ML20059A367
| ML20059A367 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/20/1993 |
| From: | Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Antony D NORTHERN STATES POWER CO. |
| References | |
| NUDOCS 9310260313 | |
| Download: ML20059A367 (1) | |
See also: IR 05000282/1992025
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ill
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799 ROOSEVELT ROAD
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GLEN ELLYN. ILUNOIS 60137-5927
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007 2 0 1993
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Docket No.
50-282
Docket No.
50-306
Northern States Power Company
ATTN: Mr. D. D. Antony
Vice President
Nuclear Generation
414 Nicollet Mall
Minneapolis, MN 55401
-
Dear Mr. Antony:
This will acknowledge receipt of your letter dated October 13, 1993.
This
letter revised your previous responses dated March I and April 22, 1993.
These letters responded to our letter dated January 28, 1993, transmitting a
Notice of Violation associated with Inspection Reports No. 50-282/92025(DRS)
and No. 50-306/92025(DRS) and subsequent telephone discussions on the matter.
These reports summarized the results of our inspection of quality control
inspector qualification and certification at your Prairie Island Nuclear
Generating Station.
We find the described changes to be accpetable and will examine your
+
corrective actions during future inspections.
Sincerely,
M L.
&
William L. For
, Afting Dir
o
Division of Reactor Safety
cc:
E. L. Watzl, Site Manager,
Prairie Island Site
M. Wadley, Plant Manager
R. Anderson, Director, Licensing
and Management Issues
cc w/ltrs dtd 03/01/93;
04/22/93; and 10/13/93:
OC/LFDCB
Resident Inspector, Rill
Prairie Island
Resident Inspector, Rill
Monticello
John W. Ferman, Ph.D.,
Nuclear Engineer, MPCA
State Liaison Officer, MN
Prairie Island LPM, NRR
,
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D. Funk, R]Il
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9310260313 931020
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Northern States Power Company
414 tbcoltet Mall
fAnneapohs. Minnesota 55401
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Telephone (612) 330 5500
'
March 1, 1993
,
,
U S Nuclear Regulatory Commission
Attn:
Document Control Desk
Washington, DC 20555
,
,
?
PRAIRIE ISLAND NUCLEAR CENERATING PIANT
Docket Nos. 50-282 License Nos. DPR-42
50-304
[
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3
Response to Notice of Violation 92025
,
L'e akne s s in the Ouality Assurance Fronram
'
,
Your letter of January 28, 1993, which transmitted Inspection Repert No. 50-
i
282/92025 (DRS) and 50-306/92025 (DRS), requested a response to the Notice of
,
Violation. Attachment 1 is offered in response to that request. There are
four items addressed in the Notice of Violation; we responded to each one
,
separately.
,
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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:
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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
l
will be included in Administnative 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.
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Training on these guidelines will be conducted for individuals who
!
certify Quality Control personnel. This training will be completed by
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June 30, 1993.
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Northem States Power Company
March 1, 1993
Page 2
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.
.l
Current evaluation forms will be included for all active certifications
!
of all personnel at the Prairie Island site. This will be completed by
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April 30, 1993.
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A Quality Assurance audit will be conducted on Material and Special
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Processes Administrative Procedure M&SP 6.1 by December 31, 1993.
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issues will be revie[ed for applicability to Monticello also.
Should
These
you have any questions on this response, please contact Tom Parker at 612-337-
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2030.
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Douglas D Antony
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Vice President
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Nuclear Generation
Re'gional Administrator, Region III, NRC
c:
Senior Resident Inspector, NRC
NRR Project Manager, NRC
1 E Silberg
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State of Minriesota
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Kris Sanda
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ATTACHMENT 1
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Response to Notice of Violation 92025
Weakness in the Ouality Assurance ProRram
l
Violation "a"
3
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a.
The inspector certification program, described in Corporate Nuclear
!
Administrative Control Directive NlACD 3.2 and Administrative Control
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
j
,
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)).
'
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Reason for the Violation
!
The Regulatory Guide 1.58 re,quirement for a high school diploma or GED was not
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4
included in corporate administr'ative controls or implementing procedures.
l
Since the Operational Quality Assurance Plan commits NSP to comply with
j
Regulatory Guide 1.58, administrative controls should have implemented this
l
requirement.
