ML17325B435
| ML17325B435 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 07/24/1991 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1148C, NUDOCS 9107290239 | |
| Download: ML17325B435 (8) | |
Text
ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
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CESSION NBR:9107290239 DOC.DATE: 91/07/24 NOTARIZED: NO DOCKET CIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana 05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
(formerly Indiana
& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to NRC 910624 ltr re violations noted in insp rept 50-315/91-01.Corrective actions:Review deficiencies implementation instructions for independent verification found in program documents.
DISTRIBUTION CODE: IEOlD COPIES RECEIVED:LTR 9 ENCL SIZE-TITLE: General (50 Dkt)-Insp Rept/Notice of VioLation Response NGTES D
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD AEOD/TPAB NRR MORISSEAU,D NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/OTSB llE22 NUDOCS-ABSTRACT OGC/HDS2 RGN3 FILE 01 EXTERNAL: EG&G/BRYCE,J.H.
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1 RECIPIENT ID CODE/NAME COLBURN,T.
AEOD/DEIIB DEDRO NRR SHANKMAN,S NRR/DOEA/OEAB NRR/DST/DIR 8E2 NRR/PMAS/ILRB12 OE DI REGNILE 02 NRC PDR COPIES LTTR ENCL 1
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NOTE TO ALL"RIDS" RECIPIENTS:
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D PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 22
Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 Z
INDIANA NICHIGAN IaOWKR AEP: NRC: 1148C Donald C.
Cook Nuclear Plant Units 1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC INSPECTION REPORT NOS.
50-315/91012(DRS)
AND 50-316/91012(DRS)
RESPONSE
TO NOTICE OF VIOLATION U.
S. Nuclear Regulatory Commission Document Control Desk Washington, D.
C.
20555 Attn:
A. B. Davis July 24, l991
Dear Mr. Davis:
This letter is in response to Mr. G.
C. Wright's letter dated June 24,
- 1991, which forwarded the report on the routine safety inspection conducted by members of your staff from June 3 through June 7,
1991 of activities at Cook Nuclear Plant Units 1 and 2.
The Notice of Violation attached to Mr. Wright's letter identified one Severity Level IV violation associated with training provided to personnel performing independent verifications of surveillance activities.
As previously discussed with your staff, we disagree with the cited violation.
The basis for our disagreement is provided in the attachment to this letter.
Two weaknesses identified in the inspection report are also addressed in the attachment.
This document has been prepared following Corporate procedures that incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Sincerely, 884N p.~4 E.
E. Fitzpatrick Vice President 9i07290239 9i0724 PDR ADOCK 05000315 9
Mr. A. B. Davis AEP:NRC:1148C eh Attachments cc:
D. H. Williams, Jr.
A. A. Blind - Bridgman J.
R. Padgett G. Charnoff NFEM Section Chief NRC Resident Inspector
- Bridgman
ATTACHMENT TO AEP'NRC:1148C
RESPONSE
ATTACHMENT TO AEP:NRC:1148C Page 1
NRC Violatio "10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program" states in part that the licensee shall establish a quality assurance program which complies with the requirements of Appendix B.
This program shall be documented by written policies, procedures, or instructions, and shall be carried out throughout Plant life in accordance with those
- policies, procedures, or instructions.
It further states that the program shall take into account the need for verification of quality by inspection and test and shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
The Indiana and Michigan Power Company Quality Assurance Program Description (QAPD) is the policy by which Criterion II above is carried out.
Section 1.7.10.2.4 of the QAPD states in part that personnel who inspect work are qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1 (1971) and are periqdically trained in their skill area.
Contrary to the above, personnel who inspected work on June 3 and 4,
- 1991, were not trained in their skill'rea.
Specifically instrumentation and control (1&C) personnel who signed off as performing independent verification of work activities had not completed required training in their skill areas.
This is a Severity Level IV violation (Supplement I)
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Res onse to Violation:
The violation references the QAPD with regards to personnel who inspect work being qualified in accordance with Regulatory Guide 1.8 and ANSI N18.1.
