ML20059F460

Notice of Violation from Insp on 931206-22.Violation Noted:Procedure 2D8,rev 3 Was Not Appropriate to Circumstances Re Safety Injection Sys

ML20059F460
Person / Time
Site:	Prairie Island
Issue date:	01/05/1994
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059F451	List: IR 05000306/1993021 ML20059F449 ML20059F460
References
50-306-93-21, NUDOCS 9401140036
Download: ML20059F460 (3)

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i NOTICE OF VIOLATION Northern States Power Company Docket No. 50-306 Prairie Island Unit 2 License No. DPR-60 During an NRC inspection conducted on December 6 through 22, 1993, four violations of NRC requirements were identified. In accordance with the .

" General Statement of Policy and Procedure for NRC Enforcement Actions," i 10 CFR Part 2, Appendix C, the violations are listed below:  !

1. Criterion V of 10 CFp. 50, Apper. dix B requires that activities affecting 1 quality be prescribed by documented instructions, procedures, or ,

drawings, of a type appropriate to the circumstances and shall be  !

accomplished in accordance with these instructions, procedures, or-drawings. Establishing and maintaining the integrity of the reactor ,

coolant system (RCS) pressure boundary are activities affecting quality.

Contrary to the above, Procedure 2D8, Revision 3, " Filling and Venting the Reactor Coolant System," which identifies specific valves that must be isolated before proceeding with filling and venting the reactor coolant system, via Procedure Checklist D8-2, " Reactor Coolant System i Filling and Venting System Prestart Checklist," was not appropriate to i the circumstances of its use, in that it omitted PCS pressure boundary .

motor-operated valve MV-32208. This omission contributed to the overpressurization of safety injection system piping that occurred on December 1, 1993.

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

2. Section 3.8. A.1 of the Technical Specifications requires, in part, that during core alterations, "The equipment hatch and at least one door in -

each personnel air lock shall be closed. In addition, at least one isolation valve shall be operable or locked closed in each line which ,

penetrates the containment and provides a direct path from containment i atmosphere to the outside."

Contrary ta the above, on November 23, 1993, core alterations commenced  !

when a direct path from the containment atmosphere to the outside (in this case the Auxiliary Building) existed through penetration No. 38B ,

because valve MV-32150 was open.

This is a Severity Level IV Violation (Supplement I).

3. Criterion V of 10 CFR 50, Appendix B requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or i drawings. Containment boundary equipment isolation is an activity affecting quality. Section 6.6.3 of Administrative Work Instruction >

3.10.3, "Use of NSP Safety Tags," states that when performing an 9401140036 DR 940105 ADOCK 05000306' PDR

Notice of Violation 2 equipment isolation, " Operators or other authorized plant personnel shall place switches, valves, etc. in the required position, complete and install the safety tags."

Contrary to the above, on November 17, 1993, an operator installed safety tags on motor-operated valves MV-32387, MV-32150, and MV-32156, when they were containment boundary components, per work request U2156-ZC-Q, without placing the valves in the required position.

This is a Severity Level IV Violation (Supplement I).

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4. Criterion V of 10 CFR 50, Appendix B requires that activities affecting quality be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or i drawings. Containment boundary equipment position verification is an activity affecting quality.

Contrary to the above, Procedure C19.9, Revision 0, " Inventory and Refueling Integrity Boundary Control," which requires independent verification of the isolation status for each Containment Building penetration via Procedure Checklist C19.9-2, " Inventory and Refueling Integrity Containment Boundary Checklist - Unit 2," was not appropriate to the circumstances of its use in that it did not require independent verification of isolation status for penetrations controlled with an alternate isolation. This omission contributed to the failure to establish refueling integrity conditions prior to initiating' core alterations on November 23, 1993.

This is a Severity Level IV Violation (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Northern States Power Company is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTH: Document Control Desk, Washington, D.C.

20555 with a copy to the Regional Administrater, Region III, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30. days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for the violation (1) the reason for the 1

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Notice of Violation 3 i

violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not--  ;

received within the time specified in this Notice, an order or a Demand for  :

Information may be issued to show cause why the license should not be modified. ' ided, or revoked, or why such other action as may be proper should n 'en. Where good cause is shown, consideration will be given i to extenu, response time.

1 Dated at Lisle, Illin thisjf}Aay ofY}patu

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