ML20149F297

Forwards Insp Repts 50-282/97-08 & 50-306/97-08 on 970414- 0613 & Notice of Violation

ML20149F297
Person / Time
Site:	Prairie Island
Issue date:	07/16/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
Shared Package
ML20149F300	List: ML20149F297 ML20149F312 ML20149F319
References
50-282-97-08, 50-282-97-8, 50-306-97-08, 50-306-97-8, EA-97-290, NUDOCS 9707220135
Download: ML20149F297 (4)

See also: IR 05000282/1997008

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July 16, 1997

EA 97-290

Mr. M. D. Wadley

Vice President, Nuclear Generation

Northern States Power Company

414 Nicollet Mall

Minneapolis, MN 55401

SUBJECT: NRC INSPECTION REPORT 50-282/97008(DRS); 50-306/97008(DRS)

AND NOTICE OF VIOLATION

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Dear Mr. Wadley:

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On June 13,1997, the NRC completed a System Operational Performance Inspection

(SOPI) at your Prairie Island Nuclear Generating Plant. The inspection team assessed the

auxiliary feedwater (AFW), and portions of the control room ventilation and safeguards

chilled water systems' operational performance by a detailed review of the design,

maintenance, operation, and surveillance testing of the systems. The enclosed report

presents the results of that inspection.

The inspectors identified that, with exceptions, maintenance and operations were being )

well performed and that your engineering staff was considered knowledgeable end

conscientious. However, the results of the SOPl raised concerns about the rigor of i

certain aspects of engineering, particularly with verification of the design basis l

performance of safety-related pumps through an effective surveillance program. Concern .

was also raised by observations that your Updated Safety Analysis Report (USAR) was not  !

being maintained current. Additional concern was generated because corrective actions

for prior identification of these issues were not timely. The existing controls appeared to j

have failed to identify potentially degraded equipment (AFW Pumps) or to prompt

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appropriate corrective actions.

. Based on the results of this inspection, apparent violations were identified and are being

considered for escalated enforcement action in accordance with the " General Statement of

Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

The apparent violations include failure of your test controls to incorporate test criteria

necessary to assure verification that AFW pumps could meet design requirements.- In

addition, apparent violations of corrective actions were noted by your failure to complete

actions identified in 1991 that may likely have identified the AFW pump test criteria

problem, as well as failure to take timely corrective action on inaccurate AFW flowrates in

the USAR. Apparent violations of 10 CFR 50.71, " Maintenance of records, making of

reports," and of 10 CFR 50.9, " Completeness and accuracy of information," were also

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identified for failure to correct the inaccurate USAR AFW flowrate. Further, apparent

violations of 10 CFR 50.72, "Immediate Notification Requirements for Operating 'l

Reactors," 10 CFR 50.73, " Licensee Event Report System," and 10 CFR 50.59, " Changes,

Tests and Experiments," were identified for failure to report that the plant was outside its

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9707220135 970716

PDR ADOCK 05000282

PDR

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M. D. Wadley 2 July 16, 1997

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design basis when it was determined that the main feedwater line rupture analysis used a

higher AFW flow value than the pumps could deliver, and for your subsequent failure to

verify via a safety evaluation that no unreviewed safety question existed. It is of particular

concern that your staff had various opportunities to maintain the USAR current with

respect to this issue during 1993 and 1995, but this did not occur.

Accordingly, no Notice of Violation is presently being issued for these inspection findings.

In addition, please be advised that the number and characterization of apparent violations

described in the enclosed inspection report may change as a result of further NRC review.

A predecisional enforcement conference to discuss these apparent violations has been

scheduled for August 1,1997. This conference will be open to public observation. The

decision to hoU a predecisional enforcement conference does not mean that the NRC has

v 4termined that a violation has occurred or that enforcement action will be taken. This

e anference is being held to obtain information to enable the NRC to make an enforcement

decision, such as a common understanding of the facts, root causes, missed opportunities

to identify the apparent violation sooner, corrective actions, significance of the issues and

the need for lasting and effective corrective action, in particular, we expect you to

address the continued operability of the systems we reviewed and any other affected

systems and, the failures of your corrective action process.

In addition, this is an opportunity for you to point out any errors in our inspection report

and for you to provide any information concerning your perspectives on (1) the severity of

the violation (s), (2) the application of the factors that the NRC considers when it

determines the amount of a civil penalty that may be assessed in accordance with

Section VI.B.2 of the Enforcement Policy, and (3) any other application of the Enforcement

Policy to this case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on this

matter. No response regarding the(se) apparent violation (s) is required at this time.

