ML20196J723

Discusses Insp Rept 50-282/97-08 & 50-306/97-08 on 970414- 0613 & Forwards Notice of Violation & Imposition of Civil Penalty in Amount of $50,000

ML20196J723
Person / Time
Site:	Prairie Island
Issue date:	10/16/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
Shared Package
ML20196J727	List: ML20196J723 ML20196J734
References
50-282-97-08, 50-282-97-8, 50-306-97-08, 50-306-97-8, EA-97-290, NUDOCS 9812110004
Download: ML20196J723 (4)

See also: IR 05000282/1997008

Text

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1. 1. % UNITED STATES

.o 4 NUCLEAR REOULATORY COMMISSION

_

I I E REGION til

IE 801 WARRENVILLE ROAD

USLE. ILUNOIS 60532-4351

October 16, 1997

' EA 97-290

Mr. M. D. Wadley.

Vice President, Nuclear Generation

Northem States Power Company

414 Nicollet Mall '

Minneapolis, MN 55401

. SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil

PENALTY - $50,000 (NRC INSPECTION REPORT 50-282/306-97008(DRS))

Dear Mr. Wadley:

This refers to the System Operational Perfonnance inspechon conducted from

April 14 to June 13,1997, at your Prairie Island Nuclear Generating Plant. The inspection

team assessed the auxiliary feedwater (AFW) system operational performance during a

detailed review of the design, maintenance, operation, and surveillance testing of the AFW

system. The report was issued by letter dated July 16,1997, and a predecisional

enforcement conference was held in the Region lll office on August 8,1997.

Based on the information developed during this inspection and the information that your staff

provided during the predecisional enforcement conference, the NRC has determined that

four violations of NRC requirements occurred. The violations are cited in the enclosed

Notice of Violation and Proposed imposition of Civil Penalty (Notice) and the circumstances

surrounding each violation are desuibed in the subject inspection report. The violations

concem Prairie Island staffs failure to implement a test program that ensured that the AFW

system would meet its design expectations inservice and failure to understand and maintain

aspects of the AFW system design. Further, these or similar issues were known to the

Prairie Island staff but not adequately corrected.

The first issue concemed the Prairie Island staffs failure to establish an inservice Test (IST)

procedure acceptance criteria that would ensure the AFW system met certain design basis

requirements. The site engineering staff developed the acceptance criteria for the AFW IST

procedure using Section XI of the American Society of Mechanical Engineers code.

However, the engineering staff never compared the acceptance criteria with the design

requirements for the AFW system. As a result, the IST procedure would permit an AFW

. pump to be considered operable even though it had degraded below minimum design {

requirements. ' Although the potential existed for the operability of the AFW system to be  ;

compromised, members of the engineering staff confirmed that none of the AFW pumps had l

degraded below minimum system design requirements.. In addition, your engineering staff  ;

' identified, in 1991, a similar failure to establish IST procedure acceptance criteria for the  !

safety injection pump design basis requirements. The engineering staff did not take prompt '

corrective action and identify thct this problem also existed in the AFW system testing

program. In our view, if your staff had implemented broader corrective action, it is likely this

violation would not have occurred. '

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9912110004 971016 '- u

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PDR ADOCK 05000282

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M. Wadley -2-

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The second issue concemed the Prairie Island staff's failure to analyze a discrepancy ,

between the Updated Safety Analysis Report (USAR) and anticipated AFW flows. The l

Prairie Island engineering staff failed to maintain the USAR when discrepancies in the  !

published flow requirements for the AFW system were identified during a 1992 AFW design

basis reconstitution effort. Although your engineering staff recognized that the USAR value

was incorrect, your staff failed to resolve the discrepancy or update the USAR. These

violations collectively represented a failure to maintain the design basis for the AFW system

and assure the system would perform satisfactory in service, and have been classified in the

aggregate in accordance with the NUREG-1600, " General Statement of Policy and

,

Procedure for NRC Enforcement Actions"(Enforcement Policy), as a Severity Level 111

problem. l

Individually and collectively the safety significance of the violations was low since the AFW

system always met the design basis requirements. However, the regulatory significance was

, high because: (1) your existing administrative processes and barriers failed to ensure that

IST acceptance criteria considered the design basis requirements; (2) the engineering staff

failed to appreciate the need to maintain the fidelity of the USAR; and (3) the engineering

' staff failed to implement timely and comprehensive corrective actions when they identified

test program deficienciet, and AFW flow discrepancies.

