IR 05000315/1987022
| ML17334B155 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/07/1987 |
| From: | Jablonski F, Reynolds S, Tella T, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17334B153 | List: |
| References | |
| 50-315-87-22, 50-316-87-22, NUDOCS 8710130398 | |
| Download: ML17334B155 (15) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/87022(DRS);
50-316/87022(DRS)
Docket Nos.
50-315; 50-316 Licenses No.
American Electric Power'ervice Corporation Indiana Il Michigan Power Company'
Riverside Plaza Columbus, OH 43216 Facility Name:
D.C.
Cook Nuclear Plant, Units 1 and
Corporate Office, Columbus, Ohio Inspection At:
D.C.
Cook Site, Bridgman, Michigan Inspection Conducted:
June 16 through July 2, 1987 Meeting Conducted:
eptember 17, 1987 n,
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Inspectors:
H. <A.
W lker
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/'ate g/ Q~(- ~.(
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Tg()~a IO-7- 87 Date
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I Date Accompanied By:
L.
Approved By:
F. d.
guali Ins ection Summar R. Wharton J blonski, Chief Assurance Programs Section
/0 747 Date Ins ection on June 16 throu h Jul 2, 1987'e orts No. 50-315/87022 DRS
No. 50-316/87022 DRS and the meetin on Se tember
1987 p
i gi b
d d
Headquarters based inspector of licensee action on previously identified problems and the licensee's gA, audit and procurement programs.
The inspection was conducted using selected portions of inspection Modules 35701, 38701, 92701, 92702 and 92720.
Results:
Three violations were identified with problems noted in all areas inspected.
The violations were: 'failure to properly evaluate, select and control suppliers (Paragraph 2.h.( 1), 2.h.(2),
and 3.b); failure to provide prompt and adequate corrective action (Paragraphs 2.m, 2.p.,
and 3.a);
and failure to properly certify lead auditors (Paragraph 3.a).
8710l30398 871%@i PDR ADOCK 050003i5 Q
DETAILS 1.
Persons Contacted American Electric Power Service Cor oration AEPSC q**M q*P
- J
- M.
q**R
- B Alexich, Vice President Nuclear Operations Barrett, Nuclear Safety and Licensing Feinstein, Manager, Nuclear Safety and Licensing Horvath, Site Quality Assurance Supervisor Kroeger, Manager of Quality Assurance Lauzau, Nuclear Safety and Licensing Indiana and Michi an Electric Com an I&MEC
- T. Beilman, Instrument and Control/Planning Superintendent
- A. Blind, Assistant Plant Manager
- E. Morse, Quality Control Department Head
- J. Veach, Stores Supervisor
+*W. Smith, Jr., Plant Manager Nuclear Re viator Commission NRC)
+B. Burgess, Section Chief
+J. Harrison, Branch Chief
+F. Jablonski, Section Chief
+B. Jorgensen, Senior Resident Inspector
- Indicates those attending the exit meeting at the D.C.
Cook Plant on June 26, 1987.
2.
- Indicates those attending the exit meeting at the AEPSC corporate offices in Columbus, Ohio, on July 2, 1987.
+Indicates those principal personnel attending the management meeting at the D.C.
Cook site on September -17, 1987.
Other individuals were contacted as a matter of course during the inspection.
Licensee Action in Previous Ins ection Findin s
a.
(Open)
Unresolved Item (315/83001-04; 316/83001-04):
Qualifications of persons verifying inspections were not sufficient.
The NRC inspector reviewed certification packages for five QC inspectors and several problems were noted.
The inspector was referred to a letter AEP:NRC 0970A dated December 23, 1986, notifying the NRC that QC was no longer responsible for inspection.
This letter voided commitments made in response to previous inspection findings dealing with inspector qualifications/certifications.
Changing inspection'responsibilities from QC to maintenance, as described in
the referenced letter, was implemented January 15, 1987, by issuing procedure PMI-7090, "Plant Quality Control Program,"
Revision 1.
Performing inspections by maintenance personnel did not appear consistent with Section 1.7.10.2.4 of the D.C.
Cook QA Program dated July 1986 which states that the plant QC department has the responsibility for performing in-process verifications and inspections.