The omission of the requirement was an oversight.
i
In August 1981, our commitment to Regulatory Guide 1.58 included an exception
!
to the above educational requirement. A subsequent submittal in 1986
'j
inadvertently omitted the educational exception. At this time, we were
j
committed to comply with the educational requirement. This change was not
j
identified when the corporate administrative control documents were revised or
!
during subsequent periodic reviews.
!
We are considering requesting an exception to this requirement in the near
future. '
Corrective Steps That Have Been Taken and Results Achieved
I
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N1ACD 3.2, SACD 3.21 and the Certification Manual have been revised to include
the requirement for a high school education or GED.
i
All active certifications at Prairis Island meet this education requirement,
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Corrective Actions That Will Be Taken to Avoid Further Violations
A random verification of education requirements will be added to the
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certification process.
This action will be completed by April 30, 1993.
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Date When Full Compliance will be Achieved
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Full compliance has been achieved.
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March 1, 1993
Page 2
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Violation
"b"
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b.
Certification records indicated that two QC inspectors were improperly
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certified since journeyman or craft experience was accepted to certify
inspectors rather than limiting, applicable experience to inspection,
j
examination, and testing as required by Section 6.6 of 5ACD 3.21,
l
" Qualification and Certification of Inspection, Examination, and Testing
Personnel," Revision 1, and Attachment 4 to Chapter 1 of the
i
Certification Manual, " Qualification and Certification of QC Inspection.
{
Personnel," Revision 1 (282/92025-OlB(DRS); 306/92025-01B(DRS)).
!
Reason for the Violation
l
We don't believe that these individuals were improperly certified, but our
records are deficient in documenting the rationale used for applying
,
journeyman experience as equivalent inspection, examination and testing
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experience.
,
.
i
ANSI N45.2.6 and NSP administrative control directives (NlACD3.2 and SACD3.21)'
specify that the experience requirements shall be met by "related experience
in equivalent inspection, examination and testing activities." Prairie Island
'
has used Nuclear Navy and discipline related trade experience as related
l
experience.
No written guidelines on what constitutes related experience or
j
the limitations on applying this experience were included in the certification
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procedures.
!
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corrective Stens That Have Been Taken and Pesults Achieved
i
The work performed by the two referenced Quality Control inspectors has been
i
reviewed, with a sampling of the work being re-inspected. No safety-related
problems were identified.
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certifications for all Quality Control personnel no longer at the Prairie
Island site have been de-activated and, if these individuals return, they will
I
be re-certified using the guidelines for experience which will be developed.
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Corrective Actions That Will Be Taken to Avoid Further Violations
Guidelines will be developed for the use of "related experience" including
i
limitations on applying this experience.
These guidelines will be included in
1
'
!
administrative controls or the Certification Manual.
The guidelines will be
baser on the rec.uirements of ANSI N45.2.6 and a survey of practices in the
nuclear industry
This will be completed by May 31, 1993.
!
I
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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March 1, 1993
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Page 3
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All active Quality Control certifications will~be re-evaluated using the newly
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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
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by August 31, 1993.
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Date k' hen Full Compliance will be Achieved
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Full compliance has been achieved.
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March 1, 1993
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Violation "c"
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c.
Qualification evaluation forms, Form 1-3011, were not used as required
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by Section 5.1.2 of Chapter 1 of the Certification Manual,
!
" Qualification and Certification of QC Inspection Personnel," Revision
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,
1.
In some cases, the evaluation forms were not used, and in mos*
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cases, when the evaluation forms were included, the form did not
actually indicate that an evaluation was performed but contained
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nondescriptive statements such as "see resume" (282/92025-OlC(DRS);
306/92025-OlC(DRS)).
.
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Reason for the Violation
!
The reason for this violation is a lack of awareness of the requirement and
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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
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well.
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Corrective Steps That Have Been Taken and Results Achieved
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Current evaluation forms 1-3011 have been included for all active
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certifications of personnel reporting to the Superintendent. Quality Services.
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All Level III personnel reporting to the Superintendent Quality Services (i.e.
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those individuals who certify personnel) have.been trained in the requirements
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and use of the 1-3011 form.
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Corrective Actions That Vill Be Taken to Avoid Further Violations
All Level III personnel on site will be trained in the requirements and use of
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Form 1-3011.
This will be complete by April 30, 1993.
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Current evaluation forms will be included for all active certifications of all
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personnel at the Prairie Island site. This will be completed by April 30,
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1993.
