ML17321A331

Responds to NRC 841026 Ltr Re Violations Noted in Insp Repts 50-315/84-16 & 50-316/84-18.Corrective Actions:Plant Commitments Generated as Result of NRC Insp Repts Will Be Tracked

ML17321A331
Person / Time
Site:	Cook
Issue date:	11/28/1984
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17321A330	List: IR 05000315/1984016 ML17321A331
References
AEP:NRC:0911, AEP:NRC:911, NUDOCS 8412100237
Download: ML17321A331 (12)

See also: IR 05000315/1984016

Text

INDIANA 8 MICHIGAN ELECTRIC COMPANY P.O.BOX 16631 COLUMBUS, OHIO 43216 November 28, 1984 AEP:NRC:0911

Donald C.Cook Nuclear Plant Docket Nos.50-315 and 50-316 License Nos.DPR-58 and DPR-74 NRC REPORT NOS.50-315/84-16(DRS);

50-316/84-18(DRS)

Mr.James G.Keppler U.S.Nuclear Regulatory

Commission

Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Dear Mr.Keppler: This letter responds to Mr.R.D.Walker's letter dated October 26, 1984 which forwarded the subject Inspection

Report of the routine safety inspection

conducted by your staff at the Donald C.Cook Nuclear Plant and AEPSC Corporate offices in Columbus, Ohio during the period August 7, 1984 through October 18, 1984.Per discussion

with Mr.F.Hawkins of your staff on November 26, 1984 an extension to December 3, 1984 was granted for the response to this inspection

report.The Notice of Violation attached to Mr.Walker's letter identified

two items of noncompliance, one of which (Item 2)requires no response.The following is our response to Item 1: ITEM OF NONCOMPLIANCE

-1"10 CFR 50, Appendix B Criterion XVI, as implemented

by the Donald C.Cook Operations

guality Assurance (gA)Program, requires that measures be established

to ensure that conditions

adverse to quality are promptly identified

and corrected.

Contrary to the above, the following examples of untimely or inetfective

corrective

action were noted.a.The commitment

date of February 1984 for full compliance

in establishing

and implementing

a guality Control (gC)inspector qualification

program for the D.C.Cook plant was not met.b.Responses to Corrective

Action Requests (CARs)were consistently

late.The report of overdue CARs issued August 9, 1984 listed 61 overdue CAR responses.

c.A Corrective

Action Request was not issued on the failure to perform required limit switch testing during the 1983 Unit 1 refueling outage.This problem was noted by the American Electric Power Service Corporation (AEPSC)auditor in audit gA-84-06 but the auditor did not submit the item as a finding for required corrective

action." 7 8gg208~g,goCY pDR aqggi00~05Q00

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Page 2 AEP:NRC:0911

RESPONSE TO THE ITEN OF NONCOMPLIANCE

a~Within this report it is stated that this item had been identified

previously

by the Resident Inspector in August, 1983 (315/83-12-03;

316/83-13-02).

In reviewing this report, it appears that the noncompliance

was initiated due to the following: "Inspection

acti,vities

during this;period

resulted in finding that personnel assigned responsibility

for performing

ice condenser basket weight surveillance

testing were not certified to be qualified to perform this task.Further review determinedthat, the commitments

to certify personnel according to the'r'equirements,'f

ANSI N45.2.6 had never been implemented

for plant personnel who perform surveil,lance

testing, inservice tests and inspection.

Interestingly, contractor

quality assurance programs were responsive

to the plant's commitments

in this area.There was no evidencethat the failure.to certify these personnel resulted in questionable

performance

of tests, and inspections.

10 CFR 50 Appendix B Criterion II requires that quality assurance program be documented

by written instructions, proce'dures

or policy.This aspect of the program doe's not comply with this requirement

and constitutes

an item of noncompliance

as documented

in the Appendix (315/83-12-03 (DPRP);316/83-13-02 (DPRP))." This was further expanded on in the item of noncompliance

referenced

in the above IE Report 315/83-12;

316/83-13 in which the following was stated: "10 CFR 50, Appendix B, Criterion II states in part..." This[guality Assurancej

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.

