L-PI-05-059, Reply to Non-Cited Violation 05000306-05-003-02

Reply to Non-Cited Violation 05000306-05-003-02

ML051650049
Person / Time
Site:	Prairie Island
Issue date:	06/13/2005
From:	Solymossy J Nuclear Management Co
To:	Document Control Desk, NRC/RGN-III
References
IR-05-003, L-PI-05-059
Download: ML051650049 (2)

Text

Prairie Island Nuclear Generatina Plant Operated by Nuclear Management Company, LLC L-PI-05-059 10 CFR 50.36 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 [72-101 License Nos. DPR-42 and DPR-60 [SNM-25061

SUBJECT:

Nuclear Management Company Prairie Island Unit Nos. 1 & 2; Docket Nos. 05000282 and 05000306 Reply to Non-Cited Violation 05000306/2005003-02

REFERENCE:

(a) Letter from Mr David Passehl, Nuclear Regulatory Commission, to Mr. Joseph Solymossy, Nuclear Management Company, dated April 28,2005, Nuclear Management Company - NRC, Integrated lnspection Report 05000282/2005003; 05000306/2005003 This letter requests reassessment of the Human Performance aspect of Non-Cited Violation 2005003-02. The inspection report states that "The inspectors determined that the finding impacted the cross-cutting area of Human Performance (organization) because the licensee's management organization failed to carefully assess the situation regarding TS compliance."

This observation was not discussed with NMC at, or subsequent to, the Inspection exit.

Accordingly, NMC is now providing additional information to show that compliance with Technical Specifications, specifically exiting TS 3.0.3, was discussed among, and carefully evaluated by, NMC management at various levels. We emphasize that NMC1s commitment to safety and Technical Specification compliance was at the time, and remains today, our highest priority.

To clarify, the organizational decision-making that occurred prior to the decision to exit TS 3.0.3 was based on a formal Operability Recommendation (OPR-533). (The OPR, using the guidance of Generic Letter 91-18, concluded that "FCU 21 is capable of providing sufficient heat removal capacity for one train of containment with the compensatory measures of FCU 23 isolated and inlet water temperature no greater than 650F1').The OPR received careful scrutiny by PlNGP plant staff and management.

The OPR was reviewed not only for technical adequacy, but also for assuring that nuclear safety and compliance with Technical Specifications were maintained and assured. A "Challenge Board" (a multi-disciplined group of NMC nuclear professionals) was assembled for the purpose of "drilling-down" into the OPR's conclusions. The Challenge Board concluded that application of the OPR was appropriate. Additionally,

Document Control Desk Page 2 management discussions were held between senior site management and NMC executives and other managers not assigned to PINGP. The licensing and compliance rationale and bases for exiting TS 3.0.3 were assessed by these operational and licensing professionals and they concluded that by implementing the OPR and exiting TS 3.0.3, nuclear safety as well as compliance with Technical Specifications would be maintained.

We recognize that technical disagreements and differences of opinion can (and do) occur among experienced individuals. However, the existence of a disagreement does not constitute a shortcoming in the full and careful assessment of a situation. The above information was not presented to the Resident Inspectors since NMC was not aware that the NRC had concerns with NMC's decision-making process for this issue. As a result, the full story of organizational engagement and challenges that took place was most probably not known or available for consideration during the NRC's Inspection Report development and review process. Based on the facts surrounding NMC1s decision-making process as stated above, NMC respectfully requests re-characterization of the Non-Cited Violation as not impacting the cross-cutting area of Human Performance (organization).

Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.

I?

Nuclear Generating Plant Enclosure (1) cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC