ML19210E016
| ML19210E016 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/04/1979 |
| From: | Daniels F, Jackiw I, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19210E001 | List: |
| References | |
| 50-282-79-21, 50-306-79-18, NUDOCS 7911290164 | |
| Download: ML19210E016 (25) | |
See also: IR 05000282/1979021
Text
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
PIGION III
Report No. 50-282/79-21; 50-306/79-18
Docket No. 50-282; 50-306
Leiensee: Northern States Power Company
414 Nicollet Mall
Minneapolis, MN 55401
Facility Name:
Prairie Island, Units 1 and 2
Inspection At: Red Wing, MN-
Inspection Conducted: July 9-13, 17-18, August 1-3 and 9, 1979
Inspectors:
W. S. Little
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Approved By:
W. S. Litt'le, Chief
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Nuclear Support Section 2
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Inspection Summary
Inspection on July 9-13, 17-18, August 1-3 and 9, 1979 (Report No.
50-282/79-21;50-306/78-1R
Areas Inspected:
Announced special inspection of the licensee's implementa-
tion of the Quality Assurance Program in the following areas: QA/QC
sdministration; qualification of personnel; design changes and modifications;
records control; receipt storage and handling; tests and experiments;
procurement control; document control; offsite and onsite review committees;
audits; test and measurement equie; ment; surveillance and calibration;
maintenance; housekeeping and cleanliness; and offsite support staff.
The inspection involved 171 inspector hours on site by four NRC inspectors.
Results: Of the sixteen areas inspected, no apparent items of noncomp-
linace or deviations were identified in thirteen areas, two apparent items
of noncompliance were identified in two areas (infraction - failure to
follow design change proceduresji- Paragraph 7; infraction - failure to
adhere to record control requirdments Paragraph 15) one apparent deviation
was identified in one area.
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DETAILS
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1.
Persons Contacted
G. H. Neils, General Superintendent, Nuclear Power Plant Operation
F. P. Tierney, Plant Manager
L. O. Mayer, Manager, Nuclear Support Services
E. L. Watzl, Plant Superintendent, Plant Engineering and Radiation
Protection
A. A. Hunstad, Staff Engineer
R. E. Warren, Office Supervisor
R. L. Lindsey, Superintendent Operations
D. A. Schuelke, Superintendent Radiation Protection
J. L. Hoffman, Superintendent Technical Engineering
K. J. Albrecht, Quality Assurance Engineer
R. V. Pederson, Quality Assurance Engineer
P. F. Suleski, Supervisory Engineer QA Nuclear
D. J. Silvers, Quality Assurance Engineer
T. E. McFadden, General Superintendent, Operational Quality Assurance
P. H. Kamman, Superintendent, Nuclear Quality Assurance
The inspectors also interviewed several other licensee employees
including shift supervisors and plant engineering and administrative
personnel.
On August 9, 1979, a management meeting was held in the Northern
States Power Company (NSP) corporate offices in Minneapolis, Minnesota.
The purpose of the meeting was to discuss the findings identified
during the Quality Assurance inspection conducted on July 9-13,
17-18 and August 1-3, 1979. Attendees included the following
reprensentatives.
NRC Region III
R. F. Heishman, Chief, Reactor Operations and Nuclear Support Branch
W. S. Little, Chief, Nuclear Support Section 1
R. F. Warnick, Chief, Reactor Projects Section 2
I. N. Jackiw, Reactor Inspector
C. D. Feierabend, Reactor Inspector
F. T. Daniels, Reactor Inspector
L. J. Wachter, Vice President, Power Production and System Operation
D. E. Gilberts, General Manager, Power Production
G. H. Neils, General Superintendent, Nuclear Power Plant Operation
T. E. McFadden, General Superintendent, Operational Quality Assurance
L. O. Mayer, Manager, Nuclear Support Services
P. H. Kamman, Superintendent, Nuclear Quality Assurance
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F. P. Tierney, Plant Manager, Prairie Island
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G. T. Bart, Quality Assurance Engineer
E. L. Watzl, Plant Superintendent, Plant Engineering and Radiation
Protection, Prairie Island
K. J. Albrecht, Quality Assurance Engineer, Prairie Island
P. D. Charais, Quality Assurance Engineer, Prairie Island
R. L. Scheinost, Quality Assurance Engineer, Montir.ello
T. E. Harlan, Operations QA Specialist I
2.
QA/QC Administration
The QA/QC implementing procedures were reviewed to evaluate the
licensee's administrative program for assuring tuat the QA program
scope is defined, for controlling the preparation, review and approval
of QA/QC procedures; and for establishing responsibilities and
methods for reviewing and evaluating the QA/QC program. The Adminis-
trative Control Directives (ACD's) and Administrative Work Instructions
(AWI's) were reviewed against the commitments made in " Operational
Quality Assurance Plan", (0QAP) Rev. 3 which had been accepted by
NRC.
a.
