ML20203J958
| ML20203J958 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/26/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-282-97-23, NUDOCS 9803040375 | |
| Download: ML20203J958 (4) | |
Text
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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 February 26,1998 10 CFR Part 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Reply to Notice of Violation (Inspection Report 97023),
Procedural Adherence issue x
4 Your letter of January 30,1998, which transmitted Inspection Report No. 97023, required a response to a Notice of Violation. Our response to the notice is contained in the attachment to this letter.
In this response we have made one new Nuclear Regulatory Commission commitment as noted by the italicized text under Corrective Steps to Avoid Further Violations.
Please contact Jeff Kivi (612-388-1121, Ext. 4713) if you have any questions related to this letter.
N Joel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant c:
Regional Administrator - Region lil, NRC Senior Resident inspector, NRC J
NRR Project Manager, NRC
[t Ii J E Silberg
~
3
Attachment:
RESPONSE TO NOTICE OF VIOLATION n
\\'fkh 9803040375 900226 PDR ADOCK 05000282 O
PDR l
l RESPONSE TO NOTICE OF VIOLATION VJOLATION Technical Specification 6.5 requires that detailed written procedures be prepared and followed. Technical Specification 6.5.A 4 specifically requires procedures for surveillance and testing requirements that could have an effect on nuclear safety.
Contrary to the above, on December 10,1997, Maintenance Procedure D32,
" Temperature Coefficient Measurement At Hot Zero Power," Revision 6, a physics testing procedure that could have an effect on nuclear safety, was not followed for Unit 1 when the reactor operator and the nuclear engineer coordinating the procedure, on two separate occasions, failed to perform an approximately five degree cooldown and an approximately five degree heatup as required by procedure steps 7.2 and 7.3, respectively.
This is a Severity Level IV Violation (Supplement 1)
RESPONSE TO VIOLAT10B Backaround During the performance of the zero power physics testing at the beginning of Unit 1 Cycle 19, steps in the procedure for determining the isothermal temperature coefficient (lTC) were not fully complied with on multiple occasions, all resulting from a consistent interpretation of the steps. Procedure D32, Temperature Coefficient Measurement at Hot Zero Power, Rev. 6, requires that a slow and stable temperature decrease of approximately 5 F followed by a slow and stable increase of approximately 5 F be performed to determine the ITC.
The average of the two measurements is the ITC of record. Contrary to the wording of the applicable steps, temperature changes of 2.2*F,1.8'F,2.4 F and 1.2'F were made in the determination of the ITC.
Reason for the Violation The event was caused by the Nuclear Engineer's interpretation of the various parts of the procedural steps. The Nuclear Engineer was familiar with the procedure and had participated in its performance several times in the past.
Past history had shown that maintaining a large " stable" temperature change 1
was difficult and that a stable temperature change was more important than a
Attachment February 26,1998 Page 2 large temperature change. The phrase " stable temperature dec. ease of approximately 5"F" was therefore interpreted as a stable temperature decrease that may require up to a 5 F change. The temperature changes made in the performance of the ITC measurements were exceptionally stable and it was determined that a larger change was unnecessary. The Nuclear Engineer indicated that sufficient data had been gathered and the Operations staff suspended the temperature change.
Corrective Steps Taken and Results Achieved We have performed a review to ensure that the performance of the test was acceptr.ble per the standard (ANSI /ANS 19.6.1.1-1985, Reload Startup Physics Tests for Pressurized Water Reactors) even though the procedural steps were not literally complied with. Although the temperature change required by the procedure was not met, it has been determinec that the measurement of the ITC, and the validation of the <
- safety analysis, was not adversely impacted.
The benchmarking studies pt
-d in the development of the NSP Nuclear Arialysis reload design methoou'ogy consisted primarily of heatup and cooldown data spanning from 1*F to 3'F and is therefore consistent with tne data gathered during this event. Through discussions with Westinghouse it was concluded that a stable change of >1'F is sufficient to accurately determine the iTC.
ANSI /ANS 19.6.1.1-1985 contains a user's guide listed as Appendix A that is not a part of the standard and contains no requirements but is included as a guide for establishing a startup physics testing program. The guidelines addressing ITC measurement recommend a 3 F - 10 F temperature change, however, Appendix A specifically states,"The test enteria shown in this Guide are recommendat nn only. As industry experience changes, the criteria should change with it." Given the benchmarking studies performed by NSP Nuclear Analysis in combination with the opinion of Westinghouse, industry experience would indicate that the performance of the test was acceptable per the standard even though the procedural steps were not literally complied with.
Corrective Steos To Avoid Fudher Violations 1.
Procedure D32, Temperature Coefficient Measurement at Hot Zero Power will be revised to reflect the required test criteria. This actiun will be completed prior to the next use of procedure D32.
IR97023. DOC
Attachment February 20.1998 Page 3 2.
There exists an o~joing plant-wide initiative to train all site personnel on the importance oi procedure adherence and the timely correction of identified procedure errors.
The Date When Full Comoliance Will be Achieved Compliance has been re-established.
5 IR97023. DOC f