ML17329A071
| ML17329A071 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 06/24/1991 |
| From: | Langstaff R, Lougheed V, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A069 | List: |
| References | |
| 50-315-91-12, 50-316-91-12, NUDOCS 9107010044 | |
| Download: ML17329A071 (11) | |
See also: IR 05000315/1991012
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
Reports
No. 50-315/91012 (DRS); 50-316/91012 (DRS)
Docket Nos. 50-315;
50-316
Licenses
No. DPR-58;
Licensee:
Company
1 Riverside Plaza
Columbus,
Ohio 43216
Facility Name:
Donald C.
Cook Nuclear Power Plant:
Inspection At:
Donald C.
Cook Plant Site,
Bridgman, Michigan
Inspection
Conducted:
June 3-7,
1991
Inspectors:
R. A. Langstaff
Da e
V. P.
Lo
eed
D te
Approved By:
M. P. Phil ips, Chief
Operational
Programs
Section
g z<t~(
Date
Ins ection
Summar
Ins ection
on June
3-7
-1991
Re orts No. 50-315
91012
. No.
50-316
91012
Areas Ins ected:
Routine unannounced
safety inspection of the
licensee
s quality verification program,
including the peer
inspection process.
This inspection utilized NRC inspection
module 35702.
Results:
One violation and two unresolved
items were identified.
The violation involved personnel
not being trained in their skill
area
as required by the licensee's
quality assurance
program
(Paragraph
3).
The unresolved
items dealt with the apparent
lack
of independence
of personnel
performing verification activities
for instrumentation
and control
(I6C) work (Paragraph
4),
and the
qualification of plant personnel to Regulatory Guide 1.8 and
(1971)
(Paragraph
3).
Two weaknesses
were identified in the licensee's
program.
These
entailed:
(1) the lack of procedures
addressing qualification
requirements
for peer inspectors
in the I&C department,
and
(2) the ability of the Quality Control Department surveillances
to identify the above concerns with the peer inspections
process.
5'107010044
giOh24
ADOCK 05000315
6
These weaknesses
are discussed
in Paragraphs
2 and 5,
respectively.
DETAILS
1 ~
Persons
Contacted
Indiana Michi an Power
Com an
American Electric Power Service
Cor oration
AEPSC
A. Blind, Plant Manager
R. Allen, Regulation Supervisor,
Maintenance
K. Baker, Assistant Plant Manager,
Production
P. Carteaux,
Safety
& Assessment
Superintendent
L. Gibson, Assistant Plant Manger, Projects
E. Kincheloe, Training Superintendent
J. Rutrowski, Assistant Plant Manager,
Technical Support
T. Wagoner,
Maintenance
Supervisor
M. Wiederwax, Safety and Assessment,
QC/NDE Supervisor
K. Worthington,
AEPSC Site Quality Assurance
U.S. Nuclear
Re ulator
Commission
NRC
J.
Isom, Senior Resident Inspector
D. Passehl,
Resident Inspector
2 ~
All of the above personnel
attended
the exit meeting held on
June
7,
1991.
The inspectors
also interviewed other licensee
employees
during the course of the inspection.
ualit
Verification Procedures
The licensee controlled its quality verification program in
accordance
with its Quality Assurance
Program Description
(QAPD) Chapter 1.7.10,
"Inspection," dated
December
1990.
Specific implementation requirements
were addressed
in
Plant- Manager Instruction PMI-7090, ."Plant Quality Control
Program," dated June
1990.
The
QAPD provided an overview of the inspection process.
It
stated,
in part, that inspections
are performed by personnel
other than those
who perform the activity; inspections
are
performed by qualified personnel;
I&M personnel
who inspect
work are qualified in accordance
with Regulatory Guide 1.8
and ANSI N18,.1 (1971),
and are periodically trained in their
skill area using
INPO accredited training; and that peer
inspection personnel
are independent
in that they do not
perform or directly supervise
the work being inspected,
but
may be from the
same work group.
O
PMI-7090 expanded
upon the requirements
of the
QAPD. It
defined the terms verification, independent verification,
inspection,
and inspection hold point,
and outlined the
requirements for each.
