safety-related components was issued as a non 'N' (not safety-related)

procurement to a company that was not on the ' Qualified Supplier List.'

Two previous incidents of improperly classifying procurement of services as non-safety related were noted in Inspection Reports No. 315/86019 and No.

316/86019 in May of 1986. (315/86043-01; 316/86043-01)."

Response to NRC Violation No. 1 We believe the proper classification of the procurement of services affecting safety-related structures is very important. The classification of Purchase Order No. 90407-040-6N was not done inadvertently. We interpreted our Quality Assurance Program Description (QAPD) to exclude radiographs as safety-related structures, systems, or components which prevent or mitigate the consequences of a postulated accident. We are implementing the actions addressed below to ensure that radiographs are addressed as safety-related. These actions will ensure that the procurement of services related to radiographs will be identified as safety-related.

We believe that the storage of records is very important and that we have fulfilled the applicaole requirements of Criterion XVII of Appendix B to 10 CFR 50. The records that we consider important are those which furnish evidence of activities affecting the quality of structures, systems, or components which prevent or mitigate the consequences of a postulated accident. The fulfillment of the requirements in ANSI N45.2.9-1974,

" Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants," is important in ensuring the preservation of records.

We reviewed the vendor's procedure and concluded that it met the requirements of ANSI N45.2.9-1974. We believe that the vendor's procedure addresses each of the applicable requirements.

Our review of the vendor's procedure was performed prior to the issue of P.O. No. 90407-040-6N, which was issued prior to NRC Inspection Reports 315/86019 and 316/86019.

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a Atttchmint to AEP:NRC:1019 Peg 2 2

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We believe that to interpret our decision, to classify the storage of radiographs as non-safety related, as indicative of ineffective corrective actions is improper. Our decision to classify P.O. No. 90407-040-6N as non-safety related was deliberate and based on our understanding of how 10 CFR 50 Appendix B was to be applied to the storage of records.

Specifically, we believed that if we assured compliance with the applicable parts of 10 CFR 50, Appendix B Criterion XVII, no additional controls were required or needed. The applicable parts of Criterion XVII address maintaining the identification, retrievability and retention of records.

We continue to believe we have met these applicable requirements. Thus, we believe our deliberate classification of radiograph storage is not representative of a programmatic deficiency.

Additional discussion of our understanding of how 10 CFR 50 Appendix B applies to the storage of records is provided below.

Action Taken and Results Achieved We reviewed our decision to classify Purchase Order No. 90407-040-6N as non-safety-related. The decision was based on our understanding of how 10 CFR 50, Appendix B applies to the storage of records.

The Introduction to 10 CFR 50 Appendix B establishes the quality assurance requirements for the design, construction and operation of structures, systems, and components that prevent or mitigate the consequences of postulated accidents. Our belief is that records (radiographs) do not fit the description of a safety-related system, component, or structure.

A requirement of 10 CFR 50, Appendix B Criterion XVII is that sufficient records shall be maintained to furnish evidence of activities affecting quality [of structures, systems, and components]. The Introduction to 10 CFR 50, Appendix B specifies these activities as all those which affect safety-related functions of structures, systems and components.

Furthermore, the Introduction specifies these activities to include designing, purchasing, fabrication, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying [ structures, systems, and components).

The storage of records is not included in the list of the activities affecting the quality of structures, systems or components.

Thus, if (1) a record is not a safety-related structure, system, or component and (2) storage of records is not an activity which affects a safety-related function of a structure, system, or componeht, then there is no requirement to classify the procurement of services to store radiographs as safety-related.

Finally, if the services procured were not safety-related, the supplier (company) is not required to be on the Qualified Suppliers List.

The NRC violation indicates that we should have concluded that the radiographs provide a safety-related function and that the storage of the radiographs is an activity affecting that safety-related function.

Therefore, we should have classified Purchase Order (P.O.) No. 90407-040-6N as "N" (safety-relate,d).

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1At'tachment'to AEP:NRC:1019

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Paga 3 Based on-this NRC position, we.will reclassify our purchase order as "N".

In addition .we are requesting that the vendor, associated with P.O.-No.

90407-040-6N, delineate his' procedure for storing records as a quality assurance program. After we approve'the vendor's QA program, the vendor will be added to our Qualified Suppliers List (QSL).

Action Taken to Avoid Further Violation Our understanding was that radiographs were not safety-related, in that they do not meet our interpretation of safety-related as defined in the-D. C. Cook Quality Assurance Program. Description (QAPD). .Therefore, we will revise our QAPD described in our FSAR to explicitly state that. _

radiographs associated with safety-related structures, systems, or components are in themselves safety-related.

Date When Actions Will Be Achieved Actions will be completed by July 22, 1987 when our next FSAR update is submitted.

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Attcchment to AEP:NRC:1019 JPegs 4

_t-NRC Vio1Ation No; 2

"10 CFR 50, Appendix.B. Criterion V, as implemented by the D. C. Cook Operations Quality Assurance Program, requires _that activities affecting quality be prescribed by and performed per documented instructions or

procedures of a type appropriate to the circumstances, and the appropriate quantitative or qualitative acceptance criteria be included.

Contrary to the above,-Paragraph 4.3.1 of PMI-5040 ' Design Change Control Program,' Revision 7, allowed the responsible department superintendent to waive parts of all of the procedure without limitation or guidance (315/86043-02; 316/86043-02)."

Response to NRC Violation No. 2-During an inspection by the NRC (IE 50-315/86005, 50-316/86005),-the inspector determined that Paragraph 4.3.1 of PMI-5040 did not contain adequate controls regarding the process of waiving steps or sections of the procedure based upon applicability to a particular Design Change. .This was expressed as a programmatic concern and was not the result of having identified any inappropriate application of the waiver provision. Note that the term " waiver" (as used in PMI-5040) was an unfortunate selection of terms. Where " waiver" infers a reduction in applicable requirements, the provision actually is intended and applied as a recognition that not all aspects of our administrative controls apply to all modifications.

Corrective Action Taken and Results Achieved PMI-5040 was revised and paragraph 4.3.1 was changed to delineate what portions of PMI-5040 could not be waived. The revision also required more stringent documentation of the rationale for waiving a particular step or section.

Corrective Action Taken to Avoid Further Violations See above.

Date When Full Comoliance Was Achieved Full compliance was achieved on December 31, 1986, when Revision 8 of PMI-5040 became effective.