ML20196J734

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Violation Noted:Since 910531 Until 970424,test Program Failed to Assure That Written Test Procedures Incorporate 200 Gallons Per Minute Limit

ML20196J734
Person / Time
Site:	Prairie Island
Issue date:	10/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196J727	List: ML20196J723 ML20196J734
References
EA-97-290, NUDOCS 9812110006
Download: ML20196J734 (4)

Text

- . .- . . . - . . - - - - - - .- ..... - - - - - - . _ - .. - _ . .

4 i 4

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Northem States Power Company Docket Nos. 50-282 and 50-306 Prairie Island Nuclear Generating Plant Licenses No. DPR-42 and DPR-60 EA 97-290 During an NRC inspection from April 14 to June 13,1997, four violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),  ;

42 U.S.C. 2262, and 10 CFR 2.205. The particular violations and associated civil penalty l are set forth below:  !

1. 10 CFR Part 50, Appendix B, Criterion XI," Test Control," requires, in part, t,' tat a test program shall be established to assure that all testing required to demonstrate that l systems will perform satisfactorily in service is identified and perfonned in i

accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents.

Updated Safety Analysis Report (USAR) at Section 11.9.3.a. " Loss of Main Feedwater Transients" documented that during a loss of offsite power transient a single Auxiliary Feedwater (AFW) pump will provide sufficient flow to prevent water relief from the pressurizer relief valves. USAR Table 11.9-2, " Summary of ,

Assumptions used in the AFW System Design Verification Analysis," stated that the minimum required AFW flow during a loss of offsite power transient was 200 gallons per minute to a steam generator.

Contrary to the above, since at least May 31,1991, and continuing until April 24, 1997, the test program failed to assure that written test procedures incorporated the

! 200 gallons per minute acceptance limits contained in Section 11.9.3.a of the USAR; l

the applicable design documents. Specifically, the acceptance criteria for the Unit 1 and Unit 2 monthly and refueling outage AFW surveillance tests listed below would have permitted the AFW pumps to degrade below (and remain operable) the minimum flow - 200 gallons per minute - to a steam generator during a loss of offsite power transient. (01013)

SP 1103,"11 Turbine-Driven Auxiliary Feedwater Pump Once Every Refueling Outage Test;"

SP 1101,"12 Motor-Driven Auxiliary Feedwater Pump Once Every Refueling Outage Test;"

SP 2101, "21 Motor-Driven Auxiliary Feedwater Pump Once Every Refueling Outage Test;"

SP 2103,"22 Turbine-Driven Auxiliary Feedwater Pump Once Every

, Refueling Outage Test,"

j .

SP 1102, "11 Turbine-Driven Auxiliary Feedwater Pump Monthly Test,"

SP 1100,"12 Motor-Driven Auxiliary Feedwater Pump Monthly Test,"

SP 2100, "21 Motor-Driven Auxiliary Feedwater Pump Monthly Test,"

l SP 2102, "22 Turbine-Driven Auxiliary Feedwater Pump Monthly Test."

9812110006 971016 PDR ADOCK 05000282 G PDR

e i

o I Notice of Violation  ;

l 2. 10 CFR 50.71(e), " Maintenance of Records, Making of Reports," requires, in part, that each license periodically update the final safety analysis report (FSAR) [now  :

! know as the USAR at Prairie Island] to assure that the information included in the FSAR contains the latest material developed.

10CFR50.71(e)(4) requires, in part, that revisions be filed such that the intervals between successive updates to the USAR do not exceed 24 months. It further states that the revisions must reflect all changes up to a maximum of 6 months prior  !

to the date of filing.

The applicable section of the FSAR, now titled the Updated Safety Analysis Report (USAR), is Section 11.9.3, " Performance Analysis - Condensate, Feedwater, and Auxiliary Feedwater Systems" Contrary to the above, as of May 16,1997, the licensee had not assured that the i

information included in the FSAR contained the latest material developed and had not updated the FSAR periodically, as required in 10 CFR 50.71. Specifically, in

, October 1992, the licensee identified that the 400 gpm Auxiliary Feedwater Pump l (AFW) flow rate specified in USAR Section 11.9.3 under the Main Feedwater Line l Rupture accident scenario disagreed with actual Auxiliary Feedwater pump l performance capabilities of approximately 200 gpm with only one pump avaliable.

Since October 1992, three opportunities to update this section of the USAR were '

available, yet the revisions of September 1993, June 1994 and December 1995, did not contain the latest material developed or reflect all changes prior to the date of the filing. (01023)

3. 10 CFR Part 50, Appendix B, Criterion XVI, " Corrective Action," requires, in part, that conditions adverse to quality are promptly identifM and corrected; and in the case of significant conditions adverse to quality, the cause of the condition shall be documented, appropriately reported to levels of management, and corrective action taken to preclude repetition.

A. Contrary to the above, as of May 16,1997, the licensee had not resolved a significant condition adverse to quality that was identifM on March 6,1991, and documented on the assessment of Operating Experience Document NSD-TB-80-11, "High Head Safety injection"; Specifically, the assessment documented that design requirements - such as flow - had not been adequately considered when the safety injection pump surveillance l

procedures acceptance criteria were determined and there was a need to l ensure that design requirements were correctiy incorporated for other pumps' surveillance test acceptance criteria. Corrective action was not taken for the Auxiliary Feedwater, Residual Heat Removal, and Containment Spray Pumps. This was demonstrated when the NRC inspectors determined that the Auxiliary Feedwater Pump Surveillance tests' acceptance criteria would have allowed an AFW pump to be considered operable even if the pump parameters were below the minimum design requirements. (01033) 1

4.

Notice of Violation B. Contrary to the above, as of May 16,1997, the licensee had not resolved a condition adverse to quality that was identified on November 18,1992, and documented on Configuration Management Follow-On item FOI 40781, " Basis For AFWP Requirements After Line Break". Specifically, FOl 40781 documented a ,

deviation from the updated final safety analysis (USAR) in that the AFW pumps were not in conformance with the 400 gpm flow rate for a main feedwater pipe rupture accident scenario as specified in section 11.9.3 of the USAR with only one pump available. The licensee failed to promptly correct the deviation by demonstrating '

that the AFW pump capacity of approximately 200 gpm with only one pump available would be sufficient during a main feedwater pipe. rupture. (01043)  :

This is a Severity Level lli problem (Supplement 1)

Civil Penalty $50,000 Pursuant to the provisions of 10 CFR 2.201, Northem States Power Company is hereby

{

required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed imposition of Civil Penalty (Notice). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be schieved if an adequate reply is not received within the time {

specsfied in this Notice, an order or a Demand for information may be issued as why the license should not be modified, suspended, or revoked or why such other action as may be

, proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty preposed above, or may protest imposition of the civil penalty in whole or in part, by L a written answer addressed to the Director, Office of Enforcement, U.S. Nucieer Regulatory Commission. Should the Licensee fail to answer within the time specified, an order

! imposing the civil penalty will be issued. Should the Licensee elect to file an answer in l

t-I

s Notice of Violation  !

t

accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer 1

should be clearly marked as an " Answer to a Notice of Violation" and may: (1) deny the i

i violation (s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the civil penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the civil penalty, in requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure forimposing a civil penalty.

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attomey General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S.

Nuclear Regulatory Commission, Region lil and a copy to the NRC Resident inspector at the Prairie Island Nuclear Generating Plant facility.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois this 16th day of October 1997