ML20127K473
| ML20127K473 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 02/07/1975 |
| From: | Wachter L NORTHERN STATES POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20127K451 | List: |
| References | |
| NUDOCS 9211200413 | |
| Download: ML20127K473 (3) | |
Text
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NORTHERN STATES POWER COMPANY Minneapolis, Minnesota 55401 February 7, '.975 Mr. J. G. Teppler, Director Region III Office of Inspection and Enforcement United States Nuclear Regulatory Comission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
lDNTICELLO NUCLEAR GENERATING PIAhT Docket No. 50-263 License No. DPR-22 This letter is submitted in reply to the two apparent violations of AEC requirements identified as items A and B under Enforcement Action in the Summary of Findings section of R0 Inspection Report No. 050-263/74-10. A copy of these items is attached for your reference.
Response to Item A.
The teittporary bypass line around the 102 valve for CRD 46-27 was installed in early June, 1974 Since that time a number of changes to Administrative Control Directives and administrative forms have been incorporated, The Work Request Authoritation (WRA) forms, which are used to initiate, authorite and control work such as the bypass line installation, were revised in late June,1974. The plant directive governing the processing and use of the WRA forms was revised in July, 1974. All of the plant Directives related to design changes, including ACD-7.1, were superseded by Power Production Department directives in November, 1974. These changes include the addition of a blank on the WRA forms which must be signed by the Superintendent of Plant Engineering and Radiation Protection before work involving a design change is allowed to commence. This provides a means for assuring that proper review and approvals are obtained prior to opera-tion of safety-related design changes.
The RO Inspection Report refers in several places to " Approval" by the Operations Commit tee. As a point of clarification, it should be noted that the Committee is only required to reviev and make recommendations; approval is a management function.
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FF8 1 2.1975
2 Response to Item B.
In January, 1975, Administrative Control Directive 4 ACD-4.8, Bypass Control, was revised to incorporate the use of a Jumper Bypass Form. The form has clearly identified spaces for each required signature or initial, including those required to docinent independent verification.
Instructions are printed on the back of the form. The problem has been discussed with the Shift Super-visors.
It is believed that these measures will minimize the probability of a recurrence.
Yours very truly, h
c/M L. J. Kachter Vice President - Power Production and System Operation cc: hfr E. G. Case htr G Charnoff
}!innesota Pollution Control Agency Attn: Fir. E A Pryzina Assistant Director for Construction and Operations attac1 rent i
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SU! MARY OF FINDINGS Enforce..cnt Action i
The following violations are considered to be of Category II severity.
A.
Criterien V, 10 CFR 50, Appendix B, states in part, that "Activitics l
af fecting quality shall be prescribed by documented instructions, procedures.
. and shall be accomplished in accordance with the instructions, procedures.
." The-licensec's procedure ACD7.1 l
has the following requirements:
1.
Paragraph 6.10 states:
"If a Design Change is determined to require safety review, the Operations Committee shall review
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the Design Change Control Form; Preliminary Design Change Package and the Safety Evaluation to assure that thcy are a
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correct and complete.
If they are not, they shall be returned 4
I to the responsibic person or organir.ation for revision of completion."
2.
Paragraph 6.13 states:
"The Operations Committee may recommend changes in the design or request additional analysis and information. The.0perations Committee shall recommend approval j
or rejection of the change."
Contrary to the above the licensee completed and declared operational a design change bef ore it was approved by the Operations Committee.
j The design change was the addition of a bypass valve around CRD-102 valve..(Management Interview, Item G and Section II Report Details, l
Paragraph 4)
B.
Criterion V, 10 CFR 50, Appendix B,-states in part, that "Activitics i
affecting quality shall be prescribed.hy documented instructions,-
. and shall be accomplished in accordance with procedures.
i instructions, procedures.
." The licensee's Administrative Control Directive-(ACD) 4.8, Bypass Control, Section 6.7.1 requires, j
"All bypasses installed for other reasonr. than trouhic shooting or procedures shall have an independent verification of the installation and removal." Section 6.7.2 requires, "When a bypass is used in a procedure, the system or component shall be verified to be in the desired condition by an independent person upon completion of the procedure." Section 6.7.5 requires, "Independet.t verification shall be documented in the Bypass and Jumper 1.og Book."
Cont rary to the above, independent verification was not recorded in-the Bypass and Jumper Log when lifting wires to-transfer control-l.
logic from "C" to "il" Steam 1:ellef Valve per Work Itequent Authoriz-ation 74-1764 and when clearing of a jumper for a special test of "H" relief valve on November 21, 1974.
(Management Interview, Item D.3.(a) and Sect ion I, Report Details, Paragraph 4.C. (3)).-
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