ML20003G696
| ML20003G696 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 04/03/1981 |
| From: | Gilberts D NORTHERN STATES POWER CO. |
| To: | Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20003G695 | List: |
| References | |
| NUDOCS 8104300557 | |
| Download: ML20003G696 (4) | |
Text
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.f ft 9-Northem States PowerCompany f
2 414 Nicollet Matt D.E Gittierts
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Mirineapohs. Minnesota $$401 senior vice presteent Telephone (612) 330-6071 Power supply April 3, 1981 Mr. R. F. Heishman, Chief Reactor Operations and Nuclear Support Branch Region III, Office of Inspection and Enforce =ent U. S. Nuclear Regulatory Cennission 799 Reasevelt Road Glen Ellyn, IL 60137
Dear Mr. Heishman:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 and 50-306 In response to your letter of March 9,1981,- which transmitted Inspection Reports 50-282/81-01 and 50-306/81-01, the following is offered.
Nu= bering of the items corresponds to the nu= bering in Appendix A to your letter.
Except as noted below, the noncompliance items are correct as stated.
1.
a.
Our records indicate that audits of 3ACD 9.1 Rev. O, Surveillance Programs, and 3ACD 9.2 Rev. O, Surveillance Procedures, were com-pleted on January 6, 1981 and January 7, 1981 respectively. The,
results of these audits are delineated in Audit Reports 80-37-3-9.1 and 80-38-3-9.2 (issued February 11, 1981). The next audit of the surveillance area is presently scheduled for the third quarter of 1981.
1.
b.
Administrative Control Directive 3ACD 2.2, Audits, was revised-(Revision 6) effective February 17, 1981 to require that a post audit conference be held at the conclusion of each audit with the management of the audited organization to present audit findings and clarify misunderstandings. It was intended that Revision 6 of 3ACD 2.2 include a provision for pre-audit conferences also; this requirement was inadvertently omitted although such conferences are presently held. Action has been initiated to correct this error; Revision 7 of 3ACD 2.2 is expected to be issued by May 15, 1981.
1.
c.
We have reviewed the subject audits and concur that there is a lack of objective evidence provided in the audits of SACD 14.3 dated October 9, 1980 and SACD 8.1 dated December 29-31, 1980. We contend that the remaining audits referenced provide adequate objective evi-dence to identify program deficiencies and assess the effectiveness of the Quality Assurance Program in the areas audited. It should be noted that the subject of 5ACD 14.3, Nondestructive Examination, is also audited during the conduct of audits of the Design Change and Work Con-trol processes; the subject of SACD 3.1, Receiving Process, is also 810.4300557 APR 6 gg__
q, Mr. R. F. Heishman Page 2 April 3, 1981 audited during the audits of the Procurement Process, Design Change Process and the Control of Nonconforming items. It is believed that familiarity with the documentation _in these two areas, based.
on related or previous audits, resulted.in the lack of verifiable objective evidence documented in the audit reports.
We have recognized the importance of a well-implemented and docu-mented audit program and have taken measures to improve it.
A re-view of an additional eighteen audit reports (conducted in 1980) for objective evidence and a review of the independent audits of the Prairie Island Internal Audit Program, indicates a steady im-provement in this area.
In order to standardize and improve the program, the Prairie Island Quality Section issued two Section Work Instructions:
- 1) SWI-SQE-2, Preparation of Audit Plans / Checklists and 2) SWI-SQE-3, Audit Conduct, Reporting and Follow-up on December 30, 1980 to further improve the internal audits scheduled for 1981. In particular, SWI-SQE-3 section 6.3.2 requires that substantiating remarks be entered in the comments section of the audit plan / checklist and that copies of documents substantiating program deficiencies be attached, if possible. We believe that the internal audit program is in full compliance with -
the requirements at this time.
2.
Personnel access lists for records will be established by May 1,1981.
The auxiliary building logs and snubber qualification records nre now.
stored in fireproof cabinets. All quality records are either in fire-proof cabinets or have been microfilmed with remote storage utilized.
