IR 05000282/1992025
| ML20128A366 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/26/1993 |
| From: | Falevits Z, Jablonski F, Walker H, Ward K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20128A308 | List: |
| References | |
| 50-282-92-25, 50-306-92-25, NUDOCS 9302020201 | |
| Download: ML20128A366 (13) | |
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S. IlUCLEAR REGULATORY COMMISSIOli
REGION III
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Reports No. 50-282/92025(DRS); llo. 50-306/92025(DRS)
Docket Nos. 50-282; 50-306 Licences Ho. DPR-42; No. DPR-60 Licensout Northern States PoWor Company 414 Nicollet Hall Minneapolis, MN 55401 Facility Names Prairio Island Nuclear Generating Station Units 1 &2 Inspection At Prairio Island Site - Welch, MN Inspection conducted:
November 9 - December 18, 1992 Inspectors:
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j // Q N. A. Walko'r Q6to/
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2. Falovits Dato he hd r,{
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K. D. Ward Dato Approved By:
/24[h]_
F.'J.
Jablonski, Chief Date Maintenance and Outages Section Inspection Summary laspection conducted November 9 - December 18. 1992 (Recorts No. 50-282/92025(DRS); No. 50-3 06 / 9202 5 ( DR,S.L)
Areas Inspected:
Special unannounced inspection to follow up on concerns with quality control (QC) inspection and inspection support activities.
The areas reviewed woro normal plant inspection activitios and those associated with the station blackout /olectrical safeguards upgrado project.
The NRC inspector utilized portions of NRC inspection proceduros 35701 and 35702.
Ronults:
Tho QC inspector cortification program was inadoquato.
Weaknessos woro noted in program content and implementation.
Weaknessos in the quality assuranco program allowed some inspection personnel to be certified with little or questionable applicable exportise and experience.
In some cases, recurring.
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weaknesses, which were self identified during audits, had not 9302020201 930120 PDR ADOCK 05000202
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Inspection Summary
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been corrected.
One' violation was identiflod this violation
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included one example of. inadequate procedures and three examplos
of failure to follow procedures (Sections 2.1.1, 2.1.2, 2.1.3.1 and 3.1) in inspector certification and related areas.
Throo unrosolved items were identified maintaining proficiency for j
inspectors with multiple cortifications (Section 2.1.3.2), the
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program for cortifying inspectors outside the QC organization and maintaining independence for thoso inspectors (Soction 2.1.3.2),
i and tho adequacy of QA audits in identifying and resolving problems (Section 3.2).
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DETAILS e
s 1.0 Principal Persons Contacted llorthern Stittes Power Company (NSP)
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Albrecht, General Superintendent, Engineering
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Goldsmith, Station Blackout program Manager
- P. Kamman, Manager, Nuclear Operations, Qaality Assuranco
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Kleo, Superintendent, Quality Engineering
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McClausky, Quality Services
+*J. Mcdonald, Superintendent, Sito Quality Assurance.
- D. Mendolo, Director, Power Supply Quality Assurance D.
Perrino, Startup Manager
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Rothstoin, Senior Quality Specialist
- M.
Sollman, Plant Manager
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Watzl, Site General Manager U.
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Nuclear Reculatory Commission _
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Dapas, Senior Resident Inspector
- B.
Jorgenson, Section Chief, Projects section 2A
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Schweibinz, Senior Project Engineer
- Denotes those present at the exit meeting hold December 11, 1992.
+ Denotes those present at the supplemental exit meeting-held December 18, 1992.
Other persons were contacted as a matter of course during the inspection.
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2.0 (Closed) AMS NO. RIII-92-A-0101 E
Concerns regarding QC inspector certifications, adequacy =of QC.
inspections, and validity.of quality-records including those associated with the station blackout / electrical safeguards upgrado (SBO/ESU) project.
2.1 Concern No. 1 - Inadeauato Inspector Certification
Ernaran The concern was that the QC inspector certification programs used by NSP and NSP contractors, who supply _QC inspectors, were-inadequate and did not comply with regulatory requirements.
There was_also concern that some QC inspectors had been improperly certified, and that some resumes and'other qualification documents, the basis for the certificatione, were falso.