Documentation Reviewed
1ACD1.1, Rev. 6, Administrative Control Directives
1ACD1.2, Rev. 5, Administrative Work Instructions
1ACD2.1, Rev. 1, Operational QA Program Boundary
1ACD2.4, Rev. 1, QA Program Administration
1ACD4.1, Rev. 5, Document Control
3ACD1.1, Rev. 7, Administrative Control Directions
3ACD1.2, Rev. 6, Administrative Work Instructicns
3ACDI.3, Rev. 6, Administrative Memorandums
3ACDI.4, Rev. 5, Plant Administrative Control
3ACD2.1, Rev. 2, Operational QA Program Boundary
3ACD2.4, Rev. 3, QA Program Administration
3ACD5.1, Rev. O, Document Control
SACD1.1, Rev. 3, Administrative Control Directives
SACD1.2, Rev. 2, Special Orders
SACD1.3, Rev. 3, Section Work Instructions
5ACD1.4, Rev. 4, Plant Operations Manual
SACD2.1, Rev. O, QA Program Boundary
5ACD2.2,
- v. 5, Internel Audits
5ACD2.4,
av. O, Q-List Committee
5ACD3.1.
.ev. 4, Prairie Island Plant Organization
SACD2.2
lev. 5, Internal Audits
The above documents and their implementation as they relate to
the administration of the QA program were reviewed.
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b.
Findings
(1) Noncompliance
No items of noncompliance were identified
(2) Deviations
No deviations were identisied.
(3) Unresolved Items
Plant Q-List-1ACD2.1 lists those structures, systems and
components subject to Appendix B to 10 CFR 50, however a
Q-list extension that has been through all of the required
reviews and approvals has not been issued as required by
SACD2.1. The inspector stated that the official Q-list
extension would be reviewed during a subsequent QA inspection.
c.
Discussion
The OQAP approved by NRR states that the Plant Quality Engineer
reports to the Plant Superintendent, Engineering and Radiation
Protection. The inspector expressed concern that this organiza-
tional structure did not provide sufficient " independence from
cost and scheduling considerations when opposed to safety
considerations" as stated in paragraph 3.2 of ANSI N18.7.
No
problems were apparent in this area and the licensee indicated
that they were considering revising the OQAP such that the
Plant Quality Engineer would report to the Plant Manager.
The inspector expressed concern that the QA/QC responsibilities
were divided between so many plant and corporate organizations,
making it difficult to assure that all the proper systems and
activities are subject to the QA programs. Extra effort must
be put both on communi:ations and the interfaces between these
organizations to make certain all areas important to safety are
addressed. The inspector stressed the importance of the licensee
management communicating their interest and support of QA/QC to
the plant Quality Engineer.
It was brought to the inspectors attention that the licensee
was considering using peer QC inspectors in the plant. The
pros and cons of using peer inspectors were discussed. The
inspector stated that to make the " peer" approach work, serious
consideration must be given to making sure their QC training
was adequate; and to assigning the " peer" inspectors to the QC
engineer to supervise their activities for specific periods of
time. At the exit interview on August 9, 1979, the licensee
indicated that they were no longer considering the use of peer
inspectors.
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3.
Audit Program
The licensee's audit program was inspected to evaluate the licensee's
audit program and its compliance with the OQAP and Section 6 of the
Technical Specifications.
a.
Documentation Reviewed
1 ACD 2.2, Rev. 2, Audits
3 ACD 2.2, Rev. 3, Audits
5 ACD 2.2, Rev. 5, Internal Audits
2 ACD 7.1, Rev. 2, Safety Audit Committee
3 AWI 2.2, Rev.2, Audit Schedule and Log
3 AWI 2.26, Rev. 1, Lead Auditor Qualifications
Records to confirm implementation of the above ACD's and AWI's
were inspected at Prairie Island and in the corporate office in
Minneapolis.
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No deviations were identified.
(3) Unresolved Items
Section 20.2 of the 0QAP commits to establishing measures
to assure periodic audits of each Directive issued within
the Operational Quality Assurance Program, and Section
20.3 of the OQAP states that required audits shall be
performed each year except that the time period may be
extended to not more than two years provided such exten-
sions are justified based on past experience.
(These
commitments are implemented in Directives 3 ACD 2.2 and 5
ACD 2.2) At the time of the inspection audits of the
following directives had not been conducted yearly, and
the audit period extension was not justified based on past
experience; 3 ACD 2.2, 5 ACD 2.2, 5 ACD 2.3, 5 ACD 2.5, 5
ACD 7.1, and 5 ACD 8.4.
c.
Discussion
The division of responsibilities for the audit program appears
to be a potential source of problems. The audit of the
Surveillance Program Directive, 3 ACD 9.1, appears to not have
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been done because of a misunderstanding between the corporate
and plant QA staffs, however, the inspector did note that the
SAC had audited the plant surveillance progarm in the Spring of
1978 and 1979.
The inspector emphasized the importance of
communi.ation and interface control between the different
internal organizations performing audits to make certain that
all required audits are performed.
Currently the OQAP only required auditing of Directives within
the Operational Quality Assurance Program and does not require
the auditing of safety related activities as they are being
carried out. The inspector emphasized that to properly audit a
program (maintenance, surveillance, etc.), the audit should
include some actual observations of safety related activities
while they are in progress. The licensee stated that they were
considering revising the OQAP to include audit of activities.