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Date When Full Compliance will be Achieved
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Full co=pliance will be achieved by April 30, 1993.
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March 1,1993 -
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Page 5
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violation
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Changes had been and were continuing to be made to the NSP Velding'
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Manual by letter rather than using the revision methods specified by
N1ACD 2.2, " Document Review and Approval", Revision 5 (282/92025-
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OlD(DRS); 306/92025-OlD(DRS))..
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Reason for the Violation
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No formal systee for controlling changes to the Velding Manual was in place.
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Internal correspot,dence was used to communicate proper technical changes to
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welding requirements in lieu of changing the Welding Manual.
These changes
I
were job specific and management decided it was appropriate to issue internal.
correspondence to the personnel involved in the specific job.
This was not
,
consistent with the Quality , Assurance Program.
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This violation had been identified by NSF Quality Assurance personnel.
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However, corrective action had not been completed at the time of this
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inspection.
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Corrective Steps That Have Been Taken and Results Achieved
.
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
.
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Material and Special Processes Administrative Procedure M&SP 6.1 was written
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and distributed establishing the requirements for preparation, control and
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distribution of the' Welding Manual.
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A Quality Assurance audit will be conducted on Material and Special Processes
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Administrative Procedure M&SP 6.1 by December 31, 1993.
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Date When Full Compliance will be Achieved
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Full compliance has been achieved.
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Northem States Power Company
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414 Nicollet Mall
Minneapohs. Ennesota 55401 1927
Telephone (612) 330-5500
t
April 22, 1993
,
1
US Nuclear Regulatory Commission
Attn:
Document Control Desk
Washington, DC 20555
PRAIRIE 15ED NUCLEAR CENERATING PIANT
,
Docket Nos. 50-282 License Nos. DPR-42
!
50-306
e
Revised Response to Violation
"b"
,
of Notice of Violation 92025
}
Ueakness in the Ouality Assurance Protram
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
Viola.: ion.
Our response was provided on March 1, 1993.
Following discussions
with Al Walker and Mark Ring of Region III staff, our response to Violation
"b" has been revised (note sidebarred area of Attachment 1).
Attachment 2
contains draft guidelines for determining equivalency of related experience
for certification of QC inspectors, discussed in the corrective actions for
violation "b";
.
This letter contains no new NRC commitments.
l
Should you have any questions on this response, please contact Tom Parker at
612-337-2030.
5
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Clf) A4
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Douglas D Antony
Vice President
'
,
Nuclear Generation
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cc:
Regional Administrator - III, NRC
NRR Project Manager, NRC
Sr Resident inspector, NRC
[
State of Minnesota
Attn: Kris Sanda
J Silberg
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ATTACHMENT 1
.
Revised Response to Violation
"b"
I
.
of Notice of Violation 92025
l
Weakness in the Ouality Assurance Program
1
violation
"b"
b.
Certification records indicated that two QC inspectors were improperly-
,
'
certified since journeyman or craft experience was accepted to certify
inspectors rather than limiting applicabic experience to inspection,
i
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
Certification Manual, " Qualification and Certification of QC Inspection
Personnel," Revision 1 (282/92025-OlB(DRS); 306/92025-01B(DRS)).
i
Reason for the Violation
j
We agree that one of the two QC inspectors was improperly certified.
This QC
-;
inspector did not meet the educational requirements for certification.
We do
believe both QC inspectors have the necessary work experience for
certification.
Our records are deficient in documenting the rationale used
!
for applying journeyman experience as equivalent inspection, examination and.
.;
testing experience.
!
ANSI N45.2.6 and NSP administrative control directives (NlACD3.2 and'5ACD3.21)
specify that the experience requirements shall be met by "related experience
in equivalent inspection, examination and testing activities." Prairie Island
has used Nuclear Navy and discipline related trade experience as related
r
experience. No written guidelines on what constitutes related experience or
,
the limitations on applying this experience were included in the certification
t
procedures.
Corrective Steps That Have Been Taken and Results Achieved
,
I
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,
i
Corrective Actions That W.11 Be Taken to Avoid Further Violations
Cuidelines 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 on ANSI N45.2.6 and a survey of practices in the
nuclear industry.
This will be completed by May 31, 1993.
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Training on these' guidelines will be conducted for individuals who certify
{
Quality Control personnel
This training will be completed by June 30, 1993.
