ML20100C057
| ML20100C057 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/26/1996 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9601300019 | |
| Download: ML20100C057 (7) | |
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Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 January 26,1996 10 CFR Part 2 Section 2.201 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Reply to Notice of Violation Contained in NRC Inspection Report No. 50-263/95011 Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the notice of violation contained in your letter of December 28,1995, is provided as Attachment A. Information concoming the issues identified in the notice of violation has been provided to the NRC via Monticello Licensee Event Report (LER)95-007, submitted by letter dated November 13,1995, and during a pre-decisional enforcement conference held at the NRC Region ill offK:es on December 15,1995. Our response to the notice of violation provides a summary of this previously provided information as well as the specific information requested in the notice of violation.
NSP has previously committed to completion of the actions below as reported in LER 95-007.
This letter modifies these previously committed to actions by providing completion dates for the actions.
1.
Training will be provided to all personnel involved in the valve line-up process on:
- this event,
- self checking,
- the importance of proper valve position,
- the purpose of having locked valves, and
- the importance of independent verification.
This training will be completed by March 30,1996.
2.
The following processes are being evaluated for possible improvements-
- valve line-up (checklists) process (including signature transfers),
- independent verification process, 300004
-locked valve proc ss, and the
- hold and secure card process.
1/25/96 NSP JADO4560NoNTILMI\\VloLVR95011. DOC 9601300019 960126 PDR ADOCK 05000263 1}
G PDR m
- USNRC NORTHERN STATES POWER COMPANY
. JInurry 26,1996 Page 2 -
Changes proposed for the hold and secure process, as a result of this evaluabon will be implemented by February 29,1996.
Any cnbcal changes that are identfied for the valve lineHp, independent venfication and locked valve processes will be implemented before the upcoming refuehng outage, scheduled to start April 10,1996 3.
The process of conduchng refuehng outages has been evaluated for possible improvement in the area of Opersbons staff work load near the end of the outage.
In addition, an evaluabon has been performed on the integrabon of system restorations into outage achvities. Proposed changes will be reviewed and will be implemented i,efore the upcoming refueling outage, scheduled to start April 10, 1996. The changes will be evaluated following the outage for possible improvements. This schon will be completed by September 30,1996.
Please contact Marv Engen, Sr Licensing Engineer, at (612) 295-1291 if you require further information.
/Ad/I4 5
William J Hill Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator-lil, NRC NRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn: Kris Sanda J Silberg Attachments: Affidavit to the US Nuclear Regulatory Commission l
A - Reply to Notice of Violation
UNITED STATES NUCLEAR REGULATORY COMMISSION NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 Reply to Notice of Violation Contained in NRC Inspection Report No. 50-263/95011 Northem States Power Company, a Minnesota corporation, hereby provides the required response to the Notice of Violation associated with NRC inspection Report 50-263/95011. The Notice of Violation was transmitted to NSP via a letter from Hubert J Miller, NRC Region ill Regional Administrator, to Mr. E Watzl, Northem States Power Company, on December 28, 1995.
This letter contains no restricted or other defense information.
NORTHERN STATES POWER COMPANY By /MIMd A
William J Hill '
Plant Manager Monticello Nuclear Generating Plant On this 2(oO day of ' Tex ^ ius e v I cf 9 (o before me a notary public in and for said County, personally appeared William J Hill, Plant Manager, Monticello Nuclear Generating Plant, and being first duly swom acknowledged that he is authorized to execute this document on behalf of Northem States Power Company, that he knows the contents thereof, and that to the best of his knowledge, information, and belief the statements made in it are true and that it is not interposed for delay.
MARVIN CHARD ff4 Marvin R Engen
[
- *
- MMR Notary Public-Minhesota
- *
- h "e M Sherbume County My Commission Expires January 31,2000 1/25516 NSP J:004500WoNTILMlWloLVR95011. doc
Attachment A Reolv to a Notice of Violation Violations identified in 12/28/95 NRC Letter Violation A:
'A. Technical Specification 3.5.C.1 required that both Containment Spray / Cooling Subsystems shall be operable whenentirradiated fuelis in the reactor nssel and the reactorwateris greaterthan 212*F. A Containment Spray 2ooling Subsystem includes the valves necessary forDrywell Spray Technical Speci5 cation 3.5.C.4 provided that one Containment Spraymooling Subsystem may be inoperable for 7 days.
