ML20212E517

Provides Update Re Implementation of Insps & Expected Additions to QC Program,Per 10CFR50,App B,Criterion X.Work Activities Performed by Util & Contractors Discussed

ML20212E517
Person / Time
Site:	Cook
Issue date:	12/23/1986
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
AEP:NRC:0970A, AEP:NRC:970A, GL-81-01, GL-81-1, NUDOCS 8701050340
Download: ML20212E517 (4)

Text

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/ Dm2 INDIANA & MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 TRICRITT R Mil ign%r MNC: .y

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!hi December 23/[986 [j'yg AEP:NRC:0970A ==!

Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 .

Docket Nos. 50-315 and 50 -316 License Nos. DPR-58 and DPR-74 UPDATE ON QUALIFlCATION OF INSPECTION PERSONNEL Mr. J. G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

In a series of letters beginning with our response to Generic Letter 81-01, " Qualification of Inspection, Examination and Testing of Audit.

Personnel," Indiana & Michigan Electric Company (I6MECo) described the manner in which 10 CFR 50 Appendix B Criterion X, " Inspection," would be implemented at the D. C. Cook Nuclear Plant (Cook Plant). The purpose of this letter is to update you on how we are currently implementing inspections and expected additions to our quality control program at the Cook Plant. Accordingly, the commitments addressed in this letter supersede all previous commitments addressed in past correspondence. The correspondence which is now superseded includes our verbal and written responses related to Inspection Reports 83-12, 83-13; 84-16, 84-18; 85-16, 85-16; and 85-33, 85-33. We believe that the commitments in this letter are consistent with our obligations as described in our current Final Safety Analysis Report.

As described in Chapter 1 of the current Final Safety Analysis Report (FSAR), I&MECo is committed to ANSI N18.7 (1976), " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," and ANSI N45.2 (1977), " Quality Assurance Program Requirements for Nuclear Facilities,"

with several exceptions. I6MECo distinguishes the use of these two quality assurance standards in that significant recognition is given to quality control of work activities performed by I6MECo personnel who are qualified as per ANSI 18.1 (1971) and trained per INPO accredited programs.

Because contract personnel are not necessarily qualified to ANSI 18.1 and do not receive the systematic, periodic skills training inherent in the accredited training process, inspections conducted on activities performed by these persons are in accordance with ANSI N45.2 (1977) and ANSI N.45.2.6 (1978), o l TEL' l i l

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I Mr.: J. G. Kappler AEP:NRC:0970A I:

In view of these differences,.following are detailed descriptions of the  !

. . inspection programs with respect to who performs the work.

Work Activities Performed by I&MECo Personnel. Work functions associated with normal operation of the Plant, routine maintenance, calibrations, etc. , are routinely assigned to Plant personnel. I&MECo personnel who i

inspect this work are all qualified in accordance with ANSI 18.1,

" Selection and Training of Nuclear Power Plant Personnel," and are periodically trained in their skill area using INPO "accreditable" training. (Self-evaluation reports for all skills were submitted to INPO in June 1986,- with an expected site evaluation in May 1987.) As a result of the qualifications and training which I&MECo personnel receive, a peer inspection system is used. 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. Quality Control Department i personnel qualified to ANSI 18.1 will ensure (through surveillances) that l

inspections have been correctly implementnd and make routine reports to -

management.

t Work Activities Performed by Contractors. Major modifications,

, non-routine maintenance, and/or other services on safety-related equipment are generally performed by contractors who are required to

comply with the applicable requirements of ANSI N45.2. Inspections of i these work activities are performed by inspectors qualified and certified to ANSI N45.2.6, " Qualifications of Inspections, Examination, and Testing Personnel for Nuclear Power Plants." A peer inspection program is not 4

used for work activities performed by these personnel. To ensure inspector qualifications and certifications are met, we include specific requirements in our special provisions for contract terms which require j contractor inspection personnel be qualified to ANSI N45.2.6. I&MECo l quality control personnel who are also qualified and certified to ANSI N45.2.6 (1978) may perform inspections and/or surveillances of these activities.

Since the inception of the I&MECo Quality Control Department, work has taken place to qualify and certify our technicians to ANSI N'5.2.6. The attachment I to this letter shows the status of this effort. As an additional measure, we have' contracted with an outside Level III reviewer to independently examine 4

the qualification and certification packages of I&MECo's quality control j technicians. For those disciplines in which qualified and certified i- inspection personnel are.not yet available, contractor personnel who are certified to ANSI N45.2.6 and are working under an I&MECo-approved

} qualification and certification program are utilized.

To further enhance the peer inspection program, a quality maintenance team concept is being studied for implementation during the second half of 1987.

This program provides advanced quality control / quality assurance and radiation 1 protection programs training to maintenance crews. It is modeled after similar, very successful programs currently in place (or being implemented) in the Canadian nuclear industry and in several leading U.S. nuclear utilities, j We expect to provide further details on this program by June 1987.

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., e Mr. J. G. Kappler AEP:NRC:0970A This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Very truly yours,

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M. P. Alexich.

Vice President b Attachment cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman J. G. Keppler - Region III i

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^ ' *- Attachmant to AEP:NRC:0970A e

Ouality Control Denartment Quality Control Section - Total Technicians (10)

Mechanical Electrical E Civil Weldine '

Level I 2 Level IQ Level I Q Level I Q Level I Q.

Level.II Z Level II 1 Level-II Q Level II Q Level II 2 NDE Section - Total Technicians (7)

One Level III in PT, MT & RT Mechanical Electrical E Civil Level I Q Level IQ Level I Q Level I Q Level II 1 Level II Q Level II Q Level II Q Welding II liI ]J.I EI Level I Q Level IQ Level I Q Level I 1 Level I 2 Level II Z Level II Z Level II 2 Level II i Level II 1 AEPSC Corporate Level IIIs Mechanical Electrical 16,g Civil Welding Q l 2 2 1

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