ML20054L255

Responds to NRC Re Violations Noted in IE Insp Repts 50-315/82-07 & 50-316/82-07.Corrective Actions: Consultant Work Procedures Rereviewed for Verification of Adequate Controls & Personnel Qualification Reviewed

ML20054L255
Person / Time
Site:	Cook
Issue date:	06/07/1982
From:	Hunter R INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20054L205	List: IR 05000315/1982007 ML20054L255
References
AEP:NRC:0691, AEP:NRC:691, NUDOCS 8207070315
Download: ML20054L255 (5)

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4 lNDIANA & MICHIGAN ELECTRIC COMPANY P. O. 80 X 18 BOWLING GREEN ST ATION M EW Y ORK, H. Y.10004 June 7, 1982 AEP:NRC:0691 Donald C. Cook Nuclear Plant Unit Nos. I and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE INSPECTION REPORT NOS. 50-315/82-07; 50-316/82-07 Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter and its Attachment respond to the Notice of Violation enclosed in the subject Inspection Report. An extension until June 8,1982, was granted to us to respond to the subject Inspection Report by Mr. Hayes of your staff.

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 undersigned.

Very truly ye' irs, RSil/os Vice President cc: John E. Dolan - Columbus R. W. Jurgensen W. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff Joe Williams, Jr.

NRC Resident Inspector @ Cook Plant - Bridgman 9207070315 820701 d\lh S N PDR ADOCK 05000315 G PDR

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ATTACHMENT TO AEP:NRC:0691 ITDI No. 1.A "The AEPSC Cencral Procedure No. 33, " Supplier Evaluation, Qualification, and Control for Nuclear Power Plant", Revision 1, dated January 5,1981, where Section 5.0.2.c stated, that "AEP QA will review the request and support data, determine the need for survey, audit, or additional data, the proceed as necessary". In discussion with AEPSC Management, the inspector stated that the quantity of safety related work performed by ATI was substantial; heuever, the ATI program had not been formally verified by AEPSC to be at 1 cast equivalent to its own program in accordance with the Procedure No. 33. The licensee concurred with the inspector's finding, but also presented the following chronology of relevant documents to show that there were controls and evaluations, to a certain degree, of the subject matter:

9/5/79 Resumes submitted by ATI were reviewed by AEPSC.

Contract proposal was invited.

9/11/79 Proposal submitted listing ATI nuclear experience.

10/2/79 Purchase requisition #07203-250-9N forwarded by Design to AEP Purchasing for work on AEP premises. Numbers of persons brought on premises ranged between 4-8, selectively picked from resumes. Purchase Order was issued by Purchasing on 10/23/79.

10/11/79 and 10/26/79 ADL pipe benchmark information obtained.

11/8/79 Purchase order dollar amount and markup increased.

Personnel evaluation was conducted.

11/20/79 ATI QA program delivered to AEPSC in anticipation of work on ATI premises.

11/26/79 Qualified Supplier List signei off."

RESPONSE TO ITEM 1.A We agree with this finding to the extent that a pre-award, on-site audit of ATI was not conducted. The control of suppliers is within the purview of 10.CFR.50, Appendix B, Criterion VII which states in part: "These measures shall include provisiens, as appropriate for source evaluation and selection-- ". AEPSC General Procedure No. 33 is compatibic with this requirement and provides AEPSC QA with the option to determine whether an on-site audit / survey is required. AEPSC QA judged that an on-site

4 audit / survey was not required in' this case. We understand that 10.CFR.50, Appendix B only requires licensees to have a QA program l that provides control of suppliers commensurate with the service to 5 be provided.  ;

ITEM 1.B "Although the AEPSC Supplier Qualification Request, approved on 11/14/79, stated that the ATI QA manual and procedure are acceptable. The ATI QA manual, Revision 0, dated 3/17/78 was nothing more than a company policy commitment statement issued by the President of the Company".

i The ATI Operating Procedures, Revision 1, which contained: j (1) Document Control, Revision 1, (2) Performing Calculations, ,'

Revis f or. O, 3) Technical Reports, Revision 0, and (4) Ccaputer Usage, Revicien 0, were without proper indications of issuance, review, and approval. The content of the procedures were also

inadequate in comparison with the AEPSC establish procedures for 4

the iEB 79-14 evaluation work. An icproved ATI procedure, lio . 5, j " Calculation", Revision 0, was issued on 10/10/80, but this was

! af ter ATI work had been conducted from January to May 1980."

