IR 05000282/1998006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-282/98-06 & 50-306/98-06 on 980526.Corrective Actions Will Be Examined During Future Insps

ML20236L204
Person / Time
Site:	Prairie Island
Issue date:	07/02/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
References
50-282-98-06, 50-282-98-6, 50-306-98-06, 50-306-98-6, NUDOCS 9807100264
Download: ML20236L204 (2)

Text

July 2, 1998

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-282/98006(DRS);

50-306/98006(DRS))

Dear Mr. Wadley:

This will acknowledge receipt of your letter dated June 25,1998, in response to our letter dated May 26,1998, transmitting a Notice of Violation associated with work instructions for placing secure tags and an inadequate procedure for electrical system transfer at the Prairie Island Generating Plant. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, i

n A. Grobe, Director ivision of Reactor Safety

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Docket Nos. 50-282; 50-306 License Nos. DPR-42; DPR-60 y

Enclosure:

Ltr dtd 6/25/98 Mr Wadley Prairie Island to USNRC

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Plant Manager, Prairie Island I

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State Liaison Officer, State of Minnesota State Liaison Officer, State I

of Wisconsin Tribal Council Prairie Island Dakota Community DOCUMENT NAME: G:DRS\\PRA98006.TY To receive a copy of this document, indicate in the bor *C" = Copy without attachment / enclosure "E" a Copy wth attachtnenuenclosure "N" = No cooy OFFICE Rill u

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M. Wadley.

Distribution:

CAC (E-Mail)

Project-Mgr'NRR w/shcl C. Paperiello, Rlli w/enci J. Caldwell, Rlli w/ encl B. Clayton, Rill w/ encl SRI Prairie Island w/ encl DRP w/encI TSS w/enci DRS w/enci

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Northtrn statzs Power Company

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Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. E.

Welch, MN 55089 June 25,1998 10 CFR Part 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING STATION Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Response to Notice of Violation (Inspection Report 98006)

Your letter of May 26,1998, which transmitted Inspection Report No. 98006, i

required a response to a Notice of Violation. Our response to the notice is l

contained in the attachment to this letter.

In this response we have made three new NRC commitments as noted by bold italics under Corrective Steps to Avoid Further Violations. If you have any questions

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concerning this response, please contact John Stanton at 612-388-1121 x4083.

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Joel P. Sorensen Plant Manager Prairie Island Nuclear Generating Plant c:

Regional Administrator-lli, NRC NRR Project Manager, NRC Senior Resident inspector, NRC State of Minnesota, Attn: Kris Sanda J. E Silberg Attachment Response to Notice of Violation (Inspection Report 98006)

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Attachment l

l Response to Notice of Violation (Inspection Report 98006)

I Violation 1:

l Criterion V of 10 CFR Part 50, Appendix B, requires, in part, that activities affecting quality shall l

be accomplished in accordance with instructions, procedures, or drawings.

Step 6.10.4.c.2.b of Administrative Work Instruction 3.10.0, " Control and Operations of Plant Equipment," Revision 7, requires that qualified personnel shall check molded case circuit breakers open by " testing dead" when applying a safety tag for the "off" position.

l Contrary to the above, on April 1,1998, the inspectors observed a plant operator hang a secure tag associated with work order 9801216 on the #21 safety injection pump motor control center breaker without performing a dead test as required.

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This is a Severity Level IV violation (Supplement 1).

j Reason for Violation 1:

Background Discussion --- The violation involved a situation not fully covered by the AWI (Administrative Work Instruction). The secure tag associated with work order 9801216 was to be applied to a breaker that was already tagged in the "off" position. It had already been tested " dead" for the other tag. Testing " dead" again would have required a temporary lift of the original card in order to open the motor control center door. It is not desirable to do this and, for this reason, the operators have been trained to not perform a temporary lift but rather to note on the new tag the isolation number of the previous card. The problem illustrated by this violation is that the AWI did not detail the action to take in the event that the breaker had already been tested " dead" and

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rnalntained in that position as evidenced by a safety tag documenting a " dead" test.

