ML20149F297
| 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: |
| 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
Text
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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)
1
Dear Mr. Wadley:
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
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well performed and that your engineering staff was considered knowledgeable end
conscientious. However, the results of the SOPl raised concerns about the rigor of
certain aspects of engineering, particularly with verification of the design basis
performance of safety-related pumps through an effective surveillance program. Concern
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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
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have failed to identify potentially degraded equipment (AFW Pumps) or to prompt
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appropriate corrective actions.
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. 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
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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
9707220135 970716
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M. D. Wadley
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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
design control issues.
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M. D. Wadley
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July 16, 1997
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
the existing analysis demonstrated a low margin to the thyroid dose limit and the effects
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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,
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its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
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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:
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2. Inspection Report 50-282/97008(DRS); 50-306/97008(DRS)
cc w!encis:
Plant Manager, Prairie Island
John W. Ferman, Ph.D.,
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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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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
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"C" = Copy w/o attachment / enclosure
"E" = Copy with attachment /enclostk
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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
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,
its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
Sincerely,
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John A. Grobe, Acting Director
Division of Roactor Safety
Docket Nos. 50-282;50-306;72-10
Enclosures:
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2. Inspection Reports 50-282/97008(DRS); 50-306/97008(DRS)
cc w/encis:
Plant Manager, Prairie Island
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John W. Ferman, Ph.D.,
Nuclear Engineer, MPCA
State Liaison Officer, State
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State Liaison Officer, State
of Wisconsin
Tribal Council, Prairie Island
Dakota Community
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DOCUMENT NAME: G:\\DRS\\PRA97008.DRS
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attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy
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