This change in the organization of inspection personnel appeared to be a reduction in commitments to the NRC; however, this matter will be reviewed by the NRC along with other changes made to the revised version of the Updated QA Program for the D.C. Cook'Nuclear Power Plant submitted by the licensee on July 17, 1987.
This item remains open.
The unresolved item will remain open pending resolution of D.C.
Cook inspection responsibilities.
(Closed) Violation (315/83018-02; 316/83019-02):
NSDRC (offsite review committee) did not review the audit program and results.
Licensee action taken to. resolve this issue is described in an AEPSC letter dated January 27, 1984.
The inspector reviewed two NSDRC audit program review reports for the periods July 1, 1985, through June 30, 1986, and July 1, 1986, through December 31, 1986, respectively.
The reviews appeared to be adequate and well documented.
The reports were issued approximately five months after the close of the audit period.
The inspector expressed concern on the lack of timeliness in performing the review and issuing the report.
Licensee personnel indicated that steps had been taken to ensure a more timely i ssue of the report in the future.
This item is closed.
(Open) Violation (315/84016-02; 316/84018-02):
Untimely corrective action on certification of QC inspectors.
Action to resolve this issue is described in the licensee's response dated November 28, 1984.
The action commitment was withdrawn by letter (AEP:
NRC: 0970A)
dated December 23, 1986.
Pending resolution of this letter by the NRC, this item remains open.
(Refer to Item 2a).
(Closed)
Unresolved Item (315/85003-01; 316/85003-01):
Question on status and adequacy of 50.59 reviews for procedure changes using change sheets.
The inspector reviewed PMI-2010, "Plant Manager and Department Head Instructions, Procedures and Associated Indexes" Revision 12.
Paragraph 3.13.3A, states that change sheets are not allowed to be used to alter the intent of the instruction or procedure.
The inspector also reviewed PMI-1040, "Plant Nuclear Safety Review Committee" (PNSRC) Revision 7, and noted that Paragraph 4.9.3 requires the PNSRC to review change sheets.
Within the definition of 50.59, review of change sheets would not be required but the PNSRC review should provide assurance that change sheets are properly used.
The inspector reviewed seven change sheets; all appeared to have been properly used.
This item is close (Closed)
Open Item (315/85007-01; 316/85007-01):
Excessive use of change sheets for procedure revision.
The inspector reviewed four procedure/instruction books and noted a substantial reduction in the number of change sheets.
Based on this and the change sheet review described in Item d, this item is closed.
(Closed) Violation (315/85007-04E; 316/85007-04E):
Failure to provide an acceptable quality trend program.
Licensee action to resolve this issue is described in licensee response dated June 14, 1985.
Schedule commitments for completion of this item were changed as noted in Paragraph 2r of Inspection Reports No. 50-315/85033; No. 50-316/85033.
The quality trend program was implemented October 13, 1986.
The inspector reviewed PMI-7030, "Condition Reports and Plant Reporting,"
Revision 11, that describes problem reporting, corrective action responsibilities, and trending.
The trending program is computerized and has a wide variety of trending capabilities.
Data have been put into the system since the program was initiated.
No attempt was made to backfit the system beyond October 1986.
The inspector noted that action requests were issued for two apparent adverse trends.
The trending program appeared to have potential for early detection and correction of quality problems.
This item is closed.
(Closed)
Open Item (315/85007-08; 316/85007-08):
Submittal of proposed Technical Specification (TS) changes to the NRC prior to NSDRC review.
This practice continues.
The inspector reviewed action taken on five proposed TS changes recently submitted to the NRC and made the following observations.
(1)
All five proposed changes were reviewed by the PNSRC (onsite review committee) prior to submittal to the NRC.
(2) 'll five proposed changes were reviewed by the NSDRC (offsite review committee) at the next monthly meeting after submittal to the NRC.
(3)
In all cases, status of the NSDRC review was indicated in the letter that submitted the proposed changes to the NRC.
This item is closed.
(Closed) Violation (315/85026-01; 316/85026-01):
Failure to properly store radiographs and microfilm.
Licensee action to resolve this issue is described in licensee response dated December 20, 1985.
