IR 05000315/1992008
| ML17329A480 | |
| Person / Time | |
|---|---|
| Site: | Cook |
| Issue date: | 04/29/1992 |
| From: | Langstaff R, Phillips M, Salehi K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A479 | List: |
| References | |
| 50-315-92-08, 50-315-92-8, 50-316-92-08, 50-316-92-8, NUDOCS 9205050049 | |
| Download: ML17329A480 (8) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-315/92008(DRS);
No. 50-316/92008(DRS)
Docket Nos.
50-315; 50-316 Licenses No.
Indiana Michigan Power Company 1 Riverside Plaza Columbus, OH 43216 Facility Name:
D.
C.
Cook Nuclear Power Plant, Units 1 and
1 Inspection At:
D.
C.
Cook Site Bridgman, Michigan Inspection Conducted:
April 6 10, 1992 Inspectors: r/6V<<
K. Sale i Date R.
A. L'ng taff Approved By: ~
M. P. Phillips, Chief Operational Programs Section ze qz Date p/z rgp ~
Date Ins ection Summar Ins ection on A ril 6
1992 Re orts No. 50-315 92008 DRS No. 50-316 92008 DRS Areas Ins ected:
Routine, unannounced, safety inspection of the licensee quality control program.
Results:
Three unresolved items were closed.
One unresolved item was identified concerning the use of verifications in lieu of inspection hold points.
One violation was identified concerning the performance of peer inspections for contractor-performed activities contrary to the requirements of the licensee's quality assurance program.
However, since this violation met the criteria of Section VII.B of the NRC's enforcement policy, no Notice of Violation is being issued.
9205050049 920429 PDR ADOCK 05000315
Indiana Michigan Power Company
fD) fg 3J We will gladly discuss any questions you have concerning this inspection.
Sincerely, Enclosure:
Inspection Reports No. 50-315/92008(DRS)
No. 50-316/92008(DRS)
cc w/enclosure:
A. A. Blind, Plant Manager DCD/DCB (RIDS)
OC/LFDCB Resident Inspector, RIII James R. Padgett, Michigan Public Service Commission EIS Coordinator, USEPA Region 5 Office Michigan Department of Public Health W. Long, LPM, NRR Geoffrey C. Wright, Chief Operations Branch R+I Salehi/cg 04/~ p/92 RADII Langstaff 04/> P/92 II~>>
Ph'ips 04/27 /92 RIII gr rgensen 04/
/92 RIII Zpi t 04/g9/92
DETAILS 1.
Persons Contacted Consumers Power Com an
- A. Blind, Plant Manager
- T. Beilman, Maintenance Superintendent
- K. Baker, Assistant Plant Manager-Production
- M. Barfelz, Safety and Analysis Staff
- T. Bestrom, Maintenance Supervisor
- L. Gibson, Assistant Plant Manager
- M. Horvath, Superintendent of Site Quality Assurance (QA)
- E. Morse, General Supervisor of QA
- B. Svensson, Executive Staff Assistant
- G. Tollas, Safety and Analysis Superintendent
- T. Walsh, Maintenance Procedure Supervisor
- M. Weiderwax, Quality Control Supervisor U.S. Nuclear Re ulator Commission
- J. Isom, Senior Resident Inspector
- D. Passehl, Resident Inspector
- Denotes those who attended the exit interview conducted on April 10, 1992.
2.
Action on Previousl Identified Items 92702 a
~
Closed Unresolved Item 315 91012-02 316 91012-02:
Training in accordance with ANSI N18.1(1971) for individuals performing inspections was not documented.
The inspectors reviewed the training records for selected individuals and determined that lead technicians and mechanics who performed inspections met the minimum training requirements of ANSI N18.1(1971).
This item is considered closed.
b.
Closed Unresolved Item 315 91012-03'16 91012-03:
Verifications wer'e performed using individuals from the same work team.
The inspectors reviewed the licensee's Quality Assurance (QA) program in detail and concluded that the use of individuals from the same work team for performing verifications, as opposed to inspections, was acceptable.
The inspectors witnessed one verification activity for performance of a control room surveillance on a power range nuclear instrumen Based on review of training records for selected individuals, the inspectors concluded that those who performed verifications were either qualified to perform the work being verified or had received training on how to perform the verification.
This item is considered closed.
c ~
Closed Unresolved Item 315 88026-01:
The licensee utilized the one point method for calibrating excore nuclear instrumentation. using the incore nuclear detectors.