Technical Specification 3.5.C.5 required, in part, that if the requirements of 3.5.C.1 and 4 cannot be met, an orderly shutdown of the reactor will be initiated and the reactor water temperature shall be reduced to less than 212*F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above:
1.
From 9:55 a.m. on October 3,1995, until 5:53 p.m. on October 5,1995, while inadiated fuel was in the reactor vessel and the reactor water was greater than 212*F, both Containment Spray 200 ling Subsystems were Inoperable, a period greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and.sction was not taken to initiate an orderly shutdown of the reactor and to reduce reactor water temperature to less than 212*F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
2.
From October 23,1994, until December 17,1994, and from December 21, 1994, until October 12,1995, the 'B' Containment Spraymooling Subsystem was inoperable, periods greater than 7 days, and action was not taken to initiate an orderfy shutdown of the reactor and to reduce reactor water temperature to less than 212*F within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
Violation B:
'B.10 CFR 50, Appendix B, Critedon V, " Instructions, Procedures, and Drawings,* requires that activities affecting quality shall 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.
1.
Residual Heat Removal System Prestart Valn Checklist No. 2154-12, Revision 29, Step 1, required operators to walk down tha system and place valves in tho properposition required by the valve checklist. Step 3 required operators to perform an independent verification of the checklist and note discrepancies in the comments section.
4 AttachmentA Page 2 January 26,1996 Contrary to the abon, the Residual Heat Removal System Prestart Valw Checidist completed on October 21,1994, documented that vein PHR-74-2 was locked open, when in thect, it was urdocked closed, and no dacropencies were notedin the comments sechon.
2.
Adninistratin Work Instruction No. 4 awl-04.04.01,
- Equipment isolation,'
Revision 8, Step 4.8.12.C.2, required the ShlR Supervisorto direct the required independent wri6 cation to be pertbrmed and documented on the Isolation Worksheet or on Form 3063-1 ifpermanently clearing setiety tags. Step 4.12.6 required an independent wrMcation of posiboning and relocking oflocked equipment to M ;,;steting status.
Contrary to t Mcw, in October 1994, the StdM Manager, whne helming the duties of the,niR Superdsor, did not direct an independent wri6cetion tboowing 1
a permanent clear of saliety tags associated with Isolation Worksheet 94-80312 lbrnormallylocked open vain RHR 74-2.
l This is a Severity Lent til Problem (Supplement I)."
NSP Response NSP acknowledges the above violations.
On October 12,1995, while at 100 percent power, a plant equipment operator found the "B" i
residual heat removal (RHR) drywell spray manual isolation valve (RHR 74-2) unlocked and closed with a hold card attached to it. ' The valve had been mispositioned since retuming to power from the last refueling outage on October 23,1994. This violates the Monticello Technical Specifications, since this train of drywell spray was inoperable for more than 7 days, during a period when operability was required. During the penod of mispositioning of RHR 74-2, the "A" drywell spray system had been taken out of service for 56 hours6.481481e-4 days <br />0.0156 hours <br />9.259259e-5 weeks <br />2.1308e-5 months <br /> to perform on-line maintenance in eariy October 1995. This also violates the Monticello Technical Specifications, since both trains of drywell spray were inoperable at the same time.
I Reasons For Violations:
I A combination of inattention to detail and procedural weakness resulted in the examples identified in Violation B. The RHR Prestart Valve Checklist was incorrectly completed in October 1994 documenting RHR 74-2 as being locked open when, in fact, it was closed and unlocked. This error occurred even though operators had completed a walk down of the system including independent verification. The Shift Manager subsequently exhibited a lack of questioning attitude when confronted with the conflicting information between the Prestart Valve Checklist and Isolation Worksheet for RHR 74-2. As a result, it is believed that the Isolation Worksheet was closed without direct verification of the valve position. The Operations staff workload at the end of the refueling outage may have contributed to this error.