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The NRC inspector reviewed NSP's program for certifying QC inspectors for adequacy and compliance to regulatory requirements.
The inspector also reviewed program implementation for effectivenees and compliance, and reviewed certification records for irregularities and indications of a lack of authenticity.
This concern was substantiated in some areas.
Deficiencies were noted in the QC inspector certification program and the described program was improperly implemented.
2.1.1 lic1[nw_01. N S P ' s Q.C_LDEng e t o r Gp r t i f i c atiq11]Ipfgram The NRC inspector reviewed Section 1.2, Paragraph 9, and Section 12.14, Paragraph 3, of the Northern States Power Company Operational Quality Assurance Plan, and noted that both sections required compliance to ANSI H45.2.6-1978 as modified by Regulatory Guide 1.58, Revision 1, for qualification and certification of personnel performing inspections.
The QC inspector certification program was documented by management dircctives and implementing procedures.
The NRC inspector reviewed the following documentat Corporate Nuclear Administrative Control Directive N1ACD
3.2,
" Qualification and Certification of Inspection, Examination, and Testing Personnel," Revision 1 Administrative Control Directive SACD 3.21, " Qualification
and Certification of Inspection, Examination, and Testing Personnel," Revision 1 Chapter 1 of the Inspector certification Manual,
" Qualification and Certification of QC Inspection, Personnel", Revision i Section 6.6 of Directive SACD did not require a high school education or a GED equivalent, which is an education requirement of RG 1.58.
The requirements were not included in the appropriate sections of the Inspector Certification Manual.
In discussions with licensco personnel, the NRC inspector noted that the requirements were unknown to some key personnel and were not being implemented.
One example was noted where a certified level III QC inspector passed a high school level GED test after certification.
The wording used to include the education information on resumes was inconclusive as to whether a high school diploma was actually received or not.
The failure to include the requirements of RG 1.58 in these directives and the Inspector Certification Manual, which delineate the requirements for qualifying QC inspectors, is considered an example of a violation of Criterion V of 10 CFR 50, Appendix B (282/92025-01A(DRS); 306/92025-01A(DRS)).
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2.1.2 Ren9IALReYleM sLQC._ingnostar Cortif1 cation Packagen i
The NRC inspector reviewed cortification packages for a number of QC inopoctors.
This review included cortifications for both
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Lovel II and Lovel III inspectors in various disciplines.
The NRC inspector noted that in some cases, non-applicable experience was used to cortify both Level II and Loyal III inspectors in both plant maintenanco and ongoing plant modifications, which included the SB0/ESU and cooling water projects.
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with 11conson personnel verified that experience, other than i
related exporlence in inspection, examination and tanting, an
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required by RG 1.58 and the cortification manual, was accepted to cortify inspectors.
The requiremont for related experienco in inopoetion, examination and testing, was unknown to somo key i
porconnel, including management.
Journoyman or craft experienco was routinely accepted an qualifying experience for inopoctor cortification.
Based on this practico, it appeared that a significant number of inapoetion personnel had been-improperly cortified.
The NRC inopoctor
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verified, through a review of a number of inspector cortification packagon, that como Lovel II and Loyal III inspectors woro not
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appropriately certified in somo disciplinos.
In other instancos, journoyman or craft experience in the cortiflod discipline wan-not evident and the related experienco was inadoquato for cortification an an inspector in the roupoetivo disciplino.
No plant equipment problems woro noted due to this practico.
Six Lovel III cortifications for two inspectors woro datormined to be i
invalid by the NRC inspector due to inappropriato experience.
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Impropor cortification of Lovel III inspectors would invalidat a
any Lovel II cortifications mado by those Lovel III inspectors.-
The failure to follow the applicablo experience requiromonto of N1ACD 3.2, SACD 3.21, and the appropriato sections-of the Inspector Cortification Manual is considorod an example of a violation of Critorion V, of 10 CFR 50, Appendix B (282/92025-01B(DRS); 306/92025-01B(DRS)).
2.1.3 Enyiew oLCnIt.Lf1G.ation Packanes for SB0/ESU OC l
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The NRC innpoctor reviewed the certification-packages for Qu inspectors who performed inspections for the SB0/ESU project at the time of inspection as well as selected packages for somo i
inspectors who woro no longer at the plant.