For example, verifications were to
be performed by someone
other than the one who performed the
activity or otherwise established
the condition that was
being verified.
However,
a verifier could be a 'qualified
member of the
same work group.
For independent verifications,
PMI-7090 stated that the
person performing the independent verification was to be
disassociated
from those performing the task:by not being in
the area at the'ime the activity or condition was being
performed.
For cases
where two person
teams
were required
to perform the activity,
a second
team was required to do
the independent verification.
PMI-7090 further delineated
when an independent verifier was required
as
compared to a
verifier.
Examples
were:
removal
and return to service of
equipment
and systems
required by technical specifications
or equipment described in the safety analysis report and
credited with controlling the reactor or preventing or
mitigating an accident or transient.
Guidance regarding
who could perform a peer inspection
was
contained in Maintenance
Head Instruction MHI-7090,
"Maintenance
Department Inspection Hold Point Program,"
dated August 1987.
This procedure
only applied to the
inspection hold point portion of the peer inspection
process.
It specified that inspection hold points could
only be performed by:
a)
an independent
supervisor,
same
discipline,
b)
an independent
supervisor, different
discipline,
c)
an independent
maintenance
mechanic
A, same
discipline,
d)
an independent
maintenance
mechanic
A,
different discipline,
e)
an independent
maintenance
mechanic
B, or f) an independent
maintenance
engineer.
The applicability of these
requirements to other portions of
the peer inspection process
(verification, independent
verification, or inspections)
was not directly described in
either this procedure or other working level documents.
Additionally, the applicability to instrumentation
& control
(I&C) activities
(which were not covered under the
maintenance
department)
was not defined.
Lack of specific
lower level procedural
guidance
was considered to have
contributed to the deficiencies
found by the inspectors
regarding
I&C department
implementation of the peer
inspection
program
and was
a weakness
in the licensee's
program.
Trainin
and
uglification of Personnel
Performin
Peer
Ins ections
The inspectors
reviewed training records for selected
individuals whom the inspectors
had observed
performing
independent verification activities.
The inspectors
observed
performance of four I&C surveillances
on June
3 and
4,
1991.
For all of these surveillances,
the independent
verifications were performed by individuals who had not
completed the accredited training program as documented
on
their training matrix.
As part of the peer inspection process,
the licensee,
in its
QAPD, required all individuals performing quality
verification activities to be periodically trained in their
skill area using an accredited training program,
and to be
qualified in accordance
with ANSI-N18.1 (1971).
The accredited
program consisted of classroom
course work
followed by on-the-job training for specific tasks.
When
both sets of training had been completed,
the individual was
considered qualified.
Some individuals,
due to length of
service time when the program was initiated,
were waived
,from either the classroom training, the on-the-job training,
or both.
The status of an individual s qualifications was
tracked through
a training matrix.
The matrix indicated
whether
a person
was qualified through performance or
simulation of a specific task,
was waived,
had completed the
classroom training, or was unqualified.
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
'rogram
Description
(QAPD) is the policy by which Criterion
II 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 periodically trained in their skill area.
The lack of completed training for these individuals is
considered
an example of a violation of the requirements
of
10 CFR Part 50, Appendix B, Criterion II, as implemented
by
the licensee's
QAPD.
(315/91012-01;
315/91012-01).
Interviews with I&C supervisors
revealed that the
supervisors
recognized that personnel
who performed
and
oversaw surveillances
needed to be qualified.
However, they
did not consider
such qualification necessary
for personnel
who performed the independent verifications,
and,
as such,
the practice of using personnel
who had not completed the
applicable qualification training for performing independent
verifications was accepted.
In contrast,
interviews with
supervisors
and training personnel
outside of the I&C
department
revealed that personnel
who performed independent
verifications in the maintenance
department
had to be
qualified in the task being verified.
In addition to the skill area training described
above,
specific training on peer inspections
was conducted for
maintenance
mechanics
and electricians.
This training was
comprised of a four hour classroom
course
and included
discussions on'lant commitments, qualifications necessary
to perform inspections,
independent
inspections,
and
condition/problem reports.