The reason that the plant Technical Specifications were not trmt as identified in Violabon A, is that the valve was not known to be mispositioned until October 12,1995, approximately one
Attachment A Page 3 January 26,1996 year after the valve is believed to have been mispositioned. The reasons that the valve was mispositioned are as stated above.
Additional informatum can be found in Licensee Event Report (LER)95-007, dated November 13,1995.
Correchve Achon Taken and Results Achieved:
The following schons have been taken to avoid further violations associated with Violations A and B:
1.
The hold card was removed from RHR 74-2 on October 12,1995, and the valve was opened and locked in the open position.
2.
AN locked valves outsede the inerted dryweN have been venfied to be locked in their proper posebon 3.
AN Emergency Core Coohng System (ECCS) valves outside the inerted dryweN have been verified to be in their proper posibon.
l 4.
All cntical locked valves inside the drywell were determined to be in the proper position by indication or by correct system operation to date.
5.
All on-line maintenance was tempc,;arily halted unless specsfically authorized by I
the plant manager, initially, there was a concem associated wd' h the temporary lift process for Hold cards during on-line maintenance. The investigation identified no process problems associated with the temporary lift process and on-line maintenance. A process improvement to the temporary lift process has been implemented. Based on these findings, the on-line maintenance temporary halt has been removed.
6.
The locked valve checkhst has been changed to remove the high radiabon exempbon for RHR 74-2. The quarterly locked valve surveil!ance was a rra== fully completed on au locked valves outside the drywell on December 17,1995.
7.
Management has addressed the improper clamaa"t of the isolabon associated with the hold card found on RHR 74-2 with the entre Opersbons staff. The following issues were emphasized
- the importance of maintaining a questioning athtude,
- follow the procedural processes, and
- the 'urguisce of self-checiong 8.
Quality Services personnel has changed their audit plans and win penodecally i
observe a sampling of Prestart Valve Checkhsts. The quarterly kded valve surveillance, conducted on December 17,1995, was observed by Quality Services personnel. No problems were observed.
Attachment A
~
Page 4 January 26,1996 l
i Corrective Action to be Taken to Avoid Further VW-H~1s-t i
The following schons wiH be taken to avoid further violations. NSP has previously committed i
to completion of these actions as reported in LER 95 007, submitted by letter dated November l
13,1995. These actions are restated herein for completeness and to provide a status concoming completion.
i l
1.
Training wil be provided to al personnel involved in thw valve line-up process on:
i
- this event, i
- self checking,
- the importance of proper valve position,
- the purpose of having locked valves, and
- the importance of independent verificabon.
l Appic4T "i 75% of the involved personnel have been traned Training wiu be l
completed by March 30,1996.
1 2.
The iciiv#, rig processes are bem0 evaluated for possible 'Tvic;;T. erd.:
1
- valve kne up (checkhsts) process (including signature transfers),
-indepsndent verificabon process,
-locked valve process, and the
- hold and secure card process.
The hold and secure process has been evaluated Chan0es proposed, as a result
{
of this evalumbon have been reviewed by Operations personnel and these changes i
will be implemented by February 29,1996.
co.T.T-r :: have been idenwied for the other three processes and any enbcal changes that are identfied win be implemented before the upcoming refuebng outage, scheduled to start April 10,1996.
3.
The process of conduchng refuehng outages has been evaluated for possible improvement in the area of Operabons staff work load near the end of the outage.
in addition, an evaluabon has been performed on the integrabon of system restorabons into outage activities.
The Scheduling depa 1 ment has reviewed this event and proposed several changes to lower the work load on the Operabons staff at the end of the outage. These changes are being reviewed and wiu be implemented before the upcoming refueling outage, scheduled to start April 10,1996. The changes win be evaluated following the outage for possible improvements This schon wiu be coiT(:::j by September 30,1996.
Date when Full Comoliance WiH Be Achieved:
Full compliance has been achieved.
.