The licensee contracted radiograph and microfilm storage to National Underground Storage (NUS) of Boyers, Pennsylvania.
The record package for NUS contained an audit of NUS that was conducted by Carolina Power and Light on October 28, 1986.
This audit appeared to provide adequate verification that the record storage facility
met the requirements of ANSI N45.2.9 "Requirements for Collection, Storage and Maintenance of gA Records."
The inspector does not have concerns about the improper storage of radiographs; this item is closed.
The purchase order (PO)
to-NUS was originally issued as non-safety related but required that record storage comply with ANSI N45.2.9.
The PO was subsequently changed to safety-related.
In reviewing records about this matter the following observations were made:
(1)
AEPSC gA performed an audit of the NUS record storage facility on February 5, 1987.
The trip report for the NUS audit was dated February 13, 1987, and indicated that the audit consisted of a "detailed review of ANSI N45.2.9 facility requirements and NUS's implementing procedures and practices."
A generic checklist was used by the auditor to perform the audit.
The checklist was brief and included only the general requirements of 10 CFR 50 Appendix B, but not the detailed requirements of ANSI N45.2.9, which were required by the PO.
In fact, review of the checklist and discussions with the auditor by the inspector indicated that detailed ANSI N45.2.9 requirements had not been verified.
(The specific minimum attributes th'at the audit should have included were delineated in NRC letter to AEPSC dated March 4, 1987.
This letter stated that Sections 1.3, 5, 6, and 8 of ANSI N45.2.9 specifically applied to the procurement of record storage services).
This failure to assure that the PO requirements were met is a
violation of 10 CFR 50, Appendix B, Criterion VII (315/87022-01A; 316/87022-01A).
(2)
The trip report dated February 13, 1987, and a letter from R.
F. Kroeger to J.
B. Brittan dated February 13, 1987, stated that NUS did not have an approved gA program.
Even so, and contrary to AEPSC GP No. 7-1, "Supplier Evaluation gualification and Control," Revision 1, NUS was placed on the gualified Supplier List (gSL).
The PO was re-issued (90745-040-7N)
and now states
"the supplier should understand that the material, equipment or service is for nuclear service and shall be furnished under a
vendor gA program previously approved by the buyer."
The buyer, AEPSC, failed to approve a
gA program because NUS does not have one.
Failure to ensure that PO requirements were met, and approving a supplier without an approved gA program are violations of 10 CFR 50, Appendix B, Criterion VII (315/87022-01B; 316/87022-01B).
(Open) Violation (315/85026-02; 316/85026-02):
Failure to take proper corrective action to prevent the inadvertent mixing of swing and piston check valves.
Licensee action to resolve this issued is described in licensee response dated December 20, 1985.
The permanent fix to this.problem was long term and involved verifying the type and manufacturer of currently installed check valves.
Since this verification sometimes involved containment access and
removal of insulation, all verifications have not been completed and interim control measures are still in place.
Licensee personnel agreed to review the work yet to be done by August 31, 1987, and commit to a date for final completion.
This item remains open.
(Closed)
Unresolved Item (315/85026-05; 316/85025-05):
Different audit groups (AEPSC site QA and AEPSC corporate QA) audit portions of systems or functional areas.
Individuals from AEPSC corporate QA have been assigned to audit whole functional areas in procurement, corrective action and design control.
The inspector reviewed two internal audit reports, C13-8G-10-10.5 and C13-86-11-11.5, that placed emphasis upon interfaces between the corporate office and the plant site.
The audits appeared to adequately address the interfaces.
This item is closed.
(Cl osed)
Recommendation (315/85026-R01; 316/85026-R01):
Recommended establishing a system to status open request for changes (RFCs)
through all stages until completion.
The inspectors noted that two separate computerized tracking systems were used for tracking and status of open RFCs, one for the plant and one for the corporate office.
Computer printouts from both systems were reviewed and the inspector has no further concerns.
This item is closed.
(Closed)
Recommendation (315/85026-R02; 316/85026-R02):
Recommended establishing a tracking system for RFC packages.
The two computerized systems discussed in "k" provides this tracking.
This item is closed.
(Open) Violation (315/86019-02; 316/86019-02):
Procurement from non-qualified suppliers.
Licensee action to resolve this issue is described in the licensee response dated July 10, 1986, NRC letter dated August 7, 1986, and licensee letter dated August 27, 1986.
This violation was originally written because purchase orders were issued to suppliers who were not listed as qualified suppliers according to the specified product code.
In the NRC letter dated August 7, 1986, which addressed proposed licensee action to correct this matter, the NRC position was clarified, that is, the product code index was to be revised to "expand and clarify the products and services that suppliers are qualified to supply."
Instead, licensee actions caused the product code index to be greatly reduced and included most suppliets in two categories.
(1)
Product Code 1000 - Nuclear equipment "all items purchased as QA/QC-N where-in the item consists of more than one material part and for which spares provisioning (SIC)
may be whole items or subparts.."
(2)
Product Code 2000 - Nuclear materials/components
"all items purchased as QA/QC-N which are not normally subject to disassembly or repair, only replacement."
The inspectors noted that the gSL had 74 suppliers listed with Product Code
"1000" allowing supply of "nuclear equipment,"
and 52 suppliers were listed with Product Code "2000" allowing sup'ply of "nuclear materials/components."
Six of the above suppliers were distributors that supply a wide variety of nuclear.equipment or nuclear'materials/components from many different manufacturers, locations, and qualifty levels.
These parts are usually commercial grade and may be from a nonqualified supplier or manufacturer
.
The actions taken by the licensee to clarify and control qualification of suppliers appeared to be a blanket endorsement of multiple suppliers to supply any or all nuclear parts and components.
Failure to take proper corrective action to resolve a quality problem is a violation of 10 CFR 50, Appendix B, Criterion XVI (315/87022-02A; 316/87022-02A).
(Cl osed)
Unresolved Item (315/86019-03; 316/86019-03):
Product code index of the qualified supplier list is too general.
The product code index was redefined but product codes are now more general than before.
Since Item m. involves revision to the product code index, this item will be closed and the acceptability of the product code index will be tracked with violation (315/87022-02A; 316/87022-02A).
This matter is closed.
(Closed) Violation (315/86031-01A; 316/86031-01A):
Inappropriate approval of a qualified supplier.
Licensee action taken to resolve this issue is described in the licensee response dated October 10, 1986.
Bussman Division of Cooper Industries was placed on the gSL even though an audit indicated that 17 of 18 Appendix B criteria were deficient.
The supplier has been removed from the gSL and is no longer available as a supplier of safety-related items.
This matter is closed.
(Open) Violation (315/86031'-01C; 316/86031-01C):
Failure to provide appropriate source evaluation and selection.
Licensee action to resolve this issue is described in licensee response dated October 10, 1986.
Suppliei s were added to the gSL as conditional suppliers without benefit of an audit, survey, past performance history or other qualifying information.
The.licensee's'esponse letter stated that suppliers, and the reasons for retaining suppliers on the gSL, were being reviewed; questionable suppliers were being removed from the gSL.
This review included those companies with too many significant gA program deficiencies or those with no audit, survey or other qualifying data.
The inspector reviewed three supplier packages and determined that the two listed below were unacceptabl Stevenson and Associates, Cleveland, Ohio:
An audit was performed by Gilbert/Commonwealth, Inc., Reading, Pennsylvania, for Niagara Mohawk Power Corporation on October 15, and 16, 1985.
Results of that audit indicated that there were no procedures to implement the gA program in any area.
The supplier provided services to AEPSC for design and design related activities.
A lied Test,S stems Butler, Penns lvania:
The supplier did not have a g program, no audit or survey was performed and there was no past performance history.
There was no objective evidence or any other qualifying data; yet, the supplier was on the gSL to supply calibration services.
This indicated a continuing problem with supplier source evaluation and selection and that previous actions taken to correct violations Nos.
315/86031-01C and 316/86031-01C were not effective.
This failure to provide effective action to correct the previously identified violation is a violation of 10 CFR 50, Appendix B, Criterion XVI (50-315/87022-02B; 50-316/87022-02B).
q.
(Closed) Violation (315/86043-02; 316/86043-02):
PMI-5040, "Design Change Control Program" allowed waiver of procedure requirements.
Licensee action to resolve this issue is described in licensee response dated February 3, 1987.
