ML19270G309

Responds to NRC 790215 Ltr Re Violations Noted in IE Insp Rept 50-282/79-01 & 50-306/79-01.Corrective Actions:Design Change Has Been Implemented to Assure Problems Are Quickly Identified & Corrected

ML19270G309
Person / Time
Site:	Prairie Island
Issue date:	03/08/1979
From:	Wachter L NORTHERN STATES POWER CO.
To:	Fiorelli G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7906060093
Download: ML19270G309 (5)

Text

fLS NSP NORTHERN STATES POWER COMPANY M I N N E A PO LI S. M I N N E S OTA 55401 March 8, 1979 Mr. Gaston Fiorelli, Chief Reactor Operations and Nuclear Support Branch Region III United States Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 p

Dear Mr. Fiorelli:

b PRAIRIE ISLAND NUCLEAR GENERATING PLANT Dockets No. 50-282 and No. 50-306 In response to your letter of February 15, 1979, which transmitted Inspection Reports 50-282/79-01 and 50-306/79-01, the following information is offered:

Infraction Criterion XVI of Appendix B to 10 CFR 50 requires that " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment and nonconformances are promptly identified and corrected."

Contrary to the above, measures were not sufficient to assure prompt corrective action identified as required by your Occurrence Report No.

P-RO-77-33, dated September 2, 1977.

Response

The present system for assuring completion of corrective action utilizes the Operations Committee review process. This review process has been effective. This noncompliance was the result of a misunderstanding of responsibility complicated by the transfer of an employee from the plant staff. It is fcit the present review system is adequate and should not be modified. A design change has been initiated to implement the recommended corrective action.

Infraction Criterion X of Appendix B to 10 CFR 50 states, in part: "A program for inspection of activities affecting quality shall be established and executed. . . ."

R 121979 7906060033 2273 J57

NORTHERN STATES POWER COMPANY Mr. Gaston Fiorelli March 8, 1979 Page 2 NSP's letter of March 8, 1978, to the Director of NRR regarding

" Operational Quality Assurance Plan Implementation" indicates ACD's would be reviewed and revised in 1978 and the implementation of the revised Dircctives would be verified in the 1979 Audit Program.

Contrary to the above, while some inspection requirements, i.e. -

inservice inspection, weld inspection, and vendor inspection, have been previously identified and implemented, all of the requirements and commitments of Section 12.0, Inspection, of NSP's Operational Quality Assurance Plan have not been incorporated into specific General Office Directives, Prairie Island Directives, and Administrative Work Instructions.

Response

The General Office Administrative Control Directives utilized to implement inspection activities are identified in Section 12.7 of NSP's Operational Quality Assurance Plan Rev 3. The status of each of these Administrative Control Directives and planned corrective action where deficiencies exist is as follows:

1. lACD3.2 Plant Operation (Rev 3)

The current revision of this Directive contains appropriate inspection provisions.

2. 1ACD3.3 Desic.n Change Control (Rev 3)

The current revision of this Directive contains provisions which assure that inspection requirements contained in Appendix B to 10CFR50 are imposed on plant design changes. Whereas this Directive is considered adequate, some clarification in the area of inspection may be desirable. The QA Section has scheduled a review of our Design Change process; recommended corrective action if appropriate will be submitted to NSP management by July 1, 1979.

3. lACD5.1 Procurement Control (Rev 2)

The current revision of this Directive contains appropriate inspection provisions.

4. lACD5.2 Technical & Quality Requirements (Rev 1)

The provisions of this Directive have been incorporated in lACD3.1 Rev 2; and, therefore, it will be deleted at the appropriate time.

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NORTHERN STATES POWER COMPANY Mr. Caston Fiorelli March 8, 1979 Page 3

5. lACD5.3 Supplier Inspection (Rev 1) (Vendor Inspection)

The current revision of this Directive contains appropriate inspection provisions.

6. lACD5.5 Radioactive Material Control The measures required by 10CFR71 that were to be established in this Directive have been incorporated into 1ACD3.2 Rev 3 and 1ACD5.1 Rev 2; therefore, this Directive will be deleted from the Operational Quality Assurance Plan in the next revision.

7. 2ACD3.2 Plant Operation Revision 4 of this Directive contains appropriate inspection provisions.

