ML20127P258
| ML20127P258 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 03/08/1978 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9212020171 | |
| Download: ML20127P258 (3) | |
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NORTHERN STATES POWER COMPANY MIN N E A POU S. MIN N E SOTA 55401 x
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Director of Nuclear Reactor Regulation
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Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PIANT PRAIRIE ISIAND NUCLEAR GENERATING PIANT Docket Nos. 50-263 License Nos. DPR-22 50-282 DPR-42 50-306 DPR-60 OPERATIONAL QUALITY ASSURANCE PLAN IMPIIMENTATION Mr D K Davis's letter dated December 29, 1977, stated that the NSP Quality Assurance Plan, Revision 2, is acceptabic, with one addition regarding radiograph retention.
That letter also stated that if there are any portions of the program which could not be implemented within 90 days of the date of the letter, we should notify the NRC in writing, within 60 days of receipt of the letter, specifying which aspects of the program cannot be impicmented and stating reasons therefore. This letter is to document the portions of the Operational Quality Assurance Plan, Revision 2, which cannot be implemented within 90 days.
NSP has an Operational Quality Assurance Program which is responsive to the require-ments of Appendix B to 10 CFR Part 50.
In a letter dated March 2, 1976 from Mr D L Ziemann of the NRC, it is stated that the NRC is knowledgeable of the fact that past inspections performed by the Office of Inspection and Enforcement of the Operational Quality Assurance Programs both at Monticello and Prairie Island Plants have not indicated any significant weakness in these programs; however, the NRC Staff requires documentation of the managerial and administrative controls contained in the QA Program to be fully confident that the applicable requirements of Appendix B will be satisfied. In response to that request, NSP submitted a description of the Operational Quality Assurance Programs for the Monticello and Prairie Island Plants on June 17, 1976. The Plan provided a description of how the Operational Quality Assurance Program satisfies the requirements of Appendix B,10 CFR Part 50.
As a result of NRC Staff review of the Plan, NSP was asked to make certain revisions to the Plan including commitment to the guidelines contained in a number of ANSI Standards and NRC Regulatory Guides. The Operational Quality Assurance Plan, Revision 2, which was accepted by the NRC by their letter of December 29, 1977, con-tained commitments to fifteen ANSI Standards and the Regulatory Guides applicable to those Standards. Although the Quality Assurance Program implementation to date meets the general requirements of Appendix B,10 CFR Part 50, there are many details in the ANSI Standards and Regulatory Guides (a portion of which has been specifi-cally included in the Plan) which will require a period of time for implementation 9212O20171 780308 ADCCK0500g3 PDR P
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NORTHEMN OTATE3 POWER COMPANY 8-1 Director of Nuclear Reactor Regulation 2
Page 2 March 8, 1978 1
l beyond the 90-day period suggested by the NRC.
Implementation of these details L
will require generation of additional directives and procedures and assignment land l
training of additional-personnel.
In the case of records management, construction
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of appropriate facilities may also be necessary.
1 Incorporation of the requirements contained in the Standards and Guides.will require a detailed review of each Administrative Control Directive, making appropriate changes and reissuing them. We have included this review in our 1978 Review Pro-i gram. In the succeeding year,1979, we will-verify implementation of these revised Directives in our 1979 Audit Program; thus we can assure reasonable compliance-by i
the end of 1979. It should be noted that approximately 210 Administrative Control l
Directives are involved in this review-revision-audit process.
In addition our Operational Quality Assurance personnel have recently reviewed the 3
Operational Quality Assurance Plan with regard to implementation of its provisions.
4 This review revealed that certain areas of the Program need further attention to fully satisfy NSP's concerns. The majority of these areas of concern are minor in nature and easily corrected.
The more significant areas of concern include:
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Section 3.3 Items 1, 2, 3 & 4 j
Directive requirements associated with In Service Inspection (ISI) and Non-j Destructive Examination (NDE) need to be implemented by issuance of appropriate i
Instructions. Directives associated with ISI need to be revised. Preparation of Instructions which implement ISI & NDE requirements have been scheduled for prepara-i tion in 1978. Revision of Directives associated with ISI have been incorporated j
into the 1978 QA Review Program.
Section 3.6.2 The responsibilities assigned to the Manager, Maintenance & Testing have not been fully implemented. A concerted effort is being made by management and quality-assurance personnel to expedite full implementation.
Section 3.12.1 Items 1. 2. 3 & 4 The requirements associated with Special Processes and Inservice Inspection require further attention. Preparation of appropriate Instruction and Directive revisions
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j-has been scheduled for 1978.
Referenced Administrative Control Directive 4
4 Seven of the General Office Administrative Control Directives referenced in the Plan have not been prepared.
Preparation of these Directives has been scheduled-for 1978.
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NORTHEMN OTATEO POWER COMPANY Director of Nuclear Reactor Regulation Page 3 l
March 8, 1978 t
Correction of the deficiencies identified by our quality assurance personnel, in-cluding the above items, is expected to be fully bnplemented by the end of 1979.
In retrospect NSP recognized the need for documentation of the Operational Quality Assurance Program early in 1974 to include extended coverage of the off-site NSP organization. At that time NSP quality assurance personnel discussed our plans with NRC I&E personnel regarding the content of a Company-wide Operational Quality Assurance Progrt:m and the schedule for implementing such s program. It was concluded that full implementation could not be expected in less than five years and such a schedule was acceptable provided a number of areas of special concern were imple-l mented expeditiously. It was pointed out to NRC personnel at that time that we could and would take care of these areas of special concern immediately but that f
an effective and orderly program could not be developed on a " fire-fighting" basis j
and that after these areas of special concern were satisfied further development of the program would proceed on an orderly scheduled basis. We have adhered to this verbal conniement.
We plan to continue this orderly process of preparing the necessary Directives, implementing the Directive requirements, and verifying implementation by audit.
A-new element has now been introduced; i.e.,
revising Directives to incorporate pro-visions of Standards and Guides. We do not feel this will be a major problem since
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the changes for the most part are minor but it will take more than 90 days.
l-We reiterate that those elements of the Operational Quality Assurance Program that i
are necessary to assure the safety and operations of the Monticello and Prairie Island Nuclear Plants have been implemented.
The individual plants and the General Office Operational Quality Assurance group are ready to discuss our implementation plans in more detail with the Region III I&E personnel during future site or General Office visits.
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W' i
L 0 Mayer, PE Manager of Nuclear Support Services 1.
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