Similar. training was not
provided for I&C personnel,
as this department
was
considered
separate
from the maintenance
department at the
time of the training.
The inspectors
were unable to ascertain
from the training
records
reviewed,
whether
I&C personnel
had been trained in
accordance
with ANSI N18.1 (1971),
as required by QAPD
paragraph
1.7.10.2.4 for licensee
personnel
performing
inspections.
The licensee
was requested,
during the exit
meeting, to provide additional documentation to demonstrate
how this
QAPD requirement
was being met.
Pending
a review
of the results, this issue will be tracked
as
an unresolved
item (315/91012-02;
315/91012-02)
.
Inde endent Verification of Surveillance Activities
The inspectors
were concerned that the surveillance
activities performed within the IIC department
may not be
sufficiently independent
from the performance of the work
to meet regulatory
and
QAPD requirements.
The inspectors
observed
several
I&C surveillances
being
performed
on June
3 and 4,
1991 where the independent
verifications were performed by a member of the team doing
the work.
The majority of the surveillances
witnessed
were
routine technical specification surveillances;
however,
one
was performed following maintenance
on an inoperable
technical specification
component.
The inspectors
noted
that the normal practice for performance of independent.
verifications involved having one person
(of a two member
work team) monitor an indicator while the other team member
performed the activity, such
as racking in a breaker
on
'
back panel.
In the majority of cases
observed
by the
inspectors,
the independent verifier was in communication
with the person
who performed the activity, and was being
told what to expect by the person performing the work.
In
addition, the independent verifier did not have
a copy of
the procedure
step that was being verified.
The licensee
considered this to be independent
since the indicator was in
a different location than the breaker being manipulated.
In one case,
the lead technician stopped
work and informed
the junior technician that he would have to step out of
sight of the panel
so that the junior technician could
independently verify the lead
s activity.
The junior
technician
stepped
behind the panel
as told, returned
when
.called,
checked the switch position,
and then signed
as the
independent verifier.
The manner in which this activity was
performed led the inspectors to question whether the
technicians
were sufficiently qualified to perform
independent verification activities
(see Paragraph
3 above).
The inspectors
were also concerned
about the independence
of
the junior technician since
he clearly was taking direction
from the senior technician performing the work, and up to
that step,
had been working directly under the supervision
of the lead technician.
The inspectors
also observed
an example of maintenance
work
on a control circuit.
In this case,
two senior'evel
technicians
performed trouble-shooting activi'ties to
determine
why spiking was occurring.
Upon determining that
the leads to a potentiometer
needed to be removed, cut,
and
resoldered
in order to provide
a better connection,
the two
technicians
accomplished
the task with one holding the wire
in place while the other soldered.
In order to show that
the maintenance
had been effective, the technicians
then ran
a surveillance procedure,
which included independent
verification of the return to service of the component.
One
of the technicians
became the independent verifier by
watching the indicator light as the other technician racked
in the breaker to return the component to service.
Because
both technicians
had been actively involved in the
maintenance
work, the inspectors
did not, believe that they
could be considered
independent for this one step.
There
was no specific verification performed for the resoldering
activity.
The use of members of the team doing the work for inspection
activities did not appear to meet the licensee's
requirements
for ensuring that inspection personnel
not
perform or directly supervise
the work being inspected.
In the I&C department,
both supervisors
and personnel
repeatedly
stated that it was
common,
and acceptable,
to use
members of the
same
team for independent verification
activities.
Supervisors
and training personnel for the
mechanical
and electrical maintenance
department
indicated
that in their areas of responsibility independent
verifications were performed by individuals other than
members of the work team or their supervisor.
The
verification aspects
were considered to be separate
from the
requirements for inspections specified in Criterion X
of'ppendix
B to 10 CFR Part 50.
However, section 1.7.10.2.4
of the licensee's
QAPD specified that inspection personnel
not perform or directly supervise
the work being inspected.
As such,
the use of members
o'f the team doing the work for
inspection activities appeared to be contrary to this
program requirement.
The licensee
was requested
to provide its justification for
the practice of utilizing persons
from the
same work team to
perform the work to also conduct the verification activities
met the requirements
of the
QAPD and Appendix
B to 10 CFR Part 50.