Of those packages reviewed, two Lovel II olectrical inspectors had questionablo cortifications.
The first lacked applicable experience and the other had conflicting statomonts in the supporting resumo.
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inspectors had performed inspections on the SB0/ESU project.
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Liconaco personnel reviewed inopoction records to determino the
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inspections performed by those two inspectors.
The inspection'
work was-ovaluated and, in some casos, the hardware was-reinspected.
Discussions with licensoo personnel and a review of
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information.provided on the evaluation indicated problems with incomplete inspection records prepared by one of the inspectors.
Since these inspection records had been completed and were filed,
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inadequate review of completed inspection records was evident.
This matter was discussed with licensoo personnel.
The NRC inspector reviewed the results of the evaluation and reinspection effort and has no further concerns in this area.
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2.1.3.1 kvalification Evaluation Forms The NRC inspector noted that, in some cases, the Qualification Evaluation Forms, Form 1-3011, required by Section 5.1.2 of Chapter 1,
" Qualification and Certification of QC Inspection, Personnel," Revision 1, of the Certificetion Manual, were not
always used.
In most cases, when the evaluation sheets were
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included, the sheet did not actually indicate that an evaluation
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was perform 1d but contained nondescriptive statements such as
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"see resume".
Licenseo personnel. reviewed all certification packages for missing evaluation forms.
Current evaluations were to be performed for those inspectors for which the forms were missing.
The failure to follow procedures in evaluating inspector qualifications is considered an example of a violation of Criterion V of 10 CFR 50, Appendix B (282/92025-01C(DRS);
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306/92025-01C(DRS)).
2.1.3.2 MuJtiple Certifications
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There were 47 Level III certifications (29 individuals) and 146 Level II certifications which included many individuals with certifications in multiple areas.
One individual was certified in six disciplines.
Maintaining proficiency in multiple disciplines is of concern.
This item is unresolved and will be reviewed on a su'osequent inspection (282/92025-02 (DRS);
306/92025-02 (DRS)).
Many certified inspectors were not in the QC organization.
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certification of inspectors outside the QC organization and maintaining the required independence of these inspectors is of concern.
This item is unresolved and will be reviewed on a subsequent inspection (282/92025-03 (DRS) ; 306/92025-03(DRS)).
2.1.4 gprtification of Contracted OC Inspectotg; The NRC inspector noted that most QC-inspectors used on the SB0/ESU project Ten o supplied by contractors and that contractor-
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inspection personnel were required to be certified'to the licensee's inspector certification program.
There were no purchase order requirements for the contractors to supply
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certified inspectors.- During the review of inspector
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certification packages, the NRC inspector noted that inspector certifications from one contractor were included in some packages aa backup information.
A review of the contractor certifications
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indicated that several of the inspectors, certified by the contractor, did not have the necessary applicable experience to justify the certifications.
This indicated a significant weakness in the contractor certification program; however, since inspectors were required to be certified by the HSP QC inspector certification program, this was not a problem at Prairie Island.
t 2.1.5 Validity of Inspector Certification Records The concern was that resume information, used for certification l
of QC inspectors, did not accurately reflect experience and-education.
The licensee did not verify information that was provided in resumes as qualifying experience for inspector certification.
During the review of inspector certification packages, the NRC inspector noted irregularities in three of the certification packages.
These irregularities were not checked to verify the accuracy of the information.-
The resume for one Level II electrical inspector indicated
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that the inspector had boon previously certified as a Level 11 electrical inspector at another nuclear power plant.
The resume actually showed less than a year of applicable experience which was considerably less than the experience required for certification.
The resume for one Level II electrical inspector indicated
that the inspector had worked at three places at the same time.
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The resume for one Level II clectrical inspector indicated
that the inspector graduated from high school in 1961; yet another document indicated that he had passed a high school level GED test since coming to Prairie Island.
These items indicated inaccurate and possibly false information.
Licensee personnel stated that resume information was not verified and that there were no requirements for contractor verification.
The inspector was unable-to gather sufficient l
Information to conclude whether the records were indeed false, therefore the concern could not be substantiated; however, the L
practice of not performing any verification of resume information appeared to be a significant program weakness.- Except for the t
l first case above, the_potentially false information did not-appear to be significant to the individual's' certification.-
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the first case, the licensee re-examined the inspector's work-as-discussed in-paragraph 2.1.3 of this report.