The inspector expressed concern that extensive periods of time
were being taken to resolve audit findings.
As an example,
Audit AIII resulted in findings QAF-14 through 17.
Resolution
of these findings took as long as a year to accomplish relatively
simple corrective actions.
4.
Offsite Rceiew Committee
The inspector reviewed records and conducted interviews to evaluate
the performance of the Safety Audit Committee. The Administrative
Work Inst rucctions and records were compared with the requirements
of Section 6 of the Technical Specifications.
a.
Documents Reviewed
2 AWI 7.1.3, Rev. 2, Safety Audit Committee Charter
SAC Meeting Minutes dated 5/18/77, 8/24/77, 12/7/77, 3/8/78,
6/21/78, 9/20/78, 2/6/79
SAC Audit Schedule and Records for 1978 and 1979
b.
Findings
(1) Noncompliance
No items of noncompliances were identified.
(2) Deviations
No deviations were identified.
(3) Unresolved items
No unresolved items were identified.
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5.
Personnel Qualification Program
The inspector reviewed the QA prcgram relating to qualification of
personnel for key positions at the plant.
It was found that the
corporate and plant Directives adequately identify the minimum
educational experience and qualification requirements for:
principal
operating staff, first level supervision, oncite technical engineering
staff, plant craftsmen, plant operators, NDT personnel, chemistry
technicians, QA staff and SAC members.
a.
Documents Reviewed
5 ACD 3.1, Rev. 4, Prairie Island Plant Organization
5 ACD 3.11, Rev. 2, Plant Training Program
3 ACD 3.3, Rev. 1, Nuclear Plant Maintenance
3 ACD 7.2, Rev. 1, Power Div. Welder Qualification
3 ACD 7.6, Rev. O, NDE Personnel Qualification
3 ACD 7.5, Rev. 1, Welding Inspection
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No deviations were identified.
(3) Unresolved Items
No unresolved items were identified.
c.
Discussion
Even though the guides and standards do not require it, the
inspector stated that the minimum qualificatione for the Training
Supervisor should be specified in a plant directive.
6.
Offsite Support Staff
The inspector reviewed licensee Directives and interviewed corporate
personnel to determine whether safety related offsite support staff
functions are performed by qualified personnel in conformance with
licensee approved administrative procedures. The inspector emphasized
the importance of subjecting all such safety related support functions
to QA procedur-s.
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a.
Documents Reviewed
1 ACD 3.3, Rev. 3, Design Change Control
1 ACD 5.1, Procurement Control
1 ACD 5.4, Rev. 1, Material Receipt Control
2 ACD 3.3, Program Control
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No deviations were identified
(3) Unresolved Items
No unresolved items were identified.
7.
Design Changes and Modification Program
The inspector reviewed the Design Changes and Modification Program
to ascertain whether the licensee is implementing a Quality Assurance
Program that is in conformance with the Prairie Island Operational
Quality Assurance Plan, ANSI N18.7-1976 and 10 CFR 50 Appendix B.
The following items were considered during this review: determination
that procedures have been established for control of design and
modification change request; determination that procedures and
responsibilities for design control have been established; verification
that administrative controls for design document control have been
established; verification that responsibilities have been assigned
in writing to assure implementation of design change document control:
verification that administration control and responsibilities have
been established to assure that design changes and modification ~
will be incorporated into plant procedures, operator training programs
and updating plant drawings; verification that controls have been
developed that define channels of communication between design
organizations and the responsible individuals; verification that
administrative controls require that design documentation and records
which provide evidence that the design and review process was performed
be collected and transmitted to records storage; verification that
controls require that implementation of approved design changes be
in accordance with approved procedures; verification that controls
require that post modification acceptance testing be performed per
approved test procedures and the results evaluated; verification
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that responsibility has been assigned for identifying post modifica-
tion testing requirements and acceptance criteria; and responsibility
and method for reporting design changes / modifications to the NRC in
accordance with 10 CFR 50.59.
The inspector also reviewed the licensee's temporary modifications,
such as electrical jnmpers and lifted electrical leads, to ascert.ain
that a program exists and requires proper reviews and approvals of
temporary modifications and that these activities are accomplished
using detailed approved procedures.
a.
Documentation Reviewed
The following documents were reviewed:
5 ACD 6.1 " Design Change Control"
5ACD 6.2 " Design Change Installation Procedures"
5 ACD 6.3 " Design Change Implementation"
5 ACD 6.4 " Design Change Preoperational/ Operational Testing"
3 AWI 4.1.1 " Safety Evaluation"
3 AWI 4.1.2 " Responsibilities of Project Coordinators"
3 AWI 4.1.3 " Fire Protection Prevention Review of Design Changes"
3 AWI 4.1.4 " Design Change Records"
3 AWI 5.3.1 " Drawing Control Responsibilities"
3 ACD 5.3 " Drawing Revision"
SWI-PERP-2 "Section Work Request Authorizing Instruction"
SWI-PERP-4 " Safety Evaluation"
SWI-PERP-5 " Responsibilities of Project Coordinator"
b.