..The program shall take into account the need for special controls, processes, test equipment, tools, and skills to attain the required quality, and the need for verification

of quality by inspection

and test.Donald C.Cook Units No.1 and 2 FSAR Section 1.7.19.2 describes the quality assurance program and commits to comply with the requirements

of Regulatory

Guide 1.58 and ANSI Standard N45.2.6-1973.

Commitments

and exceptions

to the revisions of the requirements

concerning

gualifications

of Inspections, Examination, and Testing Personnel were revised by letter dated September 14, 1981 (AEP:NRC:00567).

Contrary to the above, requirements

the licensee committed to in the 1973 and 1978 version of ANSI N45.2.6 were not implemented

by written policies, procedures, or instructions.

These include: a.Certification

of personnel qualification

b.Documented

determination

of activities

individuals

are certified to perform c.Initial and periodic evaluations

of job performance

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Page 3 AEP:NRC:0911

d.Specification

of required physical characteristics.

e.Maintaining

records of the above" This citation was not directed specifically

at gC inspectors

as the gC Department

was formed in July, 1983, and the gC Section of inspection

type personnel did not become a reality until February, 1984.Corrective

Action Taken and Results Achieved In our response of September 6, 1983, to Inspection

Report 83-12;83-13 (AEP:NRC:0847), we stated the following: "In order to make our program more responsive

several of our Plant Manager Instructions

will require revision.Our current plans are to have the applicable

instructions

revised and implemented

by the end of February 1984." With the advent of the Regulatory

Performance

Improvement

Program and the changes brought about by this program, the magnitude of this effort increased substantially.

The Plant and AEPSC have been working jointly on a Corporate Level procedure, that will encompass both the Corporate Office and the Plant relative to those personnel who require certification.

This procedure should be issued no later than March 30, 1985.Since February, 1984, gC personnel have been performing

one of two tasks;either monitoring

work in progress which would'nsure

that an inspection

is performed by personnel as defined within our FSAR, or are performing

the inspection

themselves.

When a C Technician

is assi ned to erform an ins ection, this individual

receives a ro riate trainin w ich is ocumented.

T is documente trainin is consistent

wit our res onse to NRC Generic Letter 81-01 AEP:NRC:00567, 9/14/81 as acce ted b NRC Var a to Dolan, 4/9/82.In addition, the P ant guality Contro Department

has prepared two instructions/procedures

that define the training and certification

process required to meet the intent of ANSI N45.2.6-1978.

The instruction

was issued on November 13, 1984.The procedure that will implement this instruction

is in the draft stage and is scheduled for approval by December 31, 1984.This procedure will complement

the Corporate Procedure prepared for the certification

process.Corrective

Action to be Taken to Avoid Further Noncom liance One of the activities

assigned to the guality Control Department

is that of tracking commitments

to the Nuclear Regulatory

Commission.

Plant commitments

generated as a result of NRC Inspection

Reports are now placed on the gC Superintendent's

weekly Letter to the Plant Manager and applicable

Department

Heads.This listing provides the Plant Manager with the following information:

Description

of the Response or Commitment, Department

Assignment, and Due Date of Commitment.

In

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Page 4 AEP: NRC: 0911 addition, one individual

in the guality Control Department's

Administrative

Compliance

Section has been designated

to follow NRC commitments.

This individual

will contact and advise personnel of approaching

due dates and will take the necessary action to advise management

of any dates in jeopardy so that appropriate

action can be taken.Date When Full Com liance Will Be Achieved b.Partial compliance

with this item will be achieved with the issuance of the procedures

for Corporate and Plant certification

and Plant guality Control certification

scheduled for March 30, 1985 and December 31, 1984 respectively.

However, full compliance

will require varying degrees of additional

training f'r personnel affected by these procedures, before they can be deemed fully certified.

