IR 05000282/1978012

IE Inspec Repts 50-282/78-12 & 50-306/78-13 on 780905-08, 11-14,20-22 & 25-29 During Which 1 Item of Noncompliance Was Noted:Failure to Follow an Implementing Procedure for Approved QA Prog

ML20062F615
Person / Time
Site:	Prairie Island
Issue date:	11/06/1978
From:	Feierabend C, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20062F607	List: IR 05000282/1978012 ML20062F603 ML20062F608
References
50-282-78-12, 50-306-78-13, NUDOCS 7812200099
Download: ML20062F615 (5)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION III

Report No. 50-282/78-12; 50-306/78-13 Docket No. 50-282; 50-306 License No. DPR-42; DPR-60 Licensee: Northern States Power Co=pany 414 Nicollet Mall Minneapolis, M'i 55401 Facility Nace: Prairie Island Nuclear Generating Plant, Units 1 and i Inspection At: Prairie Island Site, Red Wing, MN Inspection Conducted: Septetber 5-8, 11-14, 20-22 and 25-29, 1978 Rf(2.) fe-Inspector: C. D. Feierabend // g; /S

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RFLOA Approved By: R. F. Varnick, Chief _//36._76>

Reactor Projects Section 2 In_sp_ection Summary Inspection on September 5-8, 11-14, 20-22 and 25-29, 1978 (Report No. 50-262/78-12; 50-306/76-13)

Areas Insyected: Routine, unannounced inspection of plant operation, emergency procedures, design changes and followup on nonroutine event The inspection involved 78 inspector-hours onsite by one NRC inspecto ,Results: Of the four areas inspected, no iters of nonco=pliance or deviations were found in three areas. One item of noncompliance was found in one area (deficiency - f ailure to follow an implecenting proceduce for the approved QA progra: - Paragraph 6.c).

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78122.0009$

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DETAILS 1. Persons contacted

• F. Tierney, Plant Manager

• E. Watzl, Superintendent, Plant Engineering and Radiation Protection

• A. liunstad, Staff Engineer

' Lindsay, Operations Supervisor J. Nelson, Maintenance Supervisor J. lief fman, Plant Engineer, Technical D. Crague, Shift Supervisor Ryan, Shift Supervisor Leville, Quality Assurance Engineer Silvers, Quality Assurance Engineer Stenroos, Assistant Radiation Protection Supervisor Miller, Engineer brown, Engineer liaugland Engineer Warren, Of fice Supervisor

• Denotes those present at the exit in t e rvie . _ Plant Operations The inspector reviewed plant operations including examination of selected operating logs, special orders, temporary memos, jumper and tagout logs for the period August I through September 15, 197 No areas of conflict with Technical Specifications or NRC regulations were identifie . Plant Tours The inspector walked through the varicus areas of the plant to observe operations and activities in progress; to inspect the status of conitoring instruments, to observe for adherence to radiation controls and fire protection rules, to check proper alignment of selected valves and equipment controls, and to review status of various alarmed annunciators with operator No items of concern were identifie Licensee Event Reports (LER's)

The inspector reviewed the following LER's submitted by the licensee, determined that reporting requirements had been met, and that corrective actions appeared appropriat (Closed)

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. P-RO-78-14 - Diesel Generator Day Tank Level Instrument Valve Close P-RD-78-15 - Beric Acid Tank Level Channels Inoperative, Unit P-RO-78-17 - Instrument Drift. Low Pressurizer Pressure and Lo Lo Steam Line Pressure, Unit P-RO-78-18 - Lightning Strike Caused Loss of Two Sources of Offsite Powe . Emergency Procedures The inspector reviewed the licensee's e=ergency procedures relating to operator actions prior to and af ter actuation of Saf ety Injection System (FIS) reset. The licensee had determined that canual restart of RHR pumps vould be needed for any SIS actuation after SIS reset had been setuate?. Emergency procedures for SIS initiation were revised on October 3, 1978 to add this caution to operator . Design Changes Procedure

' ; sign changes are controlled by corporate Power Production Directives 3ACD 4.1, Revision 4, Design Change Control, dated October 12,1977 and 3ACD 4.2, Revision 1 Design Change Installation Procedure, dated March 14, 1975. Review of the procedures and discussions with licensee personnel indicated that there was some lace of clarity in definitions and review assign =ent Revision of 3ACD 4.1 was in progress, and a draft of the revisions had baen provided to the plant staff for review and comment. Feview of the draft showed some improve-ments in control of *ssignments and requirement for earlier completion of updating plant records affected by changes. The inspactor provided some verbal comments to plant and corporate personnel, Status Review of the status of design changes over two years old showed that many were not yet co=plet Discussiens with several engineers and manage =ent personnel indicated that a backlog had existed in drawing and document revision, but-3-

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that recer.t improvement in processing was starting to reduce the backlog. This area had also been identified by the licen-see's QA audits and corrective actions were in progres c. Control The Superintendent of Plant Engineering and Radiation Protection (PERP) has been assigned responsibility for control of all design changes. These include:

(1) Perforcing a safety revie (2) Assigning a number to th( Design Chang (3) Identifying a Responsible Organizatio (4) Assigning a ce=ber of the plant staff to act as the Project Coordinator for each Design Change if the Responsible Organization is other than the plant staf (5) Approving the Design Change prior to installation, with the exception that installation may proceed providing that Design Change approval is obtained prior to declaring the related system (u) operable and that appropriate holds are establishe (6) Verifying that Design Change docu=entation is cc plete prior to declaring the Design Change co=plet (7) Maintaining an index of the Design Change (6) Reviewing the status of all Design Changes once each six month (9) Identifying reviewers for the following areas:

(a) Independent review (b) Overall review (c) Security review (d) Fire protection review In addition, the Superintendent PERP designates a member of his staff to act as Responsible Engineer for all design changes where the plant staff is designated Responsible Organization or to act as Project Coordinator for changes that involve a corporate departcent as Responsible Organi:ation. He also main-tains the index and record file of completed design change L-

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Review of implementation of controls identified some areas that j need improvemen (1) The index maintained by the Superintendent PERP did not identify status of the design change as required by Paragraph 6.1.2 of 3ACD 4.1, Revision i (2) There was no apparent method for reassigning design changes i

when the assigned Responsible Engineer was no longer avail-abic to complete the design change packag ;

(3) Review of the status of all design changes each six months was by informal memorandu= to each Responsible Engineer asking status of assigned design changes, how-ever, progress toward completion was not evident on many of the changes that were over two years old. Many of ,

the older design changes were apparently not safety related, t but the index and controls did not clearly differentiate between safety and non-safety related change Omission of the status of the design changes is considered to be failure to follow Paragraph 6.1.2 of 3ACD 4.1, Revision 4, which is the approved implementing procedure for the licensee's

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Operational Quality Assurance Plan.

j Records

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Completed design change packages were filed by the Superintendent PERP. No deficiencies were identified in the content of records '

reviewed, however, the area of storage procedures, storage facil-

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ities and access cgptrols for QA records as described in previous ,

inspection reporte- remains unresolve . Exit Int e rview i The inspector met with licensee representatives (denoted in Para-i graph 1) at the conclusion of the inspection. The inspector-summarized the scope and findings of the inspection.

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$ 1/ IE Inspection Report Nos. 050-282/77-12; 306/77-08 and 050-282/78-11;  ;

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306/78-12.

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