The inspector reviewed PM1-5040,
"Design Change Control Program" Revision 9, and noted that Paragraph 4.3.1 was changed to eliminate the authorization to waive applicable portions of the procedure.
This matter is closed.
During review of licensee action on previous inspection findings, three violations with multiple examples were identified.
g44 This inspection was conducted to verify that the gA program was being properly implemented to ensure compliance with regulatory requirements and operational gA program commitments.
Efforts were also made to determine management involvement in and support for quality; the approach to corrective action; and responsiveness to NRC concerns.
The inspection was performed by reviewing applicable procedures and records, conducting personnel interviews and observing work activities.
Inspection results are documented in the following sections.
~Adi
h di p
g i
d functional areas were being properly verified, that problems were being noted and that proper actions were taken to resolve noted problems.
Records of eight completed audits were reviewed.
Completed checklists indicated that audits were thorough and proble'ms appeared to be properly documented.
The inspectors noted
that in some cases responses to audit findings were being submitted a few days beyond the 30 days allowed.
This was discussed with licensee personnel and the inspectors are confident that action is being taken to correct this issue.
In reviewing audit QA-86-38-02 inspectors noted that two of the findings were the same as those previously noted in audit QA-85-10, which had been performed approximately 13 months earlier.
These findings involved the failure to revise a radiation physics procedure to include acceptance requirements.
The package included a number of letters that discussed and debated validity of the findings.
QA management determined that the findings were valid; however, action was not taken to resolve the findings which were closed by QA prior to completion of required corrective action.
Since another audit was scheduled to be performed in this area within six months, QA closed the findings noting that this situation would be reviewed then.
The next scheduled audit was audit QA-86-38-02.
CFR 50, Appendix B, Criterion XVI requires that conditions adverse to quality be promptly identified and corrected.
Contrary to the above a radiation physics procedure was not revised to include acceptance criteria as noted in an audit report yet the audit finding was closed by the QA organization.
This is a violation of Criterion XVI (315/87022-02C; 316/87022-02C).
The inspectors reviewed qualification/certification records for five lead auditors.
Lead auditors K. E. Alexejun, J. J.
Nadeau, and B.
C. Rarrick were improperly certified
.
Certification points were allowed based on non-technical experience, and in some cases points were allowed for professional accomplishment other then certifications by state and professional agencies as specified in ANSI N45.2.23.
This failure to properly certify lead auditors is considered to be violation of 10 CFR 50, Appendix B, Criterion XVIII (315/87022-03; 316/87022-03).
During the review of the two audit programs, one violation and two examples supporting another violation were identified.
Procurement The inspector reviewed the following procurement related documents:
AEPSC General Procedure GP 4.0, "Procurement Documents Control," Revision
AEPSC General Procedure GP 3.6, "Environmentally Qualified Equipment," Revision
AEPSC General Procedure GP 7.1, "Supplier Evaluation, Qualification and Control," Revision
AEPSC General Procedure GP 15.4, "Reporting Defects and Nonconformances per
CFR 21," Revision
I
& MEC Procedure No.
DAP 3120, "Stores Receipt Inspection,"
Revision
The D.C.
Cook Nuclear Plant procurement program involves purchases initiated by either D.C.
Cook site personnel or responsible AEPSC engineering organization.
This inspection focused on commercial grade procurements of spare and replacement parts.
Specifically, the inspector reviewed the procurement activities related to the licensee's method of assuring the suitability of application for commercial grade items intended for safety-related use.
Most commercial grade items were purchased to DCC (D.
C.
Cook)
specifications and from AEPSC approved suppliers.
This method is termed commercial grade safety-related and is used primarily to purchase from suppliers that will not accept
CFR Part
reporting responsibility.
The AEPSC standing policy is to buy N-grade (nuclear)
from qualified suppliers who will accept
CFR Part 21 responsibility.
The procurement program was reviewed to determine its technical adequacy and if it was being properly implemented.
The inspector conducted interviews with key personnel and reviewed procurement records and documents to determine if ( 1) practices were in accordance with administrative controls and (2) appropriate technical requirements were being satisfied.
The items of particular interest were those classified as Class 1E and those seismically qualified.