Findings
(1) Noncompliance
10 CFR 50 Appendix B, Criterion V requires that activities
affecting quality shall be prescribed by documented instruc-
tions, procedures, or drawings, of a type appropriate to
the circumstances and shall be accomplished in accordance
with these instructions, procedures, or drawings.
Contrary to the above, the following examples of failures
to follow procedures were identified by the inspector and
constitute an item of noncompliance.
(a) 3ACD4.1 " Design Change Control" Revision 4, Sections
6.4.2 and 6.4.3 require that after the Preliminary
Design Change Package is completed an overall review
of that Package shall be performed. This review
shall ensure that all pieces of the Package are
properly prepared and that this shall be indicated by
a signature of the overall reviewer.
In addition,
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the Responsible Engineer's signature shall indicate
that all required forms in the Preliminary Design
Change Package are properly completed.
The inspector found that section's III B 1 and 2 of
Design Change Control Form (DCCF) 3-3016, for Design
Change 77L397 " Removal of Auto Start of Auxiliary
Feedwater Pump", were not completed but the form was
signed approving the Design Change.
(b) 3ACD4.1 section 6.3.8 requires that the Responsible
Engineer assure that all operating, maintenance,
surveillance or other procedures which may require
revisions or which should be generated as a :esult of
the Design Change are identified on fers 3-3017-7 and
indication be made when the procedures are revised or
generated by a date and initials. Also, form 3-3017-7
" Procedures" requires that a signature block be pro-
vided to indicate that each procedure has been prepared.
While reviewing documentation for Design Change
77L397, the inspector found that form 3-3017-7, had
been completed but no initials appeared on the form.
Further review by the inspector revealed that procedure
checklist C28-2 had been revised but not initialed as
required.
(c) 3AWI 5.3.4 requires that a Drawing Revision Request
be issued to change the drawings effected by a Design
Change.
The inspector found that for Design Change 77L397, a
design change notice had been issued to indicate that
eleven drawings are expected to be effected by the
proposed Design Change. Work on the Design Change
had been completed in September 1978. A review of
records indicates that a drawing revision request had
not been issued as required, and the eleven effected
drawings have not been revised.
The inspector also found that as a result of the
Design Change a "new drawing request" had been
initiated and on January 9, 1979, a check drawing had
been received at the plant.
Six months later the
check drawing has still not been reviewed nor issued.
(2) Deviations
No deviations were identified.
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(3) Unresolved Items
The following unresolved item was identified in the area
of design caanges and modifications:
ANSI 18.7 and 3ACD 3.6 Revision 0 dated June 7, 1979
require that temporary modifications, such as electrical
jumpers and lifted electrical leads shall be controlled by
approved procedures which shall include a requirement for
independent verification has not been implemented by the
plant.
However, the inspector noted that 3ACD3.6 is being reviewed
by plant personnel and a 5ACD will be issued soon.
c.
Discussion
(1) No formal system has been established to provide and
document that Design Changes have been communicated to
plant operators.
Procedure 3AWI4.1.2 requires that the Design Project
Coordinator along with the Training Supervisor arrange and
organize the appropriate training. licweve r , if the Design
Change does not involve the Construction Department and a
Design Project Coordinator is not assigned, no formal
provisions exist to require that the Responsible Engineer
initiate the appropriate training.
(2) 3ACD4.1 Revision 5, Section 5.6(5) requires that the Plant
Superintendent Engineering and Radiation Protection approve
Design Changes prior to installation, with the exception
that installation may proceed providing that Design Change
approval is obtained prior to declaring the related system
The inspector noted that this is inconsistent with require-
ments provided in Sections 6.2 and 6.4.8 of the same
procedure. These sections require that Design Changes be
approved prior to installation.
(3) 3ACD4.1 Revision 5, Section 5.6(10) dated December 8,
1978, requires a time.'.y (3 month) close out of design
changes after installation.
The inspector's review of a number of design changes,
where installation was completed after the effective date
of the 3ACD, indicates that these design changes have been
closed out in the required 3 month period. However, the
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inspector noted that there are still a number of old
(prior to December 8, 1978) design changes that have not
been closed out.
8.
Maintenance Program
The inspector reviewed the licensee's Maintenance Program to ascertain
whether the QA Program relating to maintenance activities is being
conducted in accordance with the Operational Quality Assurance Plan,
10 CFR 50 Appendix B requirements and commitments in the QA Plan.
The following items were considered during this review; written
procedures have been established for initiating requests for routine
and emergency maintenance; criteria and responsibilities have been
designated for performing work inspection of maintenance activities;
provisions and responsibilities have been established for the identi-
fication of appropriate inspection hold points; methods and responsi-
bilities have been designated for performing testing following
maintenance work; methods and responsibilities for equipment control
have been clearly defined; and administrative controls for special
processes have been established.
.