It is expected that the required training and certification

activities

for the current gC staff will be completed by December 31, 1986.The program defined by the corporate procedure for other personnel will be implemented

on March, 30, 1985.Full compliance

for all other, personnel requiring certification

will be achieved upon satisfactory

completion

of the training defined within the approved accredited

INPO training program.The cause for this"noncompliance

was a misunderstanding

on the part of the plant staff as to what actions were required in order to respond to a guality Assurance Audit Corrective

Action Request (CAR).This misunderstanding

came about due to the lack of clarity of the instructions

for responding

to audit CARs as contained in both plant and corporate procedures.

Correction

Action Taken and Results Achieved Prior to this inspection, a list of overdue responses to gA audit CARs had been sent to senior corporate management

for resolution.

As a result of this escalation, several discussions

were held with the Cook Plant Manager to clarify the situation and to establish a schedule for submitting

the required responses.

Responses to the overdue gA audit CARs were received from the Cook Plant Manager on September 5, 1984.Corrective

Action To Be Taken To Avoid Further Noncom liance Both the plant and corporate procedures

governing gA audits have been revised to clarify the instructions

pertaining

to how to respond to gA audit CARs.

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Page 5 AEP: NRC: 0911 In addition, the manner in which gA audits are made final has been revised at the request of the Cook Plant Manager.Tentative corrective

actions and assignments

for taking such actions will be resolved at the formal audit exit meeting, thereby eliminating

the delay previously

inserted by waiting for action assignments

subsequent

to the Plant Manager's review of the audit report.The Cook Plant Manager has made a commitment

to keeping plant responses to gA Audit CARs current so as to be in compliance

with the established

requirements.

Data When Full Com liance Will Be Achieved C.Full compliance

was achieved on September 5, 1984.gA Audit 84-04, Item 06,"recommended" that certain Cook Plant Maintenance

Department

refueling procedures

and the 1983 Unit One Westinghouse

refueling procedure be reviewed and revised, as necessary, to cross reference all applicable

plant and vendor procedures

which accomplish

the same objectives.

This recommendation

was made after an auditor noted that neither weekly limit switch testing nor testing on a shift basis of the refueling crane paddle limit switches as required by Plant Maintenance

procedures, had been conducted during the 1983 Unit One refueling by Westinghouse.

gA audit procedures

define the terms"recommendation" and"deviation".

In light of a strict literal interpretation

of these definitions, Item 06 should have been classified

as a"deviation" and a corrective

action request issued.It must be pointed out that even if audit item 06 had been classified

as a"deviation", corrective

actions beyond those described below would not have been applicable

since the audit was conducted after the refueling outage was over and during a time period in which backfitting

the test was not possible or meaningful.

Corrective

Action Taken and Results Achieved The gA auditor, being aware of the problem, assured (through his personal review)that subsequent

revision of the Westinghouse

refueling procedure more clearly reflected and defined the requirements

for the refueling crane limit switch test.In addition, he required that the procedure be modified to require signatures

verifying completion

of these tests.Corrective

Action To Be Taken To Avoid Further Noncom liance Since adequate program controls were in place (gA audit procedures)

which should have assured the correct classification

of audit item 06, the noncompliance

is attributed

to an oversight with respect to these controls.

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Page 6 AEP: NRC: 0911 The AEPSC Site gA Supervisor, who is responsible

for the final review and approval of site originated

audit reports, was well aware of the program requirements, further indicating

an isolated case of oversight on the part of gA personnel.

Several discussions

between the responsible

gA personnel have been held concerning

the cited non-compliance.

In addition, gA Audit Report 84-04 and NRC Report 50-315/84-16;

50-316/84-18

have been routed for required reading by all AEPSC site gA auditors.It is our opinion that these preventive

actions are adequate to preclude future occurrences

of this nature.Date When Full Com liance Will Be Achieved Full compliance

has been achieved as of the date of this response.I rs n This document has been prepared following Corporate'rocedures

which incorporate

a reasonable

set of controls to insure its accuracy and completeness

prior to signature by.the undersigned.

Very truly'yours, N..Al ich Vice President cc: John E.Dolan W.G.Smith, Jr.-Bridgman R.C.Callen G.Charnoff NRC Resident Inspector-Bridgman G.Bruchmann

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