The violation further states that personnel who inspected work were not trained in their skill area and specifically, personnel who signed off independent verification had not completed required training in their skill area.
Verifications and Independent Verifications are included as part of our overall system of administrative controls and have greatly enhanced the performance of our personnel and our Plant.
Our program (PMI-7090) requires that the individuals performing verifications and independent verifications be qualified for the task they are performing and be independent of that task.
We respectfully disagree that a violation of 10 CFR 50, Appendix B, Criterion II occurred.
The violation states that personnel who "inspected" work were not trained in their skill area (a
requirement of the QAPD and ANSI N18.1).
The violation cites
ATTACHMENT TO AEP:NRC:1148C Page 2
performing an "independent verification" as an example.
Verification is defined in our PMI-7090, Plant ualit Control
~Pro ram, as "an act of confirming, substantiating, or assuring that an activity or condition has been implemented in conformance with the specified requirements" similar to ANSI N18.7, Section 5.2.6, a
Verificatio Our Peer Inspection Program is governed by ANSI N18.7, Section "verification activities" and "inspection activities" and our QAPD, Section 1.7.10.2.4 specifically references inspections only.
The technicians observed during the performance of the NRC inspection were performing verification activities which are not a part of our Peer Inspection Program nor part of the QAPD Section 1.7.10.2.4.
The I&C Technicians noted within the inspection report were performing a surveillance on the Reactor Protection System using a procedure which contained independent verification activities.
The supervisor (or Senior Technician) provided a job briefing to the other personnel associated with the
- work, which in the case
- observed, was a Junior Technician.
The Senior Technician performed the physical activities according to the procedure.
The Junior Technician, who was physically separated from the Senior Technician performing the task, was read the procedural step to be performed.
The Senior Technician performed the action.
The Junior Technician then performed the independent verification, read the procedure step to ensure the correct annunciator/status light was illuminated and then signed the procedure as the independent verifier.
It is our position that the Junior Technician was qualified to perform this task and was inde'pendent of the task being performed.
Independence, in this case, was achieved via separation by time and
- distance, thereby disassociating the verifier from the technician performing the task.
Our requirements of hiring personnel to ANSI N18.1 qualifications, our position descriptions and indoctrination training provide us with the reasonable assurance
- that, although Junior Technicians may not be qualified to perform the entire procedure, they are qualified to perform the types of verifications activities noted in the inspection report.
The minimum hiring requirements for I&C Technicians are an associate
- degree, trade school or 6
years Nuclear Navy background.
The skill level required to perform the task in question, (i.e., verify switch position up or down, status light on or off) is well within the abilities of any individual meeting these requirements.
Qualified personnel, strict adherence to proper procedures, and independent verification as practiced at our facility provide us with the defense in-depth required to assure
- safe, conservative operation,
- testing, and maintenance of the Plant.
As a result of your inspection, we recognize that a weakness exists
ATTACHMENT TO AEP:NRC'1148C Page 3
in our demonstration of the skill level or qualifications necessary to perform independent verification as delineated in our procedures.
Following the inspection exit meeting, we immediately instituted the requirement that the individual performing the independent verification be qualified to the same level as the individual qualified to perform the procedure.
-This was done as a
conservative measure to provide time to review our policy, program, and practices.
To remedy the weaknesses, we are reviewing the definitions and implementation instructions for independent verification found in our program documents.
This willprovide a basis for specification of the qualifications/skills necessary to perform specific types of independent verification.
We will then ensure that those individuals performing the independent veri,fication have demonstrated the necessary qualifications and skills.
Our review will be completed by September 15, 1991.
Department specific documents which specify the qualifications/skills necessary to perform independent verification activities will be completed by November 15, 1991.
The above review and document development will address Weakness No.
1 of the inspection report where it was noted that there is a lack of procedures addressing qualification requirements.
We disagree with Weakness No.
2 which stated that the Quality Control Department Surveillances failed to identify the concerns with the peer inspection process.
Verification activities, as noted in the inspection report, fall outside our peer inspection processes.
The surveillances which were performed on Z&C verification activities found that they were performing those activities in accordance with the existing program standards.