I
. All active Quality Control certifications will be re-evaluated using the newly
f
developed guidelines. .The impact of any certifications which do'not meet the '
!
guidelines will be evaluated on a case-by-case basia. This will be' completed
by August 31, 1993.
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Date When Ful? Compliance will be Achieved
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Full compliance has been achieved.
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DRAFT
ATTACID!ENT 2
FOR COMMENT DNLY
s
Guidelines for Related Experience
The purpose of this attachment is to provide a standard basis for evaluating the
cauivalency of related experience. Work experience needs to be related tc .he
discip'ine's technical topics and involve aspects of inspection, examination, or
testing activities. These guidelines are intended to initiate a logical assessment of
previous work experience and is to be used along with the candidate's familiarity
with the technical topics and the results of any proficiency testing as a basis for
certification.
For the purposes of these guidelines, experience will first be classified as under a
QA program, or not under a QA program. In addition, experience will be classified
as inspector, Same Discipline; inspector, Related Discipline; or Other Related
Experience. Credit for experience should be given in accordance with the fo!!owing
'
table and may be documented on the attached WORK EXPERIENCE SUMMARY
form.
.
Type of Experience
Under a QA Program
Not Under a QA Program
Factor
Max Credit
Factor
Max Credit
(%)
(%)
Inspector, Same Discipline
1:1
100
1:2
50
Inspector, Related Discipline
1:1
100
1:4
50 *
, Other Related Experience
1:2
100
1:4
50 *
The combination of Inspector, Related Discipline (Not under a QA Program),
and Other Related Experience (Not Under a QA Program) should not exceed
50% total
,
Refer to the attached for examples of related disciplines and other related
experience.
NOTE: The credited, related work experiences must have a documented
'
relationship to the technical topics lists (example: electrician experience
involves cable terminations). If the resume is not explicit to the activities
,
performed during the related experience, these activities must be
documented in the Levellil's evaluation of the experience.
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Experience Criteria
Duration
Under a
Type of Experience
Start
End
of
OAP
Months -
Description of Experience
Dato
Dato
Experience
inspector
Inspector
Other
Allowed
Same
Related
Related
(Months)
Yes
No
Disciplino
Discipline
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Under a OA Program
Not Under a OA Program
Total Months Allowed
Factor
Max Credit
Factor
Max Credit
Remarks
(%)
(H)
Inspector, Samo Disciplino
1:1
100
1:2
50
Inspector, Related Disciplino
1:1
100
1:4
50 *
Other Related Experience'
1:2
100
1:4
50 *
Evaluated by
Date
- Total of the two not to exceed 50%
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DRAFT
FOR COMMENT ONLY
EXAMPLES
CIVIL / STRUCTURAL
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Related Inspection Disciplines:
General Inspection
Nuclear Coatings
other Related Experience:
Civil Testing Lab or Commercial Testing Facility
Military Service Construction Battalions or similar
ratings (after completion of bcsic training)
Civil Construction Engineer (post BS degree)
ELECTRICAL
Related Inspection Disciplines:
General Inspector
Instrumentation and Control
other Related Experience:
Journeyman Electrician (heavy industry only)
Nuclear Navy - Electricians Mate, I&C Technician
(after completion of basic training)
I&C Technician
Electrical or I&C Systems Engineer (post BS degree)
,
GENERAL INSPECTION
Related Inspection Disciplines:
Civil / Structural
Electrical
Instrumentation and Control
'
Mechanical
Nuclear Coatings
Operations
Radiation Protection / Chemistry
Other Related Experience:
,
QA Auditor or Surveillor
Nuclear Navy
(after completing basic training)
Journeyman Craft Experience
Systems Engineer (post BS degree)
INSTRUMENTATION AND CONTROLS
Related Inspection Disciplines:
Electrical
General Inspection
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Other Related Experience:
,
DRAFT
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FOR COMMENT ONLY
I&C Technician
Nuclear Navy - Electricians Mate, I&C Technician (after
completion of basic training)
I&C or Electrical Systems Engineer (post BS degree)
MECHANICAL
Related Inspection Discipline,s:
General Inspection
Welding
Other Related Experience:
Nuclear Navy - Machinist Mate, Engineman or similar
rating (after completion of basic training)
Journeyman Boilermaker, Steamfitter, Pipefitter or
other similar crafts (heavy industry only)
Commercial Welding when involved in fitup or other
inspection sequences
Mechanical Systems Engineering (post BS only)
NUCLEAR COATINGS
Related Inspection Disciplines:
Civil / Structural
General Inspection
other Related Experience:
Journeyman Painter with nuclear background
OPERATIONS
Related Inspection Disciplines:
General Inspection
other.Related Experience:
Nuclear Navy reactor operator (after completing basic
training)
Operator - Nuclear power plant (post apprenticeship)
Operator Trainer - Nuclear power plant
Systems Engineer with a SRO or SRO certified ( post
BS and post SRO)
RADIATION PROTECTION / CHEMISTRY
Related Inspection Disciplines:
General Inspection
Other Related Experience
Nuclear Navy - ELT or other similar ratings (after
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DRAFT
FOR COMMENT DNLY
completion of basic training)
Industrial Chemistry or Health Physics Technician.
