ML20081L786
| ML20081L786 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 03/24/1995 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9503310002 | |
| Download: ML20081L786 (4) | |
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i Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello. Minnesota 55362-9637 l
March 24,1995 i
10 CFR Pad 2 Section 2.201 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 Ucense No. DPR-22 Reply to Notice of Violation Contained in NRC Inspection Report No. 50-263/94014 Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the notice of violation contained in your letter of February 23,1995 is provided as Attachment A.
This letter does not contain any new commitments to the NRC, nor does it modify any existing NRC commitments. Please contact Mary Engen, Sr Licensing Engineer, at (612) 295-1291 if you require further information.
//. u". /kff W J Hill Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator-I!!, NRC NRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn: Kris Sanda J Silberg
Attachment:
A - Reply to Notice of Violation
^10010 9503310002 950324 ii PDR ADOCK 05000263 1
Q PDR l
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Attachment A REPLY TO NOTICE OF VIOLATIOli VIOLATION 10 CFR Part 50, Appendix B, Critenon Xill requiredin part that measures shall be established to control the handling, storage, and preservation of matenal and equipment in accordance with work andinspection instructions to prevent damage and detenoration. Steps 6.3.3.1 and 6.3.3.2.f of Matenal Control Procedure N1ACD 6.3 requires, in part, that switchgear be classified as Level B and provided with measures to protect them from physical damage, airbome contamination, gravitational forces, humidity and vapor, and the effects of temperature extremes.
I Contrary to the above, from October 3,1994 and for an extended period thereafter, two safety related 4160 V breakers (i.e., switchgear) were stored on the 911 foot elevation of the turbine building in an area not designated as a Level B storage area. Measures formaterial control of these breakers to protect them from physicaldamage, airbome contamination, gravitational forces, humidity and vapor, and the effects of temperature extremes had not been established.
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This is a Saverity levelIV violation (Supplement I).
NSP Response:
NSP acknowledges the above violation.
Reason for the Violation:
NRC Inspection Report 50-263/92013, dated November 9,1992 contained a notice of violation for a level IV violation conceming two 4160-volt safety-related breakers which were stored in an uncontrolled location for an extended period of time contrary to plant procedures and 10 CFR 50, Appendix B, Criterinn Xill and Criterion V. The cause of this earlier violation was a personnel error consisting of a failure to follow plant material control procedures resulting in storage of the breakers in an inappropriate location (the breaker rebuild shop, adjacent to the turbine building). To resolve this issue, the spare 4160-volt breakers were stored in the plant warehouse, outside of the plant protected area.
Subsequent to relocation of the 4160-volt breaker storage location to the plant warehouse, Operations, Maintenance, and Engineering personnel identified concems with this storage location. The storage of the breakers outside of the plant protected area necessitated increased handling and transport when a spare breaker was needed in the plant. This resulted i
in a greater potential for damage to the 1200 pound breakers during transportation, the spare i
breakers were less readily available should a replacement breaker be needed, and increased resources were necessary to obtain a spare breaker.
Plant engineering reviewed the material control requirements and identified an in-plant storage location which, to the reviewers knowledge and full understanding, met the necessary requirements for Level B storage. The in-plant storage locations are in the Turbine Building.
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i Attachment A Page 2 March 24,1995
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I The Turbine Build;ng provides a fire resistant, weathertight, ventilated enclosure which provides the necessary protection from airbome contaminants, humidity and vapor, and temperature extremes. The storage location was selected such that it was out of the normal traffic pattems to preclude the potential for physical damage. The normal security controls in place for the Turbine Building protected the breakers from vandalism. Chocking of the breakers would prevent them from rolling into adjacent structures and components, and the breakers would be covered to prevent intemal contamination. As a point of clarification, this new storage location is separate and distinct from the location for which the notice of violation was received in 1992.
i Following the 1994 refueling outage and completion of breaker refurbishment work, two spare safety-related 4160-volt breakers were stored at the Turbine Building in-plant storage location I
to resolve the concems related to storage of the breakers in the plant warehouse. An enclosure was scheduled to be installed around the storage locations to enhance the physical protection for the safety-related 4160-volt breakers. Prior to completion of the storage location enclosures, an independent review was conducted of the material control requirements. This independent review determined that the enclosures should have been in place prior to use of the in-plant location for Level B material storage. This is required in order to provide controlled and limited access in accordance with our corporate administrative control directives for implementation of ANSI N45.2.21972. A differing interpretation of the capability of the in-plant storage location to meet this requirement without the enclosures installed was the reason for this violation.
Corrective Action Taken and Results Achieved:
Enclosures have been built in the Turbine Building to provide long term storage of the spare safety-related 4160-volt breakers. These enclosures provide the necessary barrier to ensure access to the spare breakers is limited to authorized personnel.
Corrective Action to be Taken to Avoid Further Violation:
No Further corrective action is required.
Date when Full Compliance Will Be Achieved:
Full compliance has been achieved.
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. TRANSMITTAL MANIFEST NORTHERN STATES POWER COMPANY NUCLEAR LICENSING DEPARTMENT
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MONTICELLO NUCLEAR GENERATING PLANT Bag!!y to Notice of Violation Contained in NRC Inspechon Report No 50-263/94014 Correspondence Date: March 24,1995 Monticello intemal Site Distribution Special Instructions Kaleen Hilsenhoff......USAR File.................Yes
- No_x_.
Steve Ludders..........NRC Commitment.....Yes No_x_
Lila imholte..............Monti OC Sec..........Yes_x_ No
- 11, No dist to OC members below if YES
- Mel Opstad............. Monti SAC Sec..........Yes_x_ No
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' Mail Room........... Monti Posting............Yes_x_ No -
-7 Monticello intamal Site Distribution:
- Monti Document Control File J C Grubb, NGSS, OC W J Hill, Plant MGR,' SAC, OC L L Nolan, GSSA, OC C A Schibonski, GSE, OC -
B D Day, MGR MTC, OC M F Hammer, GSM, OC Operating Experience Coord J E Windschill, GSRS, OC W A Shamla, NQD M W Onnen, GSO, OC Monti Site Lic File Steve Engelke Steve Ray, SR Res insp, NRC
' Jack Nystrom Monticello Training Center Library Lou Brehm NSP Intemal Distribution E L Watzi R O Anderson, Dir LMI, SAC Mike Wadley, Pl T E Amundson, Dir NQD, SAC A A Hunstad Communications Dept Yes_x_ No Extemal NSP Distribution
&& 6'8mCM Kris Sanda, State of Minn Regional Admin-lli,NRC J E Silberg Beth Wetzel, NRR PM, NRC
- Advance Distribution made by Site Licensing Manifest Date: March 27,1995