Revision 4 is presently in typing and will be issued by March 31, 1979.

8. 2ACD5.1 Nuclear Fuel Supplier's Quality Assurance Programs (Rev 3)

The current revision of this Directive contains appropriate inspection provisions. Inspection provisions relative to nuclear fuel have also been established in 2ACD5.2 Nuclear Fuel Supplier Inspection Rev 0.

9. 3ACD3.2 Plant Operation Revision 3 of this Directive contains appropriate inspection provisions.

Revision 3 is presently in typing and will be issued by March 31, 1979.

10. 3ACD3.3 Plant Maintenance (Rev 0)

The current revision of this Directive is deficient in the area of inspection, particularly inservice inspection. The following action is scheduled to correct this deficiency.

(a) The inservice inspection provision of 3ACD3.3 will be deleted and the inspection requirements associated with maintenance work will be clarified.

(b) A new Directive will be prepared and issued which establishes measures relative to the physical aspects of inservice inspection.

(c) The functional testing aspects of inservice inspection (including functional testing of valves and pumps as well as hydrostatic testing) will be incorporated into 3ACD9.1 Surveillance Test Program.

The above actions are scheduled for completion by April 30, 1979.

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NORTHERN STATES POWER COMPANY Mr. Gaston Fiorelli March 8, 1979 Page 4

11. 3ACD4.1 Design Change Control (Rev 5)

The current revision of this Directive in conjunction with 3ACD3.7 Work Control Process (Rev 1) contains appropriate inspection provisions.

12. 3ACD12.1 Radioactive Material Control This Directive, which establishes the inspection measures required by 10CFR71 relative to shipment of radioactive material, has been drafted and will be issued for implementation by April 30, 1979.

Inspection requirements have been or will be incorporated into the above Administrative Control Directives, and others if necessary, based upon the following Operational Inspection Concept:

Operational Inspection Concept It is NSP's position that it is mandatory that inspections be performed ler qualified personnel other than those who performed the activity being inspected in accordance with appropriate instructions, procedures, and checklists for the following activities:

1. Special processes

2. Inservice inspection

3. Major projects performcd in a manner similar to original construction.

Further, process utilized to control work at the operating nuclear plants must contain provisions identifying the need for inspection, identification of inspection personnel, and documentation of inspection results.

Further, modification and maintenance projects, performed in a manner similar to traditional construction work, must include provisions for inspection in accordance with applicable requirements of ANSI N45.2.4-1972 as modified by Safety Guide 30 - August 11, 1972; ANSI N45.2.5-1974 as modified by Regulatory Guide 1.94 Rev 1; ANSI N45.2.6-1973 as modified by Regulatory Guide 1.58 - August, 1973, and ANSI N45.2.8-1975.

Further, it is noted that activities normally assigned to the plant organization do not require additional inspection except those activities which involve Special Processes and those activities which involve Inservice Inspections.

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NORTHERN STATES POWER COMPANY Mr. Gaston Fiorelli March 8, 1979 Page 5 The justification for the above position is as follows:

The fundamental basis utilized in formulating the Operational Quality Assurance Program is the Operational Quality Assurance Plan including the regulations, codes, standards, and specifications identified and committed to in the Plan. The fundamental principle utilized is that adequate quality must be assured.

The Operational Quality Assurance Plan,10CFR50 Appendix B, and ANSI 18.7 all contain the following qualifying words relative to inspection requirements:

" Examination, measurements or tests of material or products shall be performed for each work operation where necessary to assure quality."

The traditional methods of performing construction activities relative to work control diff er greatly from that utilized by NSP plant maintenance organizations. NSP maintenance organizations utilize a greater degree of supervision of work during actual performance, a stringent review and authorization process, verification of operability subsequent to performance of work and review of completed documentation by knowledgeable personnel.

Considering these factors, it is felt that additional inspection is not normally needed to assure quality relative to modification and maintenance activities normally performed by NSP plant organizations except that the activities that involve Innervice Inspections at A Special Processes must be inspected. Inservice Inspection activities must be performed in accordance with applicable code rquirement; inspection of Special Processes is appropriate since plant maintenance personnel generally do not perform these processes frequently and because such processes are generally critical to quality.

Yours very truly, L. .

[

'achter Vice President - Power Production and System Operation cc: Mr. G. Charnoff 2273 361