With the exception of those items identified below, the inspector determined that for those items reviewed, the procurement program related to commercial grade items intended for safety-related use had been adequately implemented.
During the review of the licensee's commercial grade procurement practices, the inspector noted that the licensee had recently developed two "dedication packages" for use of commercial type services for safety related equipment.
Non-safety related purchase orders were issued to Precision National Corporation (PNC) of Waco, Texas, for repair of two crankshafts for emergency diesel generators.
The work was performed based on telephone discussions between AEPSC and PNC.
The purchase orders were issued and dedication packages were developed after the work was completed.
There was no evidence that any in-process surveillances at PNC were made by the licensee; however, a visit was made prior to shipment.
The crankshafts were received, placed on hold pending completion of the dedication packages, and released for use.
A hold was placed on the completed dedication packages after questions were raised by the NRC inspector.
The inspector questioned the nonsafety-related classification of the POs, issuing of the POs after completion of the work, lack of controls on the supplier, and acceptability of unverified process documentation.
The inspector was informed by the licensee that the purchase order was classified non-safety-related because the supplier reportedly had a "non-auditable" gA program.
At the suggestion of the diesel engine manufacturer the licensee chose to use the unqualified supplier.
Use of an unqualified supplier for procurement of services for safety-related repairs would. have been an acceptable option if appropriate controls had been applied; however, the licensee deemed it unnecessary to perform any in-process inspections or verifications, or to require that the repairs be made in accordance with any specified procedures.
Repairs for one of the crankshafts involved plating the crankshaft journals.
There was no requirement put into the PO for qualified procedures or personnel and there was no evidence that either were used for this special process.
The licensee's after-the-fact dedication packages for the nonsafety-related services contained unverified data and process documentation from an unqualified supplier.
The AEPSC gA Manual for D. C. Cook, Section 1.7.7.2.3, dated July 1985, requires that in-process surveillance of suppliers'ctivities during fabrication, inspection, testing and shipment of items be performed when deemed necessary, depending upon supplier qualification status, complexity and importance to safety of the item being furnished, and/or previous supplier history.
Services, for repair s to the crankshafts of the engine of the emergency generator, were procured by the following gA-S purchase orders:
(1)
P.O.
0667-040-6X, Repair bent emergency diesel generator crankshaft (2)
P.O.
06668-041-6X, Repair corrosion damaged emergency diesel generator crankshaft Repairs were performed without any in-process surveillance or verifications of the suppliers activities.
In addition, the unqualified supplier had no previous history of providing nuclear services.
These failures to provide control of quality by a contractor at an interval consistent with importance and complexity of service are in violation of 10 CFR 50, Appendix B, Criterion VII (315/87022-01C; 316/87022-01C).
During the review of procurement one example supporting another violation was identified.
4.
Conclusion Based on the noted reviews and follow-up of previously identified problems the inspectors concluded that:
Although management involvement in correcting quality problems was evident, decisions by management were not always based on a good evaluation of requirements and commitments and sometimes resulted in inadequate corrective actions and the failure to address NRC concerns.
(See Paragraphs 2a., 2.h.(2)
and 2m.).
Procurement practices in the area of supplier evaluation and qualification, and designation of safety related procurements appeared to be a significant problem and could have resulted in use of material or services with inadequate or indeterminate quality.
Audits and surveillances appeared to be adequate and conducted according to schedule; however, adequacy of some audits is uncertain because of improper certification of lead auditors.
5.
Exit Interview C
The inspectors met with licensee representatives (denoted in Paragraph 1)
at the D.C.
Cook Plant on June 26, 1987, and at the AEP Corporate offices in Columbus, Ohio, on July 2, 1987.
The inspectors summarized the purpose and findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regard to documents and processes reviewed during the inspection.
The licensee did not identify any document or process as being proprietary.
6.
~Neetin On September 17, 1987, an NRC meeting was held with senior licensee management at the D.C.
Cook plant site.
The purpose of the meeting was to discuss and further understand potential gA programmatic problems in the areas of gC inspection and procurement of products and services.
Information from that meeting will be considered during ongoing NRC analysis of current inspection findings and reviews of recent licensee gA program submittals.
12