ML20147B412
| ML20147B412 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/27/1997 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9701310324 | |
| Download: ML20147B412 (5) | |
Text
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Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 Januar/ 27,1997 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. 50-233/96008 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 27,1996, is provided in Attachment A.
Attachment A, Reply to Notice of Violation, contains the following three new NRC commitments:
The lessons teamed from the water in the fire hydrant barrel event will be covered in future j
operations and maintenance supervisor training.
The Section XI program will be changed to require identification of approved relief requests in affected plant procedures.
Training will be given to the technical staff on expectations for maintaining formal calculations.
Please contact Sam Shirey, Sr Licensing Engineer, (612-295-1449) if you require further information.
f)v'Y/bb f~4 William J Hill Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator Ill, NRC NRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn'. Kris Sanda J Silberg 310055 pgo/ '/
Attachments A - Reply to Notice of Violation 1/27/97 SIS K\\TEAAn004500MognLMAVKEW3006R1. OOC 9701310324 970127 PDR ADOCK 05000263 G
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i Attachment A i
REPLY TO NOTICE OF VIOLATION Violation 10 CFR Part 50, Appendix B, Critedon XI, " Test Control," stated in part that a test program shall be established to assure testing is performed in accordance with written test procedures i
which incorporate the requirements and acceptance limits ccntainedin design documents.
Test results shall be documented and evaluated to assure test requirements have been satisfied.
Contrary to the above:
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On October 11 and 12,1996, a plant operator documented an incorrect standby liquid control tank lewIin surveillance 0090, ' Standby Uquid Control System Checl<s." The documented values exceeded the acceptance criteda and were 1
not identified during subsequent review by operations shift management.
i b.
In May and September 1996, a mechanic performed test 0319, " Fire Protection i
System - Yord Hydrant inspection," and documented that several feet of water was left in the #1 fire hydrant barrel. The acceptable condition was stated in test 0319 was less than 2 inches of standing waterin the hydrant banel. Also,
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operations shift management and the system engineer did not identify the May
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1996 unacceptable test results.
c.
On Febmary 10,1994, the license rovised surveillance test 0085, ' Standby
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Liquid Control System Operability Test " Revision 20 using an unapproved j
calculation to determine flow rate and did not recognize that the revised calculation differed from the IST commitments.
NSP Response to Example a NSP acknowledges example 'a' cited in the above Notice of Violation.
Reason For Violation:
This was a cognitivo personal error. The cperator failed to verify that surveillance test data was within prescribed acceptance band. Subsequent surveillance test review by operations shift management failed to identify the out of specification condition.
The out of specification reading was identified by the NRC Resident inspector during review of operations and surveillance tests.
1 A cornparison of operations logs and surveillance tests revealed an acceptance band conflict between this surveillance test and the operators daily round sheet. This conflict contributed to the operator error.
i 1127 4 7 SIS X\\TEAMOO4500 MOW MnvlOLs0008R1 DOC 1
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Attachm:nt A j
Page 2 January 27,1997 i
i Corrective Action Taken and Results Achieved:
The Standby Liquid Control Storage Tank level was verified to be within soecification. The
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operator was interviewed and a determination made that the level indicator was misread. The j
surveillance test data sheet was corrected to reflect the actual value.
1 Previous and subsequent day surveillance test data sheets were reviewed to determine if similar errors had occurred. It was discovered that the subsequent day reading was also
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i misread and out of specification. This error was made by the same individual. However, this I
was the current day test data sheet and had not yet been reviewed by operations shift management. This reading was also corrected to reflect actual value.
Corrective Action to be Taken to Avoid Further Violations:
l This error was evaluated in the facility's condition report ng system. THa process ensured i
i that root and contributing causes were identified and corrective acti-
. prevent recurrence I
were developed.
