ML20034F970
| ML20034F970 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/01/1993 |
| From: | Antony D NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9303080018 | |
| Download: ML20034F970 (7) | |
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Northern States Power Company 414 Nicollet Mall Minneapohs. Minnesota 55401 Telephone (612) 330-5500 March 1, 1993 U S Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555 PRAIRIE IS1AND NUCLEAR GENERATING PIANT Docket Nos. 50-282 License Nos. DPR-42 50-304 LJR-60 Response to Notice of Violation 92025 Weakness in the Ouality Assurance Pronram Your letter of January 28, 1993, which transmitted Inspection Report No. 50-282/92025 (DRS) and 50-306/92025 (DRS), requested a response to the Notice of Violation. is offered in response to that request.
There are four items addressed in the Notice gf Violation; we responded to each one separately.
In summary, we believe the actions taken and those proposed will ensure compliance with ANSI N45.2.6 - 1978, as modified by Regulatory Guide 1.58.
This letter contains the following new NRC commitments:
A random verification of education requirements will be added to the certification process. This action will be completed by April 30, 1993.
Guidelines will be developed for the use of "related experience" including limitations on applying this experience.
These guidelines will be included in Administrative Cor.crols or the Certification Manual.
The guidelines will be based on the requirements of ANSI N45.2.6 and a survey of practices in the nuclear industry. This will be completed by May 31, 1993.
Training on these guidelines will be conducted for individuals who certify Quality Control personnel. This training will be completed by June 30, 1993.
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c Northem States Power Company USNRC March 1, 1993 Page 2 s
All active Quality Control certifications at Prairie Island will be re-evaluated using the newly developed guidelines. The impact of any certifications which do not meet the guidelines will be evaluated on a case-by-case basis.
This will be completed by August 31, 1993.
All Level III personnel on site will be trained in the requirements and use of Form 1-3011.
This will be complete by April 30, 1993.
Current evaluation forms will be included for all active certifications of all personnel at the Prairie Island site. This will be completed by April 30, 1993.
A Quality Assurance audit will be conducted on Material and Special Processes Administrative Procedure M&SP 6.1 by December 31, 1993.
These issues will be reviewed for applicability to Monticello also.
Should you have any questions on this response, please contact Tom Parker at 612-337-2030.
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DougllasDAntonyl y
Vice President Nuclear Generation c:
Regional Administrator, Region III, NRC Senior Resident Inspector, NRC NRR Project Manager, NRC J E Silberg State of Minnesota Kris Sanda
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4 ATTACHMENT 1 Response to Notice of Violation 92025 Weakness in the Ouality Assurance Program Violation "a" a.
The inspector certification program, described in Corporate Nuclear Administrative Control Directive NlACD 3.2 and Administrative Control i
I Directive SACD 3.21, did not prescribe the changes to ANSI N45.2.6 which were required by Regulatory Guide 1.58.
Regulatory Guide 1.58 requires a high school diploma or successful completion of general education l
equivalent (GED) testing for certified QC inspectors. These directives, which delineate the requirements for qualifying QC inspectors, do not include this education requirement (282/92025-OlA(DRS); 306/92025-OlA(DRS)).
Reason for the Violation The Regulatory Guide 1.58 requirement for a high school diplema or GED was not i
included in corporate administrative controls or implementing procedures.
Since the Operational Quality Assurance Plan commits NSP to comply with Regulatory Guide 1.59, adminis ative controls should have implemented this requirement. The omission of ac requirement was an oversight.
In August 1981, our commitment to Regulatory Guide 1.58 included an exception to the above educational requirement. A subsequent submittal in 1986 inadvertently omitted the educational exception. At this time, we were committed to comply with the educational requirement. This chaags. was not l
identified when the corporate administrative control documents were revised or during subsequent periodic reviews.
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We are considering requesting an exception to this requirement in the near future.
Corrective Steps That Have Been Taken and Results Achieved N1ACD 3.2, SACD 3.21 and the certification Manual have been revised to include the requirement for a high school education or GED.
All active certifications at Prairie Island meet this education requirement.
l Corrective Actions That Will Be Taken to Avoid Further Violations l
A random verification of education requirements will be added to the l
certification process. This action will be completed by April 30, 1993.
Date When Full Compliance will be Achieved Full compliance has been achieved.
i USNRC March 1, 1993 Page 2 Violation "b"
b.
Certification records indicated that tuo QC inspectors were improperly certified since journeyman or craft experience was accepted to certify inspectors rather than limiting applicable experience to inspection,
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examination, and testing as required by Section 6.6 of SACD 3.21,
" Qualification and Certification of Inspection, Examination, and Testing Personnel," Revision 1, and Attachment 4 to Chapter 1 of the l
Certification Manual, " Qualification and Certification of QC Inspection, Personnel," Revision 1 (282/92025-01B(DRS); 306/92025-01B(DRS)).