This is considered
an unresolved
item.
(315/91012-03;
316/91012-03).
ualit Verification Activities
In addition to the peer inspection process,
the licensee
maintained
a corporate Quality Assurance
(QA) function as,
well as
a plant Quality Control
(QC) capacity.
The role of
the corporate
group was to provide an overview of quality
assurance
programs at both the site and corporate offices.
The
QC group performed inspections
on any work performed by
organizations
other than the licensee (i.e., all work
performed by contractor personnel
was verified by the
department rather than through the peer inspection process).
Additionally, the
QC department
performed periodic
surveillances
of specific work activities to monitor the
implementation of the peer inspection process.
The inspectors
reviewed the annual
QA audits of the site
inspection processes
for 1989 and
1990
(QA-89-12 and 90-12).
The audits were of acceptable
scope
and depth
and noted
several deficiencies,
especially in regard to training and
independent verification.
The inspectors
also reviewed
a
sample of twelve
QA surveillances
performed in the last six
months.
These surveillances
were more limited in scope,
and
tended to provide an overview of a specific work activity
rather than just the inspection process.
The
QA audits
and
surveillance'ppeared
to be adequate
in their overview
capacity.
However, the licensee's
Quality Control Department
surveillance activities associated
with the peer inspection
process failed to identify the concerns
found during this
inspection,
even though identical activities had been
inspected.
The inspectors
revi'ew of the 1991
surveillances
determined that they had been performed
through use of an approved checklist.
The final
documentation of each individual activity inspected
(including the peer inspection process)
was
a two-line entry
into a computer program.
Although the surveillance
forms
provided
a concise description of what the
QC department
did, they did not provide any judgement
on the activities
being witnessed other than
a single letter indicating
whether the activity was acceptable,
conditional, or
unacceptable.
The inspectors
noted that over
98% of the
activities observed,
reviewed,
or verified by the
department,
including the reviews performed of I&C
Department activities,
were considered satisfactory.
None
of these surveillances identified the lack of training in
the skill area
as unsatisfactory.
Additionally the inspectors
observed that
QC routinely noted
that verifications were performed by C-level personnel
(i.e., trainees)
in the I&C areas;
however, in the
-electrical
and mechanical
maintenance
areas,
verifications
were performed
by A-level personnel
(senior level).
Because
the I&C activities were considered satisfactory
by QC, it
appeared that the fact that trainees
were performing the
work was never followed up to determine if it met the
requirements
of the licensee's
QAPD.
This is considered to
be
a weakness
in the licensee's
quality verification
program.
Unresolved
Items
An unresolved
item is
a matter about which more information
is required to ascertain
whether it is an acceptable
item,
a
deviation, or a violation.
Two unresolved
items were
disclosed during this inspection
and are discussed
in
paragraphs
3 and 4.
Exit Interview
The inspectors
met with licensee
representatives
(denoted in
Paragraph
1) at the conclusion of the inspection
on June
7,
1991.
The inspectors
summarized the scope
and 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.
After discussion during the exit meeting regarding the
qualifications of I&C personnel
performing inspection
activities, the plant manager
committed to only allow use of
personnel
who were qualified,
as denoted
on their training
matrix, to perform verifications.
The plant manager
informed the inspectors that this change
would take place
immediately and would continue until plant management
could
determine
and document the skill level necessary
to perform
verifications in the I&C area.
During the exit meeting, plant management
agreed with the
inspectors'bservations
regarding
how independent
verifications were performed in the I&C area,
but disagreed
with the inspectors'haracterizations.
Plant management
indicated that mechanical
and electrical maintenance,
because
of the nature of the work, required
a second
independent
person to perform 'the verification.
However, in
the I&C or operations
area,
the independent verification was
actually provided by the indication (the light going out
when the breaker
was racked in, for example)
rather than by
the individual.
Management
indicated that since this
approach
had been
implemented,
the number of errors in the
operations
and I&C areas
had been reduced.
Therefore,
use
of a team member to ensure that the indication had responded
was considered
by plant management
to be an acceptable
form
of independent verification.
10