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Communications within the operations department in the form of shift seminars were
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completed. The details of this error, the need for attention to detail, procedural requirements for the indentification and communication of out of specification readings, and management expectations were stressed to all personnel. The conflict between the two operations documents was corrected.
l' Date When Full Compliance Will Be Achieved l
l Full compliance has been achieved.
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NSP Response to Example b l
NSP acknowledges example 'b' cited in the above Notice of Violation. This example was also identified by NSP as documented in Monticello License Event Report (LER)96-009.
i Reason For Violation:
in both the May and September test, the mechanic performing the test notified the system engineer rather than the shift supervisor. The procedure required the shift supervisor to be l
notified. The system engineer determined that the wet hydrant was still operable during non-freezing weather conditions. This decision was technically correct, but not in conformance with the Technical Specifications. Maintenance and operations review of the completed surveillance procedure did not identify a problem with this decision in May. In September, l
operation's review identified that a wet hydrant is inoperable any time of year per the wording in the Technical Specifications,
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l Atttchmtnt A l
Page 3 i
January 27,1997 f
Corrective Action Taken and Results Achieved:
i The hydrant was declared inoperable until the water was pumped out and a work order repaired the hydrant.
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. The personnel involved in this event are now aware that, when water is found in yard fire hydrant barrels, prompt shift supervisor notification is required and that prompt actions are
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required to comply with Technical Specifications.
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Corrective Action to be Taken to Avoid Further Violations:
3 I-This event and the lessons teamed from this event was covered in engineering technical staff training. The lessons teamed from this event will be covered in future operations and j.
mc!ntenance supervisor training.
i Date When Full Compliance Will Be Achieved J
l Full compliance has been achieved.
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i NSP Response to Example c
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NSP acknowledges example 'c' cited in the above Notice of Violation. During the monthly operability test of the Standby Liquid Control pumps, the NRC resident inspector observed j
that the test procedure being used had testing parameters different from what had been j
approved by the NRC. The discrepancy was brought to the attention of the system engineer l
cn 10/16/96.
Reason For Violation:
l At the beginning of the third ten year period for ASME Section XI, a number of relief requests were submitted to the NRC for approval. One of the relief requests submitted to the NRC was for flow testing the SBLC pumps based on the rate of change of tank level during pump -
operation. The relief request was required because there is no direct means of measuring pump flow. This relief request, PR-1 was approved by the NRC on 7/6/93. Procedure 0255-02-111 was not revised at this time to reference the relief request.
Subsequently, the system engineer questioned the derivation of the calculation that determines flow rates of the Standby Liquid Control pumps and found that manufacturer tolerances were used to calculate the volumetric capacity of the SBLC Test Retum Tank, T-201. In an attempt to improve the accuracy of the flow test results, field measurements of the tank dimensions were made and the pump flow calculation was revised. The system engineer was unaware of relief request PR-1, which specified the use of the original formula.
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Attrchm nt A Page 4 January 27,1997 Corrective Action Taken and Results Achieved:
An evaluation was made to verify that all SBLC pump tests that had used the unapproved flow conversion factor showed satisfactory results using the approved flow conversion factor, The root cause of the violation was the failure to recognize the bases of the flow formula constant. No reference was given to identify the relief request in procedure 0255-02-Ill. This process error would have been avoided had the procedure identified the formula as being associated wita relief request PR-1.
i The procedure was revised (revision 23) with a note stating that "The pump flow rate formula Is from IST Program relief request, PR-1*, and the flow constant calculated by the relief i
request approved formula was reinstated into the procedure. This formula provides conservative pumping rates to evaluate pump performance.
The only other relief request similar to PR-1 is PR-8 which specifies the formula to be used to calculate the suction pressure for the safety related service water pumps. These Implementing tests were verified to match PR-8.
Corrective Action to be Taken to Avoid Further Violations:
The Section XI program will be changed to require identification of approved relief requests in affected plant procedures. This action would have prevented the occurrence of this oversight.
Training will be given to the technical staff on expectations for maintaining formal calculations.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.