RESPONSE TO ITEM 1.B 1 The policy statement issued by the President of ATI states, in part, "In accordance with the purpose and intent of the Federal Regulations stated in 10.CFR.50, Appendix B, the enclosed Quality ,

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Assurance Manual is adopted for our company". This QA Manual

• l . included the procedures referenced in Item 1.B above, and was signed by the President of ATl on March 17, 1978. We believe that the signature of the President of ATI constitutes an indication of proper review and approval.

With respect to the Insp e.: tor 's finding that "The content of the procedures (ATI's) were also inadequate in comparison with the ,

AEPSC established procedures for the IEB 79-14 evaluation work", we refer you to our response to Items.l.A and 1.C, below.

i ITEM 1.C "There was no design specification developed by AEPSC for the ATI work to define the design responsibilities, interf ace control, code applications, loading combination methods, design review verification, and acceptance criteria for piping and critical components and equipment. The ATI final stress calculations and reports were not reviewed and accepted by AEPSC.

During discussions, the inspector was presented a typical ATI I report, " Analysis of As-Built Piping", which was reviewed and approved by individuals other than the preparer. The backup i

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computer runs, manual calculations, and review documentation were I

maintained at the ATI office. The inspector stated that the methodology and criteria included in the report lacked specificity

and definition.

The inspector stated that the AEPSC design control over the contractors was considered to be insufficient. Without formally established design specification, work procedures, and QA overview, the quality of the work involved and the extent of design review verification effort can not be casily assessed. This is a violation. (315/82-07-01; 316/82-07-01)".

REEPONSE TO ITEM 1.C (1) Corrective Action Taken and Results Achieved As noted in the NRC Inspection Report AEPSC presented the following progran at the exit interview to Mr. I. T. Yin, Region III NRC

! Inspector:

"AEPSC shall re-review the consultants' work procedures for analysis in effect at the time of the work and compare them to the AEPSC program for verification of the existence of adequate controls.

Personnel qualifications will be reviewed.

l AEPSC, possibly assisted by an outside vendor, will conduct an audit to verify that calculational procedures were followed and that problem input and output are correct. AEPSC will use approved checklists.

] The extent of the audit would be as follows:

Firm Performing No. of Problems Problems to Analysis Reanalyzed be Verified ATI 32 4 EDS 33 4 liars tead 4 1 Teledyne 2 1 71 10 An interim report will be submitted by 11/1/82."

l l The above program for re-verification of analytical work was presented to the inspector, Mr. Yin. The inspector stated that the licensee's plan as stated above appeared to be acceptable. Our progress to date is as follows:

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A) A re-review of the consultants' work procedures for analysis in effect at the time of the reanalysis is now i in progress.

i B) Resumes of ATI personnel with technical input into the IEB 79-14 analysis have been reviewed and judged to be qualified. ,

l C) As of this date, the AEPSC audit of the problems to be  ;

verified has been started with the following results:

(C.1) A checklist is nearing completion for the verification of piping analysis problems performed by outside consultents.

(C.2) One piping problem, No. 1-055, by ATI, has been 1 verified and found to ir. corporate the correct .

calculational procedures.

1 (C.3) Further verification of the additional problems noted in the table cited above are in progress.

(C.4) The completion of the above plan will assure

! that Design responsibilities, interface j control, code applications and loading  !

l combinations were p roperly applicd by the outside consultants in the piping analysis performed for AEPSC. l (2) Corrective Action to be Taken to Avoid Further Non-Compliance l

The AEPSC Design Division Procedure No. 1-18, " Consultants and Outside Design Services", is being revised. Revision 4, to be issued by June 15, 1982, will include sections on " Verification

. Activities" and " Acceptance of Services". AEPSC Design Division training will emphasize the implementation of Procedure I-18.

(3) The Dats When Full Compliance Will be Achieved

, i l As indicated to Mr. Yin at the exit interview on April 15, 1982, an i interim report on the total program will be provided by November 1982. The final report, following completion of the review will be

{ provided by January 1983. '

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