3.
- a. & b.
The Prairie Island Quality Control Inspection Program is in its final stages of implementation and development. At the time of the NRC Audit, the inspection program did not formally addr'ess
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the area of handling equipment or rigging. Since the establishment of the Quality Control Section at Prairie Island (early 1980), the inspection program has been geared towards the activities of non-routine maintenance, instrument calibration, routine maintenance and minor modifications, and surveillance testing and calibration.
The scope of the inspection program was initially limited to those areas in order to obtain the necessary feedback to determine if any generic deficiencies existed in the program.
Since the NRC Audit, the QC Inspection Program has been expanded to cover the areas of storage and handling equipment. These areas will be inspected on a periodic basis in accordance with the Prairie Island Quality Assurance Program.
The initial inspections of the storage areas and handling equipment and rigging, under the QC Inspection Program, will be completed by May 15, 1981.
n
3 Mr. R. F. Heishman Page 3 April 3, 1981-3.
-c.
Access control has now been established; only stockroom personnel and supervisors are allowed unescorted access. The rear doors of Warehouse A and B are now locked.
3.
d.
This item w"as caused by insufficient storage space. Arrargements are being made to rent supplemental storage space for noncritical items.
3.
e.
Warehouse personnel have been instructed not to issue QA-1 item h n
turned over from Construction unless the items have been evalua< ed'# (t I
to show compliance with applicable specifications, codes and sta dards. Full compliance has been achieved in this area.
3.
f.
Materials marked " Flammable Liquid" have been removed from close proximity to important nuclear plant items.
3.
g.
Caps and covers will be purchased and installed on the necessary valves, flanges, pipes and fittings by June 30, 1981.
Cribbing and shoring will be utilized as necessary by June 30, 1981.
3.
h.
Procedures will be written and implemented for the periodic turning of rotating shafts by May 15, 1981. Measures will be established for the care of items according to shelf life conditions by May 15, 1981.
3.
- i. Lead riggers will verify competence of personnel assigned to operate material handling equipment. This verification of competence will be written or oral evaluation of the individual. Documentation will be retained by the Prairie Island Training Section.
4.
The reason the design change was not closed out within 3 months af ter in-stallation was due to delays in drafting drawing revisions. Corrective action included filling an' existing vacancy in the Drafting Department and more frequent auditing of incoming and outgoing drawing packages.
The entire matter of timely close out of design changes is a recognized problem. We are currently reviewing the process and will develop im-proved methods.
The design change package did not contain documentation of training.
This was due to a communication problem. Corrective action involved re-instructing responsible engineers on the use of the form which documents training. Full compliance has been achieved with the issuance of instruc-tions concerning this problem and review of the completed design change packages before close out.
Yours truly, W d/' W D. E.
11berts Senior Vice President Power Supply Attachment cc:
Mr. C. Charnoff Mr. C. D. Feierabend
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UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES PO*n'ER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLA'.'T Docket Nos. 50-282 and 50-306 LETTER DATED APRIL 3, 1981 RESPONDING TO NRC REQUEST FOR INFORMATION IN INSPECTION REPORTS 50-282/81-01 AND 50-306/81-01 Northern States Pcr.cer Company, a Minnesota corporation, by this letter dated April 3,1981, hereby sub=its information in response to NRC request for information concerning Inspection Reports 50-282/81-01 and 50-306/81-01.
This request contains no restricted or other defense infor=ation.
NORTHER STATES PO'n'ER COMPA';Y D
By: U f
Dennis E. Gilberts Senior Vice President Power Supply 84<[ day of ddp2 19 7 /
, before =e a notary On this public in and for said Countf, personally appeared D. E. Gilberts, Senior Vice President Power Supply, and being first duly sworn acknowledged that he is authorized to execute this docu=ent on behalf of Northern States Power Co=pany, that he knows the contents thereof and that to the best of his know-ledge, information and belief, the state =ents =ade in it are true and that it is not interposed for delay.
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