The inspector also reviewed the licensee's Preventive Maintenance
Program and verified that a written program has been established
which includes responsibility for the program, a master schedule for
preventive maintenance and documentation and review of completion of
preventive maintenance activities.
a.
Documentation Reviewed
The following documents were reviewed:
3 ACD 3.3, " Nuclear Plant Maintenance"
3 ACD ?.6, " Equipment Control"
5 ACD 3.10, " Equipment Control"
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SWI-0-5, " Operation Section Work Request and Work Request
Authorization"
SWI-M-1, " Maintenance Section Work Request and Work Request
Authorization"
SWI-M-7, " Control of the Electrical PM File"
SWI-E0-1, " Operations Section Work Request Authorization"
SWI-IC-1, "I&C Section WR/WRA"
3 ACD 7.1, " Welding Procedure Control"
3 ACD 7.3, " Welding Material Control"
3 ACD 7.4, " Nondestructive Examination Procedure"
5 ACD 9.4, " Welding Control"
5 ACD 8.3, " Welding Material Control"
3 ACD 7.5, " Welding Inspection"
3 ACD 3.5, " Training"
5 ACD 3.11, " Plant Training Program"
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b.
Findings
(1) None apliance
No apparent items of noncompliance were identified.
(2) Deviations
No deviations were identified.
(3) Unresolved Items
One unresolved item was identified:
The Northern States Power Company Operational Quality
Assurance Plan revision 3 dated June 20, 1978 states in
section 4.9 that training programs shall be established
for those personnel performing quality-affecting activities
such that they are knowledgeable in the quality assurance
directives and their requirements and proficient in imple-
menting these requirements.
Section 4.9 further states
that the scope, the objective, and the method of implementing
the training programs are documented.
Contrary to the commitment made in the Operational Quality
Assurance Plan the following discrepancies were identified
in the licensee's Quality Assurance Training Program:
(a) 5 ACD 3.11 does not clearly define the scope of the
QA training.
(b) No system exists for checking that individuals involved
in quality effecting activities have been trained on
all required QA material.
(c) No system exists to identify and train individuals
that had missed scheduled QA training sessions.
(d) A program for QA retraining of personnel has not been
established.
c.
Discussion
The following items were brought t
the attention of the licensee.
(1) No formal system to review corporate 3 ACD's and incorporate
th m into plant procedures in a timely manner.
For example, special processes procedure 3 ACD 7.1, 3 ACD
7.3, 3 ACD 7.4 and 3 ACD 7.5 all have effective dates of
MayorJuneofly79. The plant 5 ACD's that implement
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these procedures have effective dates prior to May and
.
June 1979 and in one case the effective date of plant 5
ACD is February 1976.
The inspector noted that no documented evidence was available
to indicate that the corporate 3 ACD requirements had been
incorporated into the plant 5 ACD's.
(2)
In some cases Work Request Authorization forms are not
being completely filled out.
The inspector found that
some of the WRA's reviewed did not have the workman and
the workman's supervisor blocks filled in.
(3) Work requests ;re not always detailed enough to determine
cause of the malfunction or failure, or description of the
corrective action taken.
9.
Housekeeping / Cleanliness Program
The inspector reviewed the licensee's Housekeeping and Cleanliness
Program to verify that the licensee is implementing adequate housekeeping
and cleanliness controls to assure that the quality of safety related
systems is not degraded. Also, that the program meets the requirements
of the Operational QA Plan and ANSI N 45.2.3.
Items considered during the review were:
Control of housekeeping
during work activities; establishment of housekeeping zones; control
of combustible material and debris; establishment of cleanliness
classifications for plant systems; and establishment of requirements
for material accountability in critical clean areas. The inspector
observed that physical housekeeping and cleanliness of the plant
appears to be adequate and is meeting the requirements of the existing
plant procedures.
a.
Documents Reviewed
SWI-I&M-3, " Plant Helper Cleaning Assigments"
SWI-0&M-6, " Auxiliary Building Vacuum Cleaner Operation"
SWI-0&M-8, " Laundry Operations"
SWI-0&M-9, " Control of Combustible Material at Job Sites"
SWI-0-8, " Plant Cleaning Responsibilities"
b.
Finding
(1) Noncompliance
No apparent items of noncompliance were identified.
(2) Deviations
No deviations were identified.
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(3) Unresolved Items
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The licensee has not addressed all the requirements provided
in ANSI N 45.2.3.
Fox example, zone designations and cleanliness requirements
for these zones have not been established as required in
ANSI N 45.2.3.
Current procedures are not specific in the
designation of zones. Also no formal procedures have been
established to inspect and evaluate housekeeping in the
plant as required by ANSI N 45.2.3.
10.
Test and Experiments Program
An inspection vas conducted to determine if the licensee had implemented
a QA Program relating to the control of test and experiments in
conformance with regulatory requirements, commitments and guides. A
formal method has been established to handle all requests or proposals
for conducting plant tests and experiments involving safety related
components, systems, structures or modes of operation different from
those described in the FSAR. A formal system, including assignment
of responsibility, has been established for reviewing and approving
test procedures and performing an evaluation pursuant to 10 CFR 50.59.