Reason for the Violation We don't believe that these individuals were improperly certified, but our records are deficient in documenting the rationale used for applying l
journeyman experience as equivalent inspection, examination and testing experience.
ANSI N45.2.6 and NSP administrative control directives (N1ACD3.2 and SACD3.21) l specify that the experience requirements shall be met by "related experience l
in equivalent inspection, examination and testing activities." Prairie Island j
has used Nuclear Navy and discipline related trade enperiet,ce as related i
experience. No written guidelines on what constitutes related experience or
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the limitations on applying this experience were included in the certification procedures.
Corrective Steps That Have Been Taken and Results Achieved The work performed by the two referenced Quality Control inspectors has been reviewed, with a sampling of the work being re-inspected. No safety-related problems were identified.
Certifications for all Quality Control personnel no longer at the Prairie Island site have been de-activated and, if these individuals return, they will be re-certified using the guidelines for experience which will be developed.
Corrective Actions That Will Be Taken to Avoid Further Violations Guidelines will be developed for the use of "related experience" including limitations on applying this experience.
These guidelines will be included in administrative controls or the Certification Manual.
The guidelines will be based on the requirements of ANSI N45.2.6 and a survey of practices in the nuclear industry. This will be completed by May 31, 1993.
Training on these guidelines will be conducted for individuals who certify Quality Control personnel.
This training will be completed by June 30, 1993.
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4 USNRC March 1, 1993 Page 3
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All active Quality Control certifications will he re-evaluated using the newly developed guidelines. The impact of any certifications which do not meet the guidelines will be evaluated on a case-by-case basis. This will be completed by August 31, 1993.
Date When Full Compliance will be Achieved Full compliance has been achieved.
t USNRC March 1, 1993 Page 4 Violation "c" c.
Qualification evaluation forms, Form 1-3011, were not used as required by Section 5.1.2 of Chapter 1 of the Certification Manual, I
" Qualification and Certification of QC Inspection Personnel," Revision l
1.
In some cases, the evaluation forms were not used, and in most i
cases, when the evaluation forms were included, the form did not actually indicate that an evaluation was performed but contained nondescriptive statements such as "see resume" (282/92025-01C(DRS);
i 306/92025-01C(DRS)).
Reason for the Violation i
The reason for this violation is a lack of awareness of the requirement and inattention to detail.
Evaluation forms were not always included in the
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certification files and, when they were, the evaluations were not documented well.
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Corrective Steps That Have Been Taken and Results Achieved 4
Current evaluation forms 1-3011 have been included for all active 1
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certifications of personnel reporting to the Superintendent Quality Services.
All level III personnel reporting to the Superintendent Quality Services (i.e.
those individuals who certify personnel) have been trained in the requirements and use of the 1-3011 form.
Corrective Actions That Will Be Taken to Avoid Further Violations All Level III personnel on site will be trained in the requirements and use of Form 1-3011.
This will be complete by April 30, 1993.
Current evaluation forms will be included for all active certifications of all personnel at the Prairie Island site. This will be completed by April 30, 1993.
Date When Full Compliance will be Achieved Full compliance will be achieved by April 30, 1993.
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March 1, 1993 Page 5 Violation "d"
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Changes had been and were continuing to be made to the NSP Welding Manual by letter rather than using the revision methods specified by NLACD 2.2, " Document Review and Approval", Revision 5 (282/92025-OlD(DRS); 306/92025-01D(DRS)).
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Reason for the Violation 1
No formal system for controlling changes to the Welding Manual was in place.
Internal correspondence was used to communicate proper technical changes to welding requirements in lieu of changing the Welding Manual. These changes l
were job specific and management decided it was appropriate to issue internal correspondence to the personnel involved in the specific job. This was not
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consistent with the Quality Assurance Program.
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This violation had been identified by NSP Quality Assurance personnel.
However, corrective action had not been completed at the time of this i
inspection.
Corrective Steos That Have Been Taken and Results Achieved i
All Welding Manual holders were sent a letter canceling all changes made to the Welding Manual requirements not in conformance with revision methods described in NlACD 2.2 " Documents Review and Approval" Revision 5.
Corrective Actions That Will Be Taken to Avoid Further Violations Material and Special Processes Administrative Procedure M&SP 6.1 was written and distributed establishing the requirements for preparation, control and distribution of the Welding Manual.
A Quality Assurance audit will be conducted on Material and Special Processes Administrative Procedure M&SP 6.1 by December 31, 1993.
Date When Full Compliance will be Achieved Full compliance has been achieved.
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