ML20199F602
| ML20199F602 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 01/13/1998 |
| From: | Hammer M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-263-97-15, NUDOCS 9802040051 | |
| Download: ML20199F602 (4) | |
Text
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Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticeno. Minnesota $5362 9637 January 13,1998 US Nuclear Regulaton/ 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. 50-263/97015 Ref.1 Letter from Geoffrey E. Grant, NRC, to M. Wadley, NSP,"Monticello NRC Inspection Report No. 50 263/97015(DPP) and Notice of Violation," December 18,1997 Pursuant to the provisions of 10 CFR Part 2, Section 2.201, NSP is su~cmitting its response to the notice of violation identified and described by the staff in Ref.1.
Attachment A, Reply to Notice of Violation, containe illowing new NRC commitments.
The applicable changes to sections 5.3.4 and 10.3.2.2.5 of the MNGP USAR will be processed as part of the USAR upgrade project and completed by the next scheduled USAR update. Procedure 1151, " Winter Checklist " will subsequently be revised to include a bases section. This revision will identify the USAR-related filtering requirements and the intent of the associated step (s) will be included.
The violation will be reviewed in Operations training. This review will emphasize the requirements for temporary change approval as delineated by 4 AWi-02.02.05," Temporary Change Process."
Please contact Joel Beres, Monticello Licensing, (612-295-1436) if additional information is required.
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Michael F. Hammer Plant Manager
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Monticello Nuclear Generating Plant c:
Regional Administrator - 111, NRC NRR Project Manager, NRC Sr. Resident inspector, NRC State of Minnesota Attn: Kris Sanda J. E. Silberg
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Attachment A - Reply to Notice of Violation
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Attachment A Reply to Notice of Violation Viohtlon During an NRC inspection conducted from October 14 through November 24,1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600 (60 FR 34381; June 30,1995), the violation is listed below.
10 CFR 50, Appendix B, Criterion V," Instructions, Procedures, and Drawings," requires that activities affecting quality be prescribed by and accomplished in accordance with documented procedures, instructions, or drawings.
Step 4.1.4 of 4 Administrative Work Instruction (AWI) 02.02.05, " Temporary Change Process,"
Revision 5, states that with the exception of temporary procedure changes made during emergency situations, temporary changes shall not change the scope or intent of an approved procedure.
Step 4.3.1 of 4 AWi 02.02.05 states that a temporary procedure change shall be approved by two members of plant management prior to implementation and one of the approvals shall be the duty shift manager or duty shift surservisor.
Step 12 of Procedure 1151,
- Winter Checklist," Revision 37, states that the operators could remove the reactor building ventilation supply filters after the ground had snow cover.
Contrary to the above, on October 27,1997, on the two occasions discussed below, activities affecting quality were not accomplished in accordance with documented procedures.
a.
Operations management issued a temporary change to Procedure 1151 which changed the intent of Step 12 af that procedure. The temporry change allowed the operators to remove the reactor building ventilation filters when outside air temperature dropped below freezing. This invalidated an outstanding operability determination which stated the filters were not to be removed until the ground was covered with snow.
b.
This temporary procedure change was not approved in accordance with 4 AWi-02.02.05. The temporary change was not authorized by a duty shift manager or duty shift supervisor.
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NSP Response to Violation NSP acknowledges the above Notice of Violation.
Reason For Violation Part a.
The primary cause of this violation is failure to recognize the impact of removing the filters on the system description in the USAR. The original development of the winter checklist occurred in March of 1978. The original procedure included a step that was not in accordance with sections 5.3.4 and 10.3.2.2.5 of the MNGP USAR. The USAR states that the reactor building, turbine building, and radwaste building are provided with filtered
..Je air. If this impact had been recognized a safety evaluation wou!d have been written tv evaluate the impact and to process the appropriate USAR and procedure changes.
Since the original development of the checklist, coritrols have been instituted to increase USAR awareness during procedure writing. These controls have included several mandatory training sessions for cognizant plant personnel on USAR awareness and the proper use of 10CFR50.59 safety evaluations. Step 4.2.3.D of 4 awl-02.02.02, " Work Procedure Reviews and Approval," includes the following requirement for the independent reviewer.
A 10CFR50.59 evaluation has been prepared to address any procedure orprocedure change that results in a deviation from steps listed in the USAR, or that will result in system operation which deviates from the way the system is described in the USAR.
The subsequent identification of the USAR and procedural discrepancy in the winter checklist as described above was a manifestation of the increased awareness among plant penaonnel. By condition report 96002018, the MNGP engineering staff identified the discrepancy between the USAR descriptions and the practice of removing the filters when snow cover was present. This condition report engendered the operability determination discussed in the violation.
A second contributing cause of this event is a failure to recognize the future need to correct affected procedures after the discrepancy had been identified. Section 4.4.8.A.3 of the condition report procedure, " Condition Report Process 4 AWi-10.01.03," requires that the assessor determine the future needs associated with the condition including procedural revisions.
Revision 37 in Procedure 1151, " Winter Checklist," did not contain a bases saction. A procedural revision could have incorporated a bases section. If the winter checklist had contained a bases or a reference to the applicable USAR sections, the technical justification for removal of the filters and the underlying intent of step 12 would have been more evident to the operators. This section would have prevented the temporary change since, by procedure, a temporary change cannot be used to change the scope or intent of an approved procedure unless emergency situations exist.
Given that the operators were not procedurally alerted to the basis for step 12, the decision to process the temporary chanae, of itself, was not unreasonable under the circumstances.
The systems had operated without filters during the snow and melt cycles of 20 winter seasons without any evidence of degradation. The operators were cognizant of the filters' function to remove particulates. Snow had already fallen and had partially melted. This 2
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would have significantly reduced the amount of airborne particulates. In addition, the operators were concerned that if tne filters were not removeo, frost or snow would restrict air flow vyhich would have a direct and more immediate detrimental effect on the operation of the associated ventilation systems.
NSP is implementing an integrated USAR review at MNGP. As part of this effort, the USAR i
is being reviewed to assure that it properly reflects the design and operation of the plant.
i This project includes a coordinated review of plant procedures, including work proceduresc to verify that these documents have not invalidated inputs used in the USAR.
Part b.
The primary cause of the violation noted in part b. above was due to a lapse of memory.
The Relief Shift Supervisor rather than the Duty Shift Supervisor authorized the temporary change. The second approval was from an off duty shift manager. This approval was not in accordance with the approval requirements of section 4.3.1.A of 4 awl-02.02.05,-
" Temporary Change Process." The temporary change approvers were aware of the AWI r3quirements, but did not remember to check that at least one approval was given by the duty shift manager or duty shift supervisor.
Corrective Action Taken and Results Achieved The system engineer was contacted and an operability determination was completed assuming that the filters were removed from the system without snow cover. The NRC staff has reviewed this evaluation. The required signatures for the temporary change were obtained.
Corrective Action to be Taken to Avoid Further Violations To preclude this same or a similar event occurring, two new commitments have been made.
These commitments are described below.
1; The applicable changes to sections 5.3.4 and 10.3.2.2.5 of the MNGP USAR will be processed as part of the USAR upgrade project and completed by the next scheduled USAR update. Procedure 1151, " Winter Checklist," will subsequently be revised to
- include a bases section. This revision willidentify the USAR-related filtering requirements and the intent of the associated step (s) will be included.
- 2. The violauon will be reviewed ?n Operations training This review will reiterate the requirements for temporary change approval as delineated by 4 AWi-02.02.05,
" Temporary Change Process."
Date When Full Compilance will be Achieved Full compliance has been achieved.
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