A review was conducted of the spent fuel pit expansion
pre-operational testing, safety injection system safeguards 'est and
a special natural circulation test.
a.
Documentation Reviewed
5 ACD 3.3, Operations Committee
3 ACD 3.9, Review & Approval of Plant, Schedules and Procedures
3 ACD 9.2, Surveillance Test Procedures
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No items of deviation were identified.
(3) Unresolved Items
No unresolved items were identified.
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11.
Test and Measurement Equipment Program
The inspector verified by the review of established controls for
test and measurement equipment that criteria and responsibility for
an equipment inventory list has been prepared which identifies the
equipment, calibration frequency, procedures and applicable national
standards. Formal requirements exist for identifying the status of
calibration and assuring that equipment is calibrated on or before
the date required. Requirements have been established which prohibit
the use of test and measuring equipment which has not been inspected
and calibrated within the prescribed frequency with controls to
prevent inadvertent use of such equipment. A system has been estab-
lished for control and evaluation of new or out-of-calibration
equipment.
a.
Documentation Reviewed
5 ACD 1.5, Procedure Control
5 ACD 3.4, Records Management
5 ACD 3.14, Measuring and Test Equipment
5 ACD 7.1, Procurement
SWI-M-6, Torque Wrenches
SWI-I&C PM-6, Condensate Storage Tank Level Calibration
SWI-I&C PM-8, Boric Acid Storage Tank Temperature Controller
Calibration
SWI-I&C TI-1, Test Instrument Calibration
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No items of deviation were identified.
(3) Unresolved Items
No unresolved items were identified.
12.
Surveillance Testing and Calibration Control Program
The inspector examined surveillance testing, calibration and inspection
required by Section 4 of the Technical Specifications, inservice
inspection of pumps and valves as described in 10 CFR 50.55a. (g),
and calibration of safety related instrumentation not specifically
controlled by Technical Specifications. A review was conducted of
master surveillance and calibration schedules for test frequency,
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group responsibility and status. Responsibility has been assigned
for approval, performance, acceptance criteria verification, and
maintaining an up-to-date schedule,
a.
Documentation Reviewed
5 ACD 1.5, Procedure Control
5 ACD 3.4, Records Management
5 ACD 3.3, Operations Committee
3 ACD 3.9, Review & Approval of Plans, Schedules and Procedures
3 ACD 9.1, Surveillance Test Programs
3 ACD 9.2, Surveillance Test Procedures
SWI-I&C-3, Initial Refueling Instrument Calibration Schedule
SWI-I&C.PM-5, Feedwater Header Flow DPI Calibration
SWI-I&C.SUR-1, I&C Surveillance Program General Description &
Guidelines
OPNS Section G, Surveillance
RPM Section H series, Plant Testing & Surveillance Files
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
No items of deviation were identified
(3) Unresolved Items
3 ACD 3.9 requires in part that surveillance test schedules
and inservice inspection examination schedules be approved
by the plant manager and reviewed by the plant operations
committee for general adequacy. Although this directive
was effective July 2, 1979, it was received at the station
on July 13, la79 and has not been incorporated in the
station 5 ACD series.
It appears that there is a lack of
responsibility assignment at the station level to handle
new ACD's or changes to the 3 ACD's that affect 5 ACD's.
13.
Receipt, Storage and Handling of Equipment and Materials Program
The inspector reviewed the program to verify the administrative
controls and implementation of the program were within the require-
ments as set forth in the Prairie Island Operational Quality Assurance
Plan, ANSI N 18.7-1976 and ANSI 45.2.2-1972.
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a.
Documentation Reviewed
(1) The following documents were reviewed to verify the establish-
ment of administrative controls for receipt of safety-related
items, disposition of items received onsite, storage of
items and handling of items.
1 ACD 5.3, Supplier Inspection
3 ACD 6.1, Uniform Nuclear Plant Procurement Process
5 ACD 8.1, Receiving Process
5 ACD 8.2, Inventory Control
5 ACD 8.3, Weld Material Control
5 ACD 8.4, Control of Non-Conforming Items
SWI-I&C-SP-1, Spare Parts Inventory Control
SWI-OS-Z, Inventory Control
(2) The following documentation was reviewed and actual physical
inspections were performed to verify the administrative
controls were properly implemented.
Puicnase Orders
M-87089
M-02041
M-94194
M-51305
M-59927
M-99574
M-97383
M-99623
b.
Findings
(1) Noncompliance
No items of noncompliance were identified in this area.
(2) Deviations
No deviations were identified.
(3) Unresolved Items
The following items do not conform with the Prairie
Island Operational Quality Assurance Plan and ANSI N
45.2.2.
(a) The requirement for administrative controls to conduct
periodic inspections of the storage areas as per ANSI
N 45.2.2-1972, paragraph 6.4.1 and the actual conducting
of such inspections are not implemented or performed.
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(b) The requirement for administrative controls for
handling of safety related material and for hoisting
equipment used in the handling of safety related
equipment as per ANSI N 45.2.2-1972, paragraph 7 are
not implemented or performed.
