ML20210R066
| ML20210R066 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 08/25/1997 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-282-97-11, 50-306-97-11, NUDOCS 9709020287 | |
| Download: ML20210R066 (5) | |
Text
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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonado Dr. East Welch, Minnesota $$089 August 25,1997 10 CFR Part 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washingt0n, 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 97011), Inadequate Aiming of l
Emergency Light and Deficiencies in the Conduct of Reviews of Procedures Your letter of July 24,1997, which transmitted Inspection Report No. 97011, required a response to a Notice of Violation. There were three violations in the Notice but your letter requests responses for Violations 2 and 3 only. Our response to those violations are contained in the attachment to this letter.
We have made two new Nuclear Regulatory Commission commitments, indicated as the statements in italles.
Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions related to this letter.
N oel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant I
c:
Regional Administrator -- Region Ill, NRC D~)
Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg
Attachment:
RESPONSE TO NOTICE OF VIOLATION 9709020207 770825 PDR ADOCK 05000282 Q
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4 RESPONSE TO NOTICE OF VIOLATION l
VIOLATION 2 Technical Specification 6.2.B delineated requirements for the Operations Committee, including:
s.
6.2.B.4.c which required Operations Committee review of proposals which would effect permanent changes to normal and emergency operating procedures and any other proposed changes or procedures that will affect nuclear safety as 4
determined by the Plant Manager.
b.
6.2,B.4.h which required, in part, that all procedures required by the Technical
- Specifications be reviewed initially and periodically with a frequency
' commensurate with their safety significance but at an interval of not more than two years.
c.
6.2.B.1 which required, in part, that no more than two alternates participate as voting members of the Operations Committee at any one time.
Contrary to the above, the inspectors determined that the requirements of Technical Specification 6.2.8 were not met in the following circumstances:
a.
At the June 11,1997, Operations Committee meet!ng,34 proposed permanent-changes to normal and emergency operating procedures and other proposed changes or procedures that could affect nuclear safety as determined by the plant manager were not adequately reviewed.
b.
On May 21,1997, the Operations Commit' tee failed to review 24 procedures
- required by the Technical Specifications at an interval of not more than two
- years, c.
At the April 26,1997, Operations Committee meeting more than two alternate members participated as voting members in Operations Committee business at one time.
This is a Severity Level IV violation (Supplement 1).
Resoonse to Violation 2 Reason for the Violation The details of how reviews were to be conducted by the Operations Committee (OC) and its members were not clearly defined in the plant administrative instructions. This
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Attachment August 25.1997 Page 2 resulted in inconsistencies in the reviews performed by the committee and its members as pointed out by the violation.
Corrective Actions Taken The OC members and alternates recognized that inconsistencies were occurring and began working on clarifying expectations on June 23,1997. For each type of item requiring the committee's review, specific guidance was developed so that members, alternates, and the plant staff in general, would know what the review by the OC should consist of. This guidance, developed by the members and alternate.4, has been adopted. Expectations for the completion of periodle review of procedures has also been communicated to the plant staff. The requirement that only two alternates participate as voting members has also been communicated to CC members and to the OC secretary.
Corrective Steps That Will Be Taken to Avoid Further Violations:
Changes to plant administrative procedum SAWI 3.3.0, Operations Committee, incorporating the above expectations have boon drafted and will bo incorporated by September 15,1997. Additionally, responsibilities of the on-site review committee as currently delineated in the Technical Specifications (Prairie Island License Amendment
(
Request dated December 14,1995 and supplemented November 25,1996 and July 14, 1997 proposes to move these responsibilities to the Operational Quality Assurance Plan) will be evaluated for changes to ensure consistency with current good industry practice.
I Date When Full Comoliance Will Be Achieved Full compliance has been achieved.
IR97011. DOC s
Attachment August 25,1997 Page 3 VIOLATION 3 10 CFR 50, Appendix R, Section Ill.J required emergency lighting units with at least an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> battery power supply shall be provided in all areas needed for operation of safe shutdown equipment and in access and egress routes thereto.
Contrary to the above, on June 24,1997,8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> emergency lighting was not provided for access and egress routes to the safeguards bus No.15 room, which contained equipment needed for operation of safe shutdown equipment.
This is a Severity Level IV violation (Supplement 1).
Resconse to Violation 3 Reason for the violation The violation was caused by incomplete adherence to the surveillance procedure for verification of safe shutdown emergency lighting; the incomplete adherence, in part, I
was initiated by an inadequate procedure from a human factors perspective.
Surveillance procedure, SP-1332, " Safe Shutdown Emergency Light Verification," is used to verify that the emergency lights are adequate for access and egress paths for areas of safe shutdown equipment; it is also used to verify that the emergency lights are adequate to operate the safe shutdown equipment, in the past, it appears that the emphasis was on the performance and steps needed by the operator at the various safe shutdown equipment locations during SP-1332 and not on the access / egress paths for these locations.
Emergency Light EL-17 has two lamps. Section 7.2 of SP 1332 directs the operator to go from the Control Room to the D1 Diesel Room. During the performance of this section of the surveillance procedure one lamp is verified to be directed toward the D1 access / egress path and the other as a general area light; both lamps appeared acceptable to the operator and engineer as emergency lighting. Section 7.5 of the procedure directs the operator to go from the Control Room to Bus Room 15, which also uses Emergency Light EL-17 as an access / egress path light. Because of the way SP-1332 is organized (it repeats the steps from the Control Room to various locations in the plant for each action), the operater repeatedly walks down a path that was previously walked down on the way to another destination. A light that was previously evaluated for one path is easily remembered as acceptable even though the next path now branches from the former path and the lighting requirements become different.
Both the engineer and operator performing the test considered the light acceptable IR97011. DOC
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Attachment August 25,1997 Page 4 because it had been accepted in a previous step as an adequate general area emergency light. However, this section was requiring that the light be a general area emergency light and a directed accesslegress light for Bus Room 15. Between the two sections of the procedure, EL 17 was identified as having three uses. Because of the organization of the procedure, the testers did not recognize the inconsistency between the procedure requirements for EL-17 and the impossibility for the two-lamp light to provide three different functions.
Correc1[ye Action TaktD Because the general area emergency light function of EL-17 is unnecessary, Work Order 9706940 was written to redirect the available lamp of Emergency Light EL-17 toward Bus Room 15 to provide better lighting for the access / egress path for Bus Room 15 and this work was completed June 27,1997.
Corrective Action to Preclude Recurrence SP-1332 will be changed to correct procedure discrepancies and better organize the procedure forhuman factors considerations. The procedure willhave the testers review each light for all ofits Intended purposes at one time Instead of reviewing the same light repeatedly during the performance of the sutveillance for varying purposes. The scope and purpose sections of the procedure will be enhanced to improve understanding of the fullIntent of the procedute before starting the steps. The changes willbe incorporated prior to the next perfonnance of the surveillance.
Date When Full Comollance Will Be Achieved Full compliance has been achieved.
1 i
11t 97011. DOC l