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l 2.2 Concern Np. 2 -_ Invalid or Innroporly Disgardnd Ouality l
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The concern was that quality documents, such as nonconformance
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reports, chart recordings, work requests and test records, woro being or had boon falsified or improperly discarded.
The concern was not substantiated regarding falsification.of records; however, some record irregularitics woro noted and ono nonconformance report (NCH) was inappropriately closed' prior to completion of required action.
The concern on invalid chart recordings could not be investigated due to insufficient information.
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The NRC inspector reviewed selected Startup Work Requests (SWRs),
Startup Test Records, and nonconformanco reports for
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irregularitios or other evidence-of falsification.
Selected NCRs were also reviewod for impropor resolution or discarding prior to appropriato action.
In addition, the mattar was discussed with a number of QC inspectors for concerns or additional information.
2.2.1 Rgylaw of Startup _ Wor}: Reauests The concern was that some revisions to startup work requests
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(SWRs) woro initialed by others and were not routed to QC for review and designation of inspection points.
The concern could not be substantiated; however, the uno of the stamps to.-indicato required inspection points would seem to indicate that the documents received the appropriato review by QC supervision.
Tho NRC ir.spector reviewed SWRs 1499 and 1500 and noted that the revised sections of the documents contained designated inspection points indicated by stamps which woro only available to the-QC organization.
Tho.QC supervisor indicated that he was not sure if. ho reviewed and initialed the docume nt or not.
Sinco many QC inspection points woro_ included'.in the revised sections, thero would appear to be very little impact on the inspection of SDO/ESU equipment.
2.2.2 Reylew of startun Test R u tda The concern was that steps of some startup test records woro signed off even though the specified: tests-were not completed.
The concern of-tho-falsificatjon.of recordsJwas not substantiated,.although completing tost proceduro entries on a date other than whenfthe_ work was performed appeared to bo a poorL practico.
The NRC: inspector reviewod the startup test records for_ procedure
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SBO-DG-602, "D6 Dional Engine-#1 Initial Run," Hovision 0, to-datormino if.the rccords woro: valid.
Steps 7.21.5 through 7.21.8 and Steps 7.22.6-through 7.22.8'of the proceduro required-that L
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the diesel engine be started and specific engine cooling system
inlet and outlet temperatures be monitored and verified to be within acceptable limits.
These steps of the procedure were
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initialed as completed on october 26, 1992.
The D6 diesel start log indicated that the engine did not run on this date.
The NRC
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inspector reviewed the Prerequisite Test - Chronological Log Shoot in the record package and noted that an entry on page 5 indicated that Sections 7.21 and 7.22 of the procedure were signed off based on temperature measurements taken during an extended test run on October 20, 1992.
The D6 diesel start log
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indicated that the engine did run on october 20, 1992.
The NRC inspector was told that chart recordings were maintained on the inlet and outlet temperatures and the inspector reviewed these
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chart recordings.
2.2.3 Re.ylew of Nonconformance Renorts The concern was that some nonconformance reports (NCRs) were closed without the completion of action to correct the noted problem.
The concern was substantiated for one NCR; however, the-problem appeared to be an inadvertent omission in the transfer of documented information.
The NRC inspector reviewed selected NCRs for appropriate corrective action and cJntrol including a review for closing-NCRs without appropriate action.
During the review, the NRC inspector-noted that Gurveillance Report 0535 was written to combine several noted instances of failure to comply with electrical cable separation requirements, which had been documented on five separate NCRs, into one document.
Open Surveillance Report (SR)
0535-B was reviewed and the NRC inspector noted that the cable separation problem documented on NCR 549 was not included.
NCR 549 referenced SR 0535 as justification for closing the'NCR.
The NRC inspector discussed tne matter with licensee personnel and a
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revision to SR 0535, 0535C,1was initiated to add the omitted cable separation problem from NCR 549 to the SR.
The NRC i
inspector was also told that an engineering review of the entire SD0/ESU electrical system for cable separation problems was in process.
The NRC inspector considered the closing of NCR 549-without ensuring that the documented cable separation problem had been included in SR 0535 to be an error in the transfer of information between documents.