(c) The requirement for administrative controls for
maintenance and care of items in storage including
shelf life as per ANSI N 45.2.2-1972, paragraph 6.4.2
are not implemented or performed.
(d) 5 ACD 8.2 states that to return an unused item to
storage it shall be inspected by the Quality Engineer;
contrary to this the I&C Section Work Instruction
allows returning QA-1 items to storage without the
required QA inspection.
(e) Levels of Storage - No apparent attempt has been to
establish the 4 levels of storage as per 3 ACD 6.1
Rev. I and ANSI N45.2.2-1972.
c.
Discussion
Access control to storage areas and security of storage.
- On July 10, 1979 observed many personnel enter the
warehouse storage area without any appearent access
control.
- Eating and drinking in I&C storage area.
- 12 I&C specialists, 2 I&C coordinators and the I&C
engineer are allowed access to the I&C storage
area.
- The I&C storage area is actually part of the I&C
shop.
- Several boxes of I&C parts were sitting on floor in
I&C shop work area.
Use of correct procedure for rcceiving controls.
Plant was
using the receiving process as specified in 3 ACD 6.1, step 6.7
while the receiving process as deliniated in 5 ACD 8.1, step
6.1 has not been revised to reflect new process.
14.
Procurement Program
The inspector reviewed the program to verify the administrative
controls and implementation of the program were within the requirements
as set forth in the Priarie Island Operational Quality Assurance
Plan, ANSI N 18.7-1976 and ANSI N 45.2.13.
d
,i
"
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.
a.
Documentation Reviewed
(1) Reviewed 3 ACD 6.1, Rev. 2, May 2, 1979, to verify the
establishment of administrative controls for procurement
documents on safety related items and to provide measures
and assign responsibilities to provide an acceptable
method for qualifying a vendor, supplier, or cont.ractor.
(2) The following documentation was reviewed to verify the
administrative controls were properly implemented.
Purchase Orders
M-03734
M-05218
M-04426
M-05509
M-04896
b.
Findings
(1) Noncompliance
No items of noncompliance were identified
(2) Deviations
No deviations were identified
(3) Unresolved Items
No unresolved items were identified.
15.
Records
The inspector reviewed the program to verify the administrative
controls and implementation of the program were within the requirements
as setforth in ANSI N45.2.9-1974, Corporate Directive 1ACD 4.3,
Rev.0, PINGP Directive 5 ACD 3.4, Rev. 1, 10-19-77 and Criterion
XVII of Appendix B to 10 CFR 50.
a.
Documentation Reviewed
(1) The following documents were reviewed to verify the establish-
ment of proper administrative controls and implementing
instructions to maintain the records required by Technical
Specifications, to accomplish proper storage control of
records, to insure retention periods for records have been
established and to insure responsibilities for above
requiremeats have been assigned.
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1 ACD 4.3
SWI-OS-9
3 ACD 3.8
5 ACD 3.4
Operational Quality Assurance Plan
(2) The following records were checked to ensure they were
retrievable;
firmly attached in binder or placed in
folders or envelopes, or other su. table containers; stored
in a suitable file cabinet or selving in a container in a
predetermined location and stored in a proper storage
facility.
Unit I and 2 Reactor Operators Log
Operations Log
Audit Reports
Discrepancy Reports
I&C Calibration Records
I&C Surveillance Records
Procurement Records
Receipt Inspection Records
Reportable Occurrence Records
Review Committee Records
Radiation Exposure Records
Radioactive Release Records
b.
Findings
(1) Noncompliance
Criterion XVII of Appendix B to 10 CFR 50 requires that
" sufficient records shall hc maintained to furnish evidence
of activities af fect 'ng quality. The records shall include
at least the following:
Operating logs and the results of
reviews, inspections, tests, audits, monitoring of work
performance and materials analyses. The records shall
also include closely-related data such as qualifications
of personnel, procedures, and equipment.
Inspection and
test records shall, as a minimum identify the inspector or
data recorder, the type of observation, the results, the
acceptability, and the action taken in connection with any
deficiencies noted. Records shall be identifiable and
retrievable.
Consistent with applicable regulatory require-
ments, the applicant shall establish requirements concerning
record retention, such as duration, location, and assigned
responsibility."
Administrative Control Directive 3 ACD 3.8, Rev. O, November 28,
1977 requires thac " Required records shall be indexed.
This index shall indicate, as a minimum, record retention
times, where the records are to be stored, and the location
}khk
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of the records within a specific file. A Records System
.
Index which identifies r.11 required record files and their
location shall also be provided."
Administrative Control Directove 5 ACD 3.4, Rev. 1, October 19,
1977 requires that "A general index shall be established
listing the required records and QA record index 1rcation".
Contrary to the above: no general index had been established
or maintained listing retention times which are required
by Technical Specificatio.is and other controlling documents.
(2) Deviations
,
.
No deviations were identified.
(3) Unresolved Items
Storage of Records - Although, some records are microfilmed
at this time, there are many more which are not maintained
in proper storage facilities. Records which are required
by the Technical Specifications are located in many places
and in some cases the manner in which they are stored is
quite lax. For example, there is a definite lack of
controlling access to required records and maintaining
fire prevention or environmental control except normal
administrative building methods.
