ML19242D425

Responds to NRC 790215 Ltr Re Violations Noted in IE Insp Repts 50-282/79-01 & 50-306/79-01.Corrective Actions:General Review of Methods Undertaken to Assure Prompt Identification of Deficiencies & Subsequent Corrections

ML19242D425
Person / Time
Site:	Prairie Island
Issue date:	05/31/1979
From:	Wachter L NORTHERN STATES POWER CO.
To:	Heishman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19242D416	List: ML19242D425
References
NUDOCS 7908150090
Download: ML19242D425 (4)

Text

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NSP NORTHERN STATES POWER COMPANY u iN N E A po te s. M O N N E SOTA 55401 May 31, 1979 Mr. R. 1. Heishnan, Chief

-, Reactor Operations and Nuclear Support Eranch Region III United States Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Heishman:

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

Infraction Criterion XVI of A; andix E to 10 CFR 50 requires that " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective caterial and equipment and nonconforcances are proeptly 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.

Supplemental Response A general review of methods used to assure co=pletion of corrective actions associated with conditions adverse to quality shows that improvecents are justified. Corrective Action Reports, procurement deficiencies, nonc onfo rmances , etc., are controlled by the QA Group to assure correctier.

Procedure changes, procedure deviations, Reportable Occurrence recommended actions, etc., are controlled by the Operations Committee review process.

Other corrective actions, such as those required by citations, IE Bulletins, IE Circulars, etc., need a better systee for assuring corrections are taken and a new tracking method has been L:ple=ented. This systet will include the documentation of the review process.

As additional conditions are identified requiring control measures to assure prompt identification and correction, they will be included as part of this system.

LS -15 7 908150.6 Q O Q

. NORTHERN STATES POWER COMPANY Mr. R. F. Heishman May 31, 1979 Page 2 .

Criterion X of Appendi> B to 10 CFF, 50 states in part, "A program for inspection of activities affecting quality shall be established and executed. . . ."

.NSP's letter of March 8,1978, to the Director of NRR regarding

" Operational Quality Assurance Plan Implementar4 n" indicates ACD's would be reviewed and revised in 1978 and the t=pl,aentation of the revised Directives would be verified in the 1979 Audit Program.

Contrary to the above, while some inspec tion requirements; i.e., in-service 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 Adcinistrative Work Instructions.

Surelerental Response The specific Prairie Island Directives and Work Instructions presently utilized to implement inspection r.ctivities are defined below:

SArD 3.2, Rev. 7 - Work Recuest I.7 ) and Work Request Authorization (WRA)

This Directive establishes responsibilities and require =ents to ensure inspection activities are properly addressed, revieved, and icplemented.

The WRA Coordinator, in his review, ensures inspection instructions are on KRA's and that provisions for documentation of work per, forced, caterials and parts used, instruments used, testing, and inspection performed are made. Syster Engineers are responsible to identify inspection requirements on WRA's and ensure their completion. SWI-PERP-2, Rev. O, Work Request Authorization Instruction, addresses hold points and independent in;pection. Test Supervisors or assigned engineers are directed to sign the WRA form when inspections are specified.

SACD 7.1, Rev. 3, vrocurenent Process Receipt and inspection requirecents and respensibilities are defined in this Directive for caterial procured for use at Prairie Island.

SACD 9.2, Rev 0, control of Electrical Penetrations /Openines and Cable Runs This Directive describes the requirements and responsibilities for visual inspection of penetration seals. SP-1192, Safeguards Electrical 6 Mechanical Penetration Inspection, addresses the routine inspection requirements.

Special requirements are specified in SACD 9.2.

(y8NN

NORTHERN STATES POWER COMPANY

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Mr. R. F. Heishman May 31, 1979 Page 3 5ACD 10.1. Rev. O, s antrol of Radioactivity This Directive describes the necessary independent verification required by the Shift Supervisor and the Superintendent - Radiation Protection for

_ gaseous and liquid releases.

SACD 12.1, Rev. O, Nuclear Fuel _ Control This Directive describes the necessary independent verification requirecent conduc ted by the QA Group, Shift Supervisor or Nuclear Engineer of the completed core pattern after a fuel shuffle.

SACD 13.1. Rev. O. Radioactive Material Packacine This Directive describes the verification required by the Superintendent -

Radiation Protection on all shipments of radioactive material fror Prairie Island.

Several other directives and instructions address inspection requirements associated with special processes. They include:

5ACD 14.1, Rev. O, Welding Procedure Control 5ACD 14 3, Rev. O, Nondestructive Examination SACD 14.4, Rev. O, Welding Inspection SWI-PERP-9, Rev. O, Preparation of Welding Instructions Other inspection and/or verification activities presently conducted at Prairie Island are not properly addressed in the Plant Directives. A review of the directives is required, and it is anticipated that the following directives need attention:

SACD 1.4, Rev. 4, Plant Operatien Manual SACD 3.9, Rev. 3, Bypass Control 5ACD 3.10, Rev. 2, Equipment Control Procedures SACD 3.12, Rev. O, Preventive Maintenance SACD 6.1, Rev. 5, Design Change Control 5ACD 6.2, Rev. 3, Design Change Installation Procedures SACD 6.3, Rev. 3, Design Change Implementation SACD 6.4, Rev. 2, Design Change Preoperational/ Operational Testing SACD 8.1, Rev. 2, Receiving Process SACD 9.3, Rev. O, Electrical Preventative Maintenance Additional inspection and/or verification Duple =enting requirements may need to be addressed in Section Work Instructions.

f390 ' ~

. NORTHERN STATES POWER COMPANY Mr. R. F. Heishman 1

May 31, 1979 Page 4 ..

The review will require a considerable manpower expenditure. This is expected to be completed with revisions by September 30, ?.9'/9.

Also, a Power Production Directive addressing Inspection is expected to

-be implemented soon. The plant may require a reevaluation of its inspection program when this ACD is issued.

Yours very truly, M

L. . Wachter Vice President Power Production and System Operation cc; Mr. G. Charnoff GS7D18