Chemist or Health Physicist (post BS degree)
RECEIPT AND MATERIAL CONTROL
Related Inspection Disciplines:
Civil / Structural
Electrical
General Inspection
Instrumentation and Control
Mechanical
Nuclear Coatings
Operations
Radiation Protection / Chemistry
Welding
Other Related Experience:
Any experience that required an individual to locate
acceptance criteria documents and then determine
that an object met the requirements of those
documents such as work under a military purchasing
program (MIL SPEC'S) or in Receiving, Vendor
Auditing or purchasing
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Northem States Power Ccmpany
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414 Nicot:ct Ms!!
Minneapo!is, Minner;:a $543t.1927
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Telephone (612) 33)s500
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October 13,1993
U S Nuclear Regulatory Commission
Atta: Document Control Desk
Washington, DC 20555
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PRAIRIE ISLAND bUCLEAR GENERATING PLAh7
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Docket Nos. 50-28; ,
License Nos. DPR-42
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50-30:
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Supplemental Respon. e to Notice of Violation 92025
Weakness in the quality Assurance Prograra
Following discussions with Jeff Wright, R-gion 111, we have modified our position concerning
the acceptability of using joumeyman or c aft experience for certification. Violation "b'
stated:
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Certification records indicated that :wo QC inspectors were improperly cenified since
journeyman or craft experience wa accepted to certify inspectors rather than limiting.
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applicable experience to inspection examination, and testing as required by Section
6.6 of SACD 3.21, Qualification md Certification of Inspection, Examination, and
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Testing Personnel," Rev!sion 1, nnd Attachment 4 to Chapter 1 of the Cer:ificatica
Manual, Qualification and Cenifi( ition of QC Inspection Personnel," Revision 1
(282/92025 01B(DRS); 306/92025 01B(DRS)).
NSP's commitment to ANSI N45.2.6-1976, Qualifications ofInspection, Examination, and
Testing Personnelfor Nuclear Power Plants, as modified by Regulatory Guide 1.58 revision
1, remains unchanged. O.ur implementin; procedures allow journeyman or craft experience
to be accepted as applicable inspect!on experience. Tnese implementing procedures will be
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revised to assure cenification is demonstr. ted by:
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docurneatation of related c: perience in inspection, examination or testing,
or,
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testing to demonstrate prof :iency in inspection, examination or testing,
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or,
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capcb!:i:y demonstration of proficiency inspection, examination, or testing.
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In addition, the Nuclear Quality Departc. ant is performing an audit to verify NSP's
compliance to ANSI N45.2.6-1978 as mcdified by Regulatory Guide 1.58, Revision 1. The
revision to the implementing ' procedures md the audit will be completed by February 1,1994.
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Any resulting audit findings will be appi.)priately resolved.
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This letter contains the following new NRC commitments:
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An audit to verify NSP's compliance to ANSI N45.2.6-1978 as modified by
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Regulatory Guide 1.58, Revision 1. To be completed by February 1,1993.
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Revision of documents implementing ANSI N45.2.6-1978 as modified by
Regulatory Guide 1.58, R-vision 1. To be completed by February 1,1993.
Previous NSP-NRC coirespondence concerning violation 92025 are letters dated March 1,
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1993, April 22,1993, and July 21,199?. Should you have any questions on this response,
please contact Roger Anderson (612 33',-2050) or Paul Kamman (612-337 2211).
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R ger Anderson
Director
Licensing and Management Issues
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Regional Administrator- Region III, NRC
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Senior Resident Inspector, NRC
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NRR Project Manager, NRC
J E Silberg
State of Minnesota
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Kris Sanda
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