ML20043A445

Responds to NRC 900319 Ltr Re Violations Noted in Insp Repts 50-282/89-29 & 50-306/89-29.Corrective Actions:Changes Will Be Made to Review & Approval Process for Work Packages

ML20043A445
Person / Time
Site:	Prairie Island
Issue date:	05/09/1990
From:	Larson C NORTHERN STATES POWER CO.
To:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9005220084
Download: ML20043A445 (4)

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Minneapolis, Minnesota $54011927 1 Telephone (612) 330 5500 j (s

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May 9, 1990

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H J Miller, Director ,

i Division of Reactor' Safety Region III

'U S Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 PRAIRIE ISIAND NUCLEAR GENERATING PLANT Docket Nos. 50 282 License Nos. DPR 42  :

50-306 DPR-60 ,

t Response to Notice of Violation .

Inspection Reports No. 50-287/89029(DRS) and 50-306/89029(DRS) ,.

S In response to your letter of March 19, 1990 which transmitted Inspection Reports No. 282/89029 and 306/89029, the following information is offered.

• The 30 day response period was. extended to May 2, 1990 by verbal communication i between Bruce Burgess of your office end Ed Watzl, Prairie Island Plant ,

Manager. Subsequently, the response period for Violation #3 was extended to May 9, 1990 by verbal communication between Sonia Burgess of your office and  ;

. Jack Leveille, Prairic Island Licensing Engineer. We responded to Violations '

1. 1 and #2 in our letter of May 2, 1990. This letter responds to Violation #3, ,

t Viointion #3 -

Section 6.5.G of the Prairie Island Technical Specifications requires

.that temporary changes to Operations Committee reviewed procedures be made with the concurrence of two members of the unit management staff, at least one of whom holds a senior reactor operator license and that the changes be documented and reviewed by the Operations Committee -r within one month, e i

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Northem States Power Company I contrary to the above: j V 1 ,'

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a- Temporary changes were made to preventative maintenance procedure b 3170 1-12,

• Main Steam Isolation Valve CV-31099 Refueling Inspection", without the approval of the Operations Committee.

As a result, work was performed utilizing the changed procedure

[ _ without the required reviews for system and plant impact (282/89029 03A; 306/89029 03A).

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t b. Temporary changes were made to five steps of procedure EP17-76, l " Prairie Island Nuclear Plant #D2 Emergency Generator Electrical i Maintenance,' Revision 5, without the approval of a senior ,

reactor operator or the Operations Committee and changes were made to three additional steps of the procedure without the approval'of the Operations Committee. As a result, work was performed utilizing the changed procedure without.the required reviews for systems and plant impact (282/89029 03B; 306/89029-  ;

03B). i This is a Severity Level IV violation (Supplement 1).

• Response I In order to characterize the nature of this violation and the proposed q corrective _ action, two topics should be discussed: 1) What constitutes +

Operations Committee review and plant manager approval? and 2) When changes to  :

procedures must be approved?

What constitutes Operations Committee review and n1 ant manager approval? i We believe the procedure changes cited above did receive Operations Committee i review by a subcommittee consisting of the Work Request Authorization i Coordinator. As such the Work Request Authorization Coordinator had been ,

designated by the plant manager to review and approve maintenance procedures.  ;

We believe it is important that the Plant Operations Committee be made up of the senior superintendents on the plant staff with the Plant Manager as the

-Chairman. Such an arrangement focuses the responsibility for overall site j safety in the positions that have the control necessary to fulfill the responsibilities. This committee is not able to review all' work requests without some prior screening. We believe that delegating that screening and "

approval responsibility to the Work Request Authorization Coordinator has

• served us well throughout the operating history of the plant.

The Work Request Authorization Coordinator reviewed the procedures and'either approved them or sought additional review if a multi-disciplined review was necessary. This additional review ranged from the review of a technical expert to the entire Operations Committee review. In order to perform this  ;

review, the Work Request Authorization Coordinator needs to have a broad i M

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,' May 9, 1990

' Page~3 Northem States Power Company engineering background. The current Work Request Authorization Coordinator is the Superintendent of Operations Engineering. .who previously held a Senior Reactor Operator license. This individual has the broad engineering experience necessary to perform this review / screening function for the Operations Committee. This additional review has not been a required part of ,

the formal process.

Since_the changes cited in paragraphs a. and b. of the violation did receive ,

the review and approval of the Work Request Authorization Coordinator acting as a subcommittee of the Operations Committee and for the plant manager, we believe these changes were properly reviewed and approved.

When must chances to nrocedures be acoroved?

In the process of preparing work packages, approved procedures may need to be modified. For example, the post maintenance testing may require a surveillance test to be performed. This test may need to be modified in order l

to test the equipment feature that was repaired. The approval of this change is not necessary until an official work package is created by the approval of the Work Request Authorization Coordinator. Changes made to the procedures before this should not be treated as temporary changes to procedures but should be considered part of procedure preparation for the work package and approved when the Work Request Authorization Coordinator reviews the package.

We believe, that the five examples cited in paragraph b of the violation were not temporary changes and did not require approval by a licensed senior reactor operator. The changes were made prior to the Work Request Authorization Coordinator's review. The changes were subsequently reviewed and approved by the Work Request Authorization Coordinator, constituting the Operations Committee's review and the plant manager's approval. We believe no

' corrective action is necessary for this concern.

l Corrective Action Taken and Res:ults Achieved Changes that will be made to our review and approval process are discussed below.

Sorrective Action To Be Taken To Avoid Further Violations After further consideration, we agree with your concern with the one person l review and approval of procedures and procedure changes. In order to broaden I the review for systems and plant impact, we will change the process for reviewing and approving maintenance procedures by June 30, 1990. This new process will apply to procedures required by Technical Specification 6.5.C.

l These procedures will be reviewed by the Superintendent of Operations and the Superintendent of Technical Engineering (or their designees). The approval will be performed by a shift superviscr. These changes will provide a multi-disciplined review of maintenance procedures.

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May.9, 1990

• *E* Northom States Power Company Date Uhen Full Como11ance Will Be Achieved We believe that we are in full compliance.

Please contact us if you have any questions related to our response to the subject inspection reports.

p gpAC - E rson 1: Vice President

[ Nuclear Ceneration t-c; Regional Administrator III, NRC Senior Resident inspector, HRC NRR Project Manager, NRC G Charnoff l

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