No other incidents of the same-type problem were noted.
This was another incident that indicated a-weakness in the review of documents; the matter was discussed with licensee personnel.
In addition, other instances of possible inadequate corrective action were noted.
Several instances were noted where hardware was repaired or the NCR dispositioned "use as is" with no action
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taken to notify the-individual responsible.
One NCR described a problem asLan isolated case; yet, ten instances of.the same problem were documented on the same NCR.
One NCR, written on the
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failure to control soldering as a special process, was dispositioned "use as is" with no corrective action required.
Although not noted on the NCR, a procedure to control soldering
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as a special process was issued a few days after the NCR was closed.
Although individually these items do not represent a significant problem, more positive action to ensure adequate corrective action is necessary.
During discussions with licensee personnel, the NRC inspector was told that the plant had recently discontinued the NCR process and had gone to the Nonconforming Item Report (NIR) and Honconforming Activity Report (NAR) system which was currently in use at the plant.
Under this cystem, effort would be made to provide more positive control of the corrective action process, 2.3 Concern No. 3 -Innppropriate Use of Instrumentation Lggp Drawingg The concern was that station blackout instrumentation had been reviewed and inspected by Quality control using loop drawings that were not to be used for such inspection purposes.
The NRC inspector concluded that testing of instrumentation loops was appropriate and adequately verified proper instrument operation.
The concern was not substantiated.
The NRC inspector reviewed a letter (ESU-2629), dated May 18, 1992, which stated, " instrumentation loop drawings should only be used for reference."
The NRC inspector reviewed the information used to establish testing requirements for SBO instrumentation loops and discussed the issue with startup personnel.
The NRC inspector was told that the instrumentation loop drawings were only used for reference in preparing tests and performing maintenance activities and at no time were the loop drawings used for the conduct of testing.
Instrumentation loop drawings had been updated and were current at the time of the inspection.
2.4 Concern No. 4 - Elimination of OC from Safety Related E E q 9 I M Ji The concern was that the licensee had written all QC out of safety related programs.
The concern was partially substantiated; however, the climination of QC inspection points from the procedures could not be determined to have a direct safety impact.
The NRC inspector discussed tnis matter with licensee personnel; QC inspection points had been removed from most plant maintenance procedures and were being removed from the balance of the plant maintenance procedures.
QC inspection points were to be retained by routing maintenance work requests (MWRs) through QC where the work requests would be reviewed for possible designation of inspection points.
The inspection points would be specified during this review.
No inspection points would be required each
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time a specific job was performed but inspection would be provided on a sampling basis.
Sampling levels for inspection points would be maintained above five percent.
This practice
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appeared to be a substantial reduction in QC inspection and did not appear to ensure that crucial points of critical work activities were inspected each time the work was performed.
Although the new method is not prohibited by regulatory requirements, it appeared to involve less QC inspection and an inconsistent application of inspection activities.
Although QC was not completely eliminated from the safety related programs, designated QC inspection points were eliminated from plant maintenance procedures.
3.0 Other Items Reviewed Qurina The Insnection During the inspection, additional items were noted and reviewed which were not within the original scope of the inspection.
These items are discussed in the following sections of this report.
3.1 Hpidina Manual Channes During the inspection, the NRC inspector noted that changes had been made to the Welding Manual by letter rather than the
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revision methods described in NlACD 2.2, " Document Review and Approval," Revision 5.
Discussions with licensee personnel indicated that the problem of improper changes to the welding manual had been noted in previous QA audits.
The NRC inspector reviewed audit records for audit AG 91-46-18 (conducted October 8 to November 15, 1991), and noted that problems with changes to.
the welding manual were noted but were not issued as findings.
Licensee personnel stated that findings were not-issued because the problem was noted in a nonsafety related area.
However, recommendations were made to develop a~procedurn to control revisions to the Welding Manual.
Changes had been and were continuing to be made by letter rather than.using the revision methods specified in NIACD 2.2,
" Document Review and Approval,
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The failure to. follow procedures in making changes to the Welding Manual is considered an example of.a violation of Criterion V of 10 CFR 50, Appendix B-(282/92025-01D(DRS);
306/92025-01D(DRS)).