1

'

According to the Enforcement Policy, a base civil penalty for $50,000 is considered for a

Severity Level lli problem occurring before November 12,1996. Since most of the l

noncompliance period occurred before Novemoer 12,1996, a base civil penalty of $50,000

was considered for this case. Because your facility has been the subject of escalated

enforcement actions within the last two years,' the NRC considered whether credit was

warranted for Identification and Corrective Action according to the civil penalty assessment

process in Section VI.B.2 of the Enforcement Policy. Identification credit was not warranted

because these violations were identified by the NRC or plant staff identified the problem but

failed to recognize the significance until prompted by the NRC. However, Corrective Action

credit was warranted based on the corrective actions that have been implemented or were

proposed at the enforcement conference. Several of your corrective actions included:

(1) a verification of the correct flow rate to the intact steam generator and a resultant revision

to the USAR; (2) a review of the design change program and a review of sample calculations

for accuracy; (3) a revision to the acceptance criteria for the AFW pumps and training to the

technical staff on the need to maintain the design basis; (4) an evaluation of the Section XI

program and the acceptance criteria to ensure that the design basis is not compromised;

(5) a review of the outstanding corrective action items for regulatory significance and

2

prioritization; and (6) a bench marking of the condition reporting system with industry

standards.

,

1. EA 97 073 issued a severtty Level ill violation with no dvil penalty on April 30.1997 for the failure to comply with heavy loads

requirements during the movement of a heavy load over a fully fueled reactor vessel EA 96-402 issueo a severity Level til

violation with a $50.000 civil penalty on January 23,1997, for an unreviewed safety question that was created by the licensee when

they look credit for the non-seismic intake canal and operator actions following an earthquake.

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M. Wadley -3-

!

Therefore, to emphasize the importance of an IST program that ensures the design basis of

plant systems is not compromised, the need to perform timely evaluations when USAR

discrepancies are identified, and the need to maintain the fidelity of the USAR, I have been

authorized, after consultation with the Director, Office of Enforcement, to issue the enclosed

i Notice of Violation and Proposed imposition of Civil Penalty in the base amount of $50,000

for this Severity Level lli problem. l

i

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. According to 10 CFR 2.790 of the NRC's " Rules of Practice," a

copy of this letter, its enclosure, and your response will be placed in the NRC Public

Document Room (PDR).

Sincerely,

-

'

A. Bill Beach

Regional Administrator

Docket Nos. 50-282 and 50-306

License Nos. DPR-42 and DPR-60

l Enclosure: Notice of Violation and Proposed l

imposition of Civil Penalty

cc w/ encl: Plant Manager, Prairie Island

State Liaison Officer, State

of Minnesota

State Liaison Officer, State ,

of Wisconsin  ;

Tribal Council

Prairie Island Dakota Community

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M. Wadley -4

DISTRIBUTION:

PUBLICM

SECY

CA

LCallan, EDO -

AThadani, DEDE

LChandler, OGC

l JGoldberg, OGC

l SCollins, NRR

!

_ RZimmerman, NRR

Enforcement Coordinators

l Rl, Rll and RIV

L Resident inspector, Prairie Island

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JHannon, NRR

BWetzel, NRR

JGilliland, OPA

I HBell, OlG

! _ GCaputo, Ol

TMartin, AEOD

OE:ES

OE:EA (2)

GJohnson, OC/DAF

i- RAO: Rill

SLO: Rill

PAO: Rill

OC/LFDCB

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DRP-

Docket File

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