This method was discussed with the Office of Nuclear Reactor Regulation, which did not identify any concerns with this approach.
Therefore, this item is considered closed.
ualit Control Ins ection Activities a
~
ANSI N45.2.6 Certified ualit Control C
Ins ectors Section 1.7.10.2.4.b of the licensee's Quality Assurance Program Description (QAPD) requires that inspections of work performed by contractors be performed by inspectors qualified and certified in accordance with Regulatory Guide 1.58 and ANSI N45.2.6.
The inspectors witnessed several inspections performed by QC personnel.
This included a welding fit inspection for valve 2-CS-300 and a valve internals cleanliness and fit inspection for valve 2-CCW-194N.
A third inspection was the QC inspection of maintenance work on 2-CS-193, a 1.5" vent valve, for the safety related Boron Injection transfer system.
The inspectors determined'that the inspections performed by QC personnel were acceptable.
A contractor for the licensee performed maintenance work on about 20 motor operator valve actuators on various systems during the 1992 refueling outage.
The work included inspection of the serviceability of the parts.
At least six (6) of the above 20 valve actuator inspections were performed by peer inspectors rather than the QC inspectors certified to ANSI N45.2.6.
The licensee identified this deficiency and initiated Condition Report No. 02-04-92-0564 on March 31, 1992.
At the time of this inspection the licensee was determining appropriate corrective actions to preclude similar recurrence.
Because of the licensee's actions, the Criteria of 10 CFR Part 2, Appendix C, Section VII.B have been met. and no notice of violation is being issue ANSI N18.1 uglified Peer Ins ectors Peer inspections are inspections performed by individuals within the work groups rather than inspectors from the QC organization.
To maintain independence, the individuals performing the inspection must not have performed the work being inspected or be a supervisor for those who performed the work.
The individuals must have also been periodically trained in their skill area using INPO "accredited" training and be qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1.
At the time of the inspection, the licensee had recently revised their plant quality assurance procedure PMI-7090 to require inspections of specific activities such as performing terminations and tightening of fasteners for safety related work.
The revised PMI-7090 specified that, inspections be performed consistent with their QAPD commitments to standards such as ANSI N45.2.4-1975 and ANSI N45.2.8-1972.
The licensee was in the process of reviewing their procedures to ensure that inspections were correctly specified in accordance with the revised PMI-7090.
However, the licensee had allotted two years to complete this review.
The licensee stated that the majority of the procedures had been examined and revised to reflect the proper use of the words
"inspection" and "verification".
The inspectors noted that not all plant staff understood when inspections were required in lieu of verifications although plant maintenance management was aware of the difference.
The inspectors were also concerned that the revised PMI-7090 specified the use of verifications in lieu of inspections for temporary modifications, such as electrical jumpers and lifted electrical leads.
Under the licensee's QA program, verifications were not intended to meet QAPD requirements or 10 CFR Part
Appendix B requirements for inspections.
The licensee considered post-modification testing with no inspection to be adequate for temporary modifications involving lifted leads and jumpers.
However, ANSI N45.2.4-1975 specifies inspection of electrical terminations such as electrical jumpers and lifted electrical lead Although the licensee was in the process of reviewing and upgrading their procedures, the inspectors identified three examples where the licensee used verifications for activities where the inspectors considered inspection hold points to be more appropriate.
The inspectors noted that the three examples were either performed prior to or shortly after the PMI-7090 revision.
These examples were:
Temporary Modification (TM) 2-92-001 installed a
switch in the hot shutdown panel for controlling a safety injection pump.
The installation involved making electrical terminations to the switch.
~
Work Order (WO)
C0000157 used procedure 12MHP5021.017.001 to reassemble a residual heat removal pump (RHR).
The pump reassembly included tightening the fasteners which secured the pump to the pump casing.
WO C0004017 used procedure 12MHP5021.005.003 to tighten fasteners for the packing on an RHR valve.
/
4.
Unresolved Items The practice of using verification steps in lieu of inspection hold points is an Unresolved Item pending further review by the NRC.
(315/92008-01; 316 92008-01)
An unresolved item is an matter about which more information is required to ascertain whether it is an acceptable item, a
deviation, or a violation.
One unresolved item was disclosed during this inspection and it is discussed in Paragraph 3.b.
5.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1)
on April 10, 1992.
The inspectors summarized the scope and the findings of the inspection.
The inspectors also discussed the likely informational content of the inspection report with regards to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents or processes as proprietary.