One violation was noted in the review of this area.
3.2 Ouality Assurance Audits of Inspection The NRC inspector reviewed audit reports of four QA audits of inspection activities conducted over the past 18 months.
The audit report for an audit of QC inspector certifications conducted May 1 to-Hay 15, 1991, stated, "The certification records were sampled for 19 of 24 QC inspectors at Prairie
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Island.
All of the certifications sampled were verified to have
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t met education and experience requirements of the Certification Manual."
The use of inappropriate experience to certify inspectors was not noted.
In reviewing the audit reports, the
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NRC inspector also noted that there were concerns or problems documented in the audit reports with no findings or recommendations for correction and no reference indicating the problem was addressed.
In addition, some audit findings that
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were issued appeared to be closed without adequate corrective I
action.
The matter of adequate QA auditing and ensuring i
resolution of noted problems is considered to be an unresolved item and will be reviewed on a subsequent inspection (282/92025-04 (DRS); 306/92025-04 (DRS)).
One unresolved item and no violations or deviations were noted in the review of this area.
4.0 Field Verification for Hardware Imnact s
In order to determine if the lack of adequate QC inspector certifications had affected the installation and modification of equipment, NRC inspectors reviewed selected portions of equipment installed or modified for the SBO/ESU project and other work performed during the current outage.
Both electrical and mechanical installations were inspected for compliance to design documents and for good workmanship.
The inspectors determined that the installations examined
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generally conformed to design requirements.
Good workmanship and
engineering prnctices were evident and personnel appeared to be knowledgeable in assigned areas.
No violations, deviations or significant discrepancies were noted.
4.1 Mechanical and P3nina Installations
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The NRC inspectors compared the fabrication and installation of piping system components:to the latest design drawings.' Ten piping systems were reviewed.
Field measurements were taken and compared to design documents and installation work was inspected for good workmanship and general appearance.
From the design drawings the NRC: inspector verified correct configuration,
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location, dimensions and clearances, and the correct components-
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and materials.
No discrepancies were-noted and the-installation work appeared to be good.
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In addition, the NRC inspector reviewed selected-NCRs, welder l
qualification / certification reports,' welding procedure-
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specifications, NDE reports and procedures 3._-and--pressure test
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reports.. The NRC inspector also discussed the work with-the-
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-Authorized Nuclear Inservice Inspector (ANII).
The:ANII-had inspected many-areas during-the modifications and had observed l
all pressure-tests.'
Noted problems had been corrected and the l
ANII had no concerns about the field installations.
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4.2 JileqtIlgal_lnni;allatigna The 11RC inopector reviewed the installation of 4.16Kv cwitchgear, 480 volt switchycar and motor control centers, cable tray inctallations including fill and nupporto, cable installationa including routing and separation, and the adequacy of terminations for compliance with applicable design drawings (including ongineering change requests) and established codes and standards.
The 11RC inspector also reviewed cable and conductor identification, component labeling, nameplaton, breaker /otarter cizen, thermal overload sizen, fune nizes, and crimping of cable lugs for compliance with requirements.
The 11RC innpector also observed several work activitico that involved engineering, craft and QC inspectors.
The liRC incpector noted some inconsistencies between the drawingo and the electrical cable data base.
In addition, come inconsistencies were noted with the labeling and rating of come AC fusen.
Licanuco personnel stated that these inconsistencies would be corrected and immediately began action to correct the differences.
The noted differences were minor and did not affect equipment operability.
5.0 Unresoly_gtl__ltana An unresolved item in a matter about which more information is required in order to accertain whether it la an acceptable item, an open iter, a deviation, or a violation.
Throo unresolved itema were noted during this inspection; two of these itema are diccunned in Section 2.1.3.2 and one in Section 3.2 of this report.
6.O Exit _lignting
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The Region III inspectors met with the licensee's representatives (denoted in Paragraph 1) during the inspection period and at exit discussions held on December 11 and December 18, 1992.
The inspectors summarized the scope and results of the inspection findings.
The inspectors discussed the likely informational content of the inspection report with regard to documents and proccases reviewed by the inspectors.
The licensee acknowledged the information and did not indicate any of the information disclosed during the inspection could be considered proprietary in nature.
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)