In addition, the NRC has determined that violations of NRC requirements occurred. These

violations are cited in the enclosed Notice of Violation (Notice) and the circumstances

surrounding them are described in detailin the subject inspection report. The violations

are of concern because they represent a lack of rigor and controlin the calculation

verification program and, for the cable tray separation issue, represent another example of

untimely and non-comprehensive corrective action for earlier-identified design issues.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part,

to determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements. Additionally, please be prepared to discuss the design control

violation during the pre-decisional enforcement conference, including the reason for the

violation (or basis for disputing it), and corrective action taken or planned to avoid similar  !

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design control issues.

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M. D. Wadley 3 July 16, 1997

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Finally, you are also requested to respond in writing on any planned actions, including timo

frames, for re-performing the control room habitability dose calculations and any plans to  !

test the control room isolation dampers for verification of the inteakage assumption as

discussed in Section E1.4 of this report. This issue was of concern to the NRC because

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, the existing analysis demonstrated a low margin to the thyroid dose limit and the effects '

of higher than assumed unfiltered inleakage could place the plant outside of the regulatory

limit.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, j

its enclosures, and your response will be placed in the NRC Public Document Room (PDR). l

Sincerely,

/s/ J. M. Jacobson (for)

John A. Grobe, Acting Director

Division of Reactor Safety

• Docket Nos. 50-282;50-306;72-10

Licenses No. DPR-42; DPR460

, Enclosures: 1. Notice of Violation  !

! 2. Inspection Report 50-282/97008(DRS); 50-306/97008(DRS)

cc w!encis: Plant Manager, Prairie Island  !

John W. Ferman, Ph.D., i

Nuclear Engineer, MPCA

State Liaison Officer, State  !

of Minnesota

State Liaison Officer, State i

of Wisconsin

Tribal Council, Prairie Island

Dakota Community

Distribution:

/encls SRis, Prairie Island, TSS w/encls

Docket File w%/encls

PMBLIC.lE-01 Monticello w/encls CAA1 w/encls

OC/LFDCB w/encls LPM, NRR w/encls DOCDESK w/encls  !

DRP w/encls A. B. Beach, Rlli w/encls J. Lieberman, OE w/encls

DRS w/encls J. L. Caldwell, Rlll w/encls J. Goldberg, OGC w/encls

Rlli PRR w/encls Rlli Enf. Coordinator w/encls R. Zimmerman, NRR w/encls

SEE ATTACHED CONCURRENCES

DOCUMENT NAME: G:\DRS\PRA97008.DRS

To receive a copy of thle document, Indicate in the box: "C" = Copy w/o attachment / enclosure "E" = Copy with attachment /enclostk "N" o copy

OFFICE Rill:DRS l Rill:DRS ,lE Rlll:DRP l Rlll:EICS l R$)lgjiirf \ l

NAME Guzman/lc/jp/kjc Rin N Mc-Barger Clayton JAobyn7()tobe

DATE 07/ /97 07//'//97 07/ /97 07/ /97 q7/g/R7/

OFFICIAL RECORD COPY U

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M. D. Wadley 3

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Finally, you are also requested to respond in writing on any planned actions, including time

frames, for re-performing the control room habitability dose calculations and any plans to

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test the control room isolation dampers for verification of the inleakage assumption as

discussed in Section E1.4 of this report. This issue was of concern to the NRC because

the existing analysis demonstrated a low margin to the thyroid dose limit and the effects

of higher than assumed unfiltered infeakage could place the plant outside of the regulatory

limit.

I

in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, i

its enclosures, and your response will be placed in the NRC Public Document Room (PDR). I

1

Sincerely,

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l John A. Grobe, Acting Director i

Division of Roactor Safety l

Docket Nos. 50-282;50-306;72-10

Licenses No. DPR-42; DPR-60

j Enclosures: 1. Notice of Violation

2. Inspection Reports 50-282/97008(DRS); 50-306/97008(DRS)

. cc w/encis: Plant Manager, Prairie Island

John W. Ferman, Ph.D.,

Nuclear Engineer, MPCA

'

State Liaison Officer, State

of Minnesota

State Liaison Officer, State

of Wisconsin

Tribal Council, Prairie Island

,

Dakota Community

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!

$ DOCUMENT NAME: G:\DRS\PRA97008.DRS

To receive a copy of this document, indicate in the box: "C" = Copy without

attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy

OFFICE Rlli 6 Rill Rlll pr Rlli Rlli

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NAME uzyn MRing BClayt l JGrobe

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DATE b O7/3/97 07/ /97 07/J /97 t7/cy/97 07/ /97

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