Although the operator knew the correct approach to the situation from previous training, this approach could not be supported by the existing AWI.

The cause of this violation was the discrepancy between the intent of the AWI and a strict reading of the words of the AWIin this case where the AWI did not address the situation directly confronted by the operator. The operator proceeded based upon prior training without recognizing the discrepancy between the words of the AWI and the action being taken.

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Violation 1 - Corrective Actions Taken and Results Achieved:

SAWI 3.10.0, " Control and Operation of Plant Equipment" was revised by an Admin Control Document Memorandum that details the action the operator is to take when a currently applied safety tag documents a " tested dead" condition. The instruction now directs the operator to take credit for the previous " dead" test by documenting the isolation number of the previous ccrd on the " Test dead"line of the subsequent card.

Violation 1 - Corrective Steps To Avoid Further Violations:

Instruction 5AWI 3.10.0 is being reviewed to verify that there are not other similarpitfalls, this review will be completed by September 30,1998.

As a short term action, a memo was issued to all plant personnel by the plant manager re-emphasizing procedure adherence concems and the need to initiate procedure changes when the procedure can't or shouldn't be performed as written.

Long term actions regarding improvements in the area of procedure adherence have been initiated in response to earlier problems. These initiatives are considered to be still appropriate to improve procedure adherence performance.

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Violation 1 - Date When Full Compilance Will Be Achieved:

Full compliance has been achieved.

Violation 2:

Criterion V, " Instructions, Procedures, and Drawings," of Appendix B of 10 CFR Part 50 requires in part, that activities affecting quality be prescribed by documented instructions, procedures, or

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drawings, cf a type appropriate to the circumstances.

Temporary memo 1997-0178, initiated October 31,1997, instructed operators to delete Step 5.1.6.H.8 (for 1MA2) and Step 5.3.4.D.5 of procedure 1C20.8," Instrument AC distribution System," Revision 9, until a modification for the transfer capability was completed. Step 5.1.H.8 provided instructions for operators to restore normal Unit 1 power to motor control center 1MA2 if necessary. Step 5.3.4.D.5 provided instructions for operators to transfer the power source

from Unit 2 to Unit 1 for motor control center 1MA2.

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Contrary to the above, the inspectors identified that during the period of November 10,1997, l

and April 7,1998, procedure 1C20.8 did not contain adequate instructions for transferring power sources for motor control center 1MA2 since temporary memo 1997-0178 was still in effect. The modification for the transfer was completed on November 10,1997, and the licensee did not cancel the temporary memo.

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This is a Severity Level IV violation (Supplement 1).

l Reason for Violation 2:

The cause of this event was an inadequate review of the plant operating procedure status associated with the modification prior to tumover for operation and failure to assign an expiration date for the temporary memo consistent with expected completed of the plant modification.

Violation 2 - Corrective Actions Taken and Results Achieved:

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Temporary Memo 1997-0178 was deleted on April 8,1998 such that procedure 1C20.8, q

l correctly identified the transferability of MCC 1MA2.

Violation 2 - Corrective Steps To Avoid Further Violations:

This violation will be reviewed by allpersonnel with plant design change Project Engineer responsibilities to ensure they understand their responsibility associated with

l plant operating procedures when filling out form PINGP 1218, Turnover Checklist.

A new procedure temporary change process has been developed. Training on the new process will be completed forplant staff prior to implementation. The training will review this violation and stress the need to assign expiration dates for temporary changes that

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should be deleted by a specified date, for example, when a plant modification is expected

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The procedure temporary change process will be investigated to determine whether all active temporary memos should be reviewed for continued applicability on a periodic basis.

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Violation 2 - Date When Full Compilance Will Be Achieved:

f Full compliance has been achieved.

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