A major problem with record storage is the lack of storage
facility. The licensee stated in a letter, dated March 8,
1978 to the Director, NRR that this was a possibly needed
facility. The inspector stated that a storage facility to
bring PINGP up to the minimum requirements of 3 ACD 3.8,
Rev. O, is needed. The cchedule for completion and imple-
mentation of a storage facility will be inspected during a
subsequent inspection.
16.
Document Control Program
The inspector reviewed the program to verify the administrative
controls and implementation of the program were within the requirements
as setforth in the Prairie Island Operational Quality Assurance
Plan.
a.
Documentation Reviewed
(1) The following documents were reviewed to verify the estab-
lishment of administrative controls for drawings, manuals,
and Technical Specifications control:
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329
22 _
,
3 ACD 5.1
5 ACD 4.2'
.
5 ACD 1.1
5 ACD 4.3
5 ACD 1.2
5 ACD 4.4
5 ACD 1.4
SWI-OS-5
5 ACD 4.1
SWI-OS-6
(2) The inspector reviewed ten working drawings at 3 different
locations to insure they were being maintained in accordance
with SWI-OS-5.
(3) The inspector verified the Operations Manual was located
in specified areas, procedure 5 ACD 4.1, Rev. 2 was in
each manual and pages were properly stamped.
(4) The inspector reviewed the controlled drawing file at the
four required locations to determine if they were being
maintained in accordance with 5 ACD 4.4, Rev. 4.
b.
Findings
(1) Noncompliance
No items of noncompliance were identified in this area.
(2) Deviations
No deviations were identified.
(3) Unresolved Items
(a) The methods of maintaining controlled drawings in the
I&C work area, electrical work area and the electrical
engineer work area did not conform with the Operational
Quality Assurance Plan and 5 ACD 4.4, Rev. 4 in that
the authorized users of the file were not designated
and the responsible person for the files in the case
of the I&C and electrical engineer files was not
aware of the requirements as set forth in the afore-
mentioned procedure.
(b) The procedure for drawing control, 5 ACD 4.4, Rev. 4,
was not revised nor had steps been taken to revise
the procedure when the control room controlled drawing
file was cancelled on June 21, 1979. This item was
brought to the attention of the responsbile supervisor
and a change was initiated.
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17.
Onsite Review Committees
.
The inspector reviewed onsite Review Committee minutes to ascertain
whether the onsite review funcitons were conducted in accordance
with Prairie Island Technical Specification.
a.
Documentation Reviewed
The inspector reviewed the following items reviewed by the
Operations Committee to verify that those who participate in
the review included persons who constituted a quorum and
possessed expertise in the areas reviewed.
Reportable Occurrence 78-14 and 79-12
Safety Evaluation #33
Quality Program Report #5
b.
Findings
(1) Noncompliance
No items of noncompliance were identified.
(2) Deviations
IE Bulletin 78-05 response states that the required
inspections would be completed by June 1, 1979, and on
February 22, 1979 the item was discussed during Onsite
Review Committee meeting #399 reflecting that the commit-
ments would not be completed and a update to bulletin
response would be required.
Contrary to the above as of July 13, 1979, the inspections
had not been completed and no update has been received by
the NRC.
(3) Unresolved Items
(a) TS 6.2.B requires a Quorum of Operations Committee
(OC) to consist of a majority of the permanent members
including the Chairman or Vice Chairman.
The inspector noted that 5 ACD 3.3, Rev. 5 allows the
Duty Engineer to act as Chairman in the absence of
both the Chairman and Vice Chairman.
A review of the last years OC minutes shows that this
has not occurred,,but if it did occur Prairie Island
would be in violation of their own Technical
Specifications.
- 24 -
i434 3
. (b) Quality Finding Report #5 was initiated June, 1977 and was not reviewed by the OC committee until February, 1979. The conclusion of the committee that changes may be required to the Work Request Authorization form did not appear to be followed up. 18. Unresolved Items Unrec'nved items are matters about which more information is required in order to ascertain whether they are acceptnble items, items of noncompliance, or deviations. Unresolved items disclosed during the inspection are discussed throughout the report. 19. Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on August 9, 1979. The senior inspector stated that the findings for each area inspected are presented in three parts; items of noncompliance; deviations; and unresolved items. In a letter to NRR dated March 8, 1978, the licensee stated that implementation of certain portions of the Operational Quality Assurance Plan (0QAP) cannot be accomplished until the end of 1979. Unresolved items are items which would be considered to be noncompliance if the problems continue to exist after the end of 1979, and the licensee is requested to consider these items at this time in order to bring their Quality Assurance program into full compliance with the OQAP by the end of 1979. The licensee is also requested to consider the discussion items in the report to decide whether application of these items would result in overall QA program improvement. Actions taken regarding these unresolved items will be reviewed in subsequent followup inspections. Licensee representatives had no significant questions or comments regarding the findings which were discussed. )hbh . ! - 25 - }}