ML20217D897
| ML20217D897 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/17/1998 |
| From: | Hammer M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-263-98-02, 50-263-98-2, NUDOCS 9804270132 | |
| Download: ML20217D897 (8) | |
Text
. - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l l
l
\\
Northem States Power Company Monticello Nuclear Generating Plant 2807 West County Road 75 Monticello, MN 55362 April 17,1998 10 CFR Part 2 Section 2.201 US Nuclear Regulatory 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. 50-263/98002 Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the notice of violation contained in your letter of March 18,1998, is provided in Attachment A.
This inspection report identified concerns in the Technical Specification (TS) amendment process regarding timely implementation of NRC issued amendments. To respond to this concern, current plant processes have been reviewed and the following will be implemented: a) Specific time limits will be placed on identifying and changing affected procedures. b) Administrative controls will prevent use of the procedures until revised. c) Management will be periodically updated on implementation status to provide overview. This will be completed by July 31,1998 as stated in commitment 9 below.
The inspectors also identified concerns in the TS amendment process, such that other effective TS changes may not be reflected in additional procedures. An immediate review of outstanding TS amendments was initiated. Affected procedures were either revised or administrative controls were placed upon them.
The NRC determined NSP's process for implementing TS amendments was weak, in that, documents potentially affected by a TS change were not identified until after a TS amendment was approved by the NRC. Due to the uncertainty of when amendments will be approved, it is impractical to identify documents potentially impacted by TS changes prior to amendinent approval. NSP does, however, agree that changes must be implemented in a timely manner. The above mentioned process changes will address this concern.
Attachment A, Reply to Notice of Violation, contains the following new NRC commitments:
1.
The process of placing a Hold card (and verification of the card) on motor operated valve handwheels will be evaluated to determine if valve position determination is necessary. This action will be completed by September 30,1998.
,1
/
,,4 v V.L '$
4/17/98 SIS JUCENSEMOLifR982NOVDOC C'
9804270132 980417 PDR ADOCK 05000263 G
USNRC NORTHERN STATES POWER COMPANY April 17,1998 Page 2 2.
'The administrative work instruction on motor operated valve position determination will be revised to qualify or remove the use of stem position as a method for valve position determination. This action willbe completedby September 30,1998.
3.
Training will be provided to operations personnel on the lessons leamed. This action willbe completed by September 30,1998.
4.
The violation regarding a hold-and-secure card attached to the control room handswitch will be reviewedin Operations training. This review will reiterate the operability verification considerations as delineatedin owl-03.02 and the plant status awamness requirements of OWi-01.06. The review willbe completedby September 30,1998.
5.
Use of the Shift Supervisor's Hold and Secure Card Book to provide isolations that are not associated with a work document will be reviewed and necessary improvements implemented byJuly 31,1998.
6.
Administrative procedures willbe revised to require completion of a workplanning checklist for all mechanical maintenance work packages, include heavy load review requirements on the work planning checklist and require pre-Job briefs for all heavy load lifting. This action will be completed by August 31,1998.
7.
Work orderpreparation processes will be evaluated to determine if further training is required for work orderpreparation. This action willbe completed by August 31,1998.
8.
During maintenance continuing training, the violation regarding heavyloads, heavyloads l
procedural requirements and actions taken in response to the violation, will be reviewed. This action will be completed by August 31,1998.
9.
The administrative process forimplementation of License Amendments willbe revised, as necessary, to assure that the appropriate changes are made to affectedprocedures or administrative controls are applied which prevent use of affectedprocedures. This willbe completed by July 31,1998.
Please contact Sam Shirey Sr. Licensing Engineer, (612)-295-1449 if you require further information.
0A$l/[/}W Michael F. Hammer Plant Manager Monticello Nuclear Generating Plant c:
Regional Administrator - 111, NRC NRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn: Kris Sanda J Silberg Attachments A - Reply to Notice of Violation l
REPLY TO NOTICE OF VIOLATION Attachmtnt A Pcgs 1 April 17,1998 During an NRC inspection conducted from January 13,1998, through February 23,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below.
Violadon No.1 Criterion V of 10 CFR Part 50, Appendix B, " Instructions, Procedures, and Drawings,"
requires that activities affecting quality shall be prescribed by documented instructions, procedures, and drawings of a type appropriate to the circumstances and shall be accomplished in accordance with those instructions, procedures, and drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or i
qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above; On January 21,1998, the equipment isolation sheet associated with Work Order (WO)-
9000108, " Install surge suppression diode at MO-2000 trip coll," did not contain i
adequate instructions for the restoration of Valve MO-2078. Specifically, the instructions did not require the operators to manually open and reposition the manual declutch after the motor-operated valve had been manually closed. As a result, these actions were not completed and operators were unable to electrically stroke the valve following the :estoration activity.
NSP Response to Violation NSP acknowledges the above Notice of Violation.
On January 20,1998, operations personnel were performing an equipment isolation that required motor operated valve MO-2078 to be secured in the closed position. The isolation had been completed (the valve is normally closed and was not positioned as part of the isolation) and an operator was assigned to perform the independent verification. The breaker supplying electrical power to MO-2078 and the switch supplying control board light indication were open as part of the isolation. A Hold card was also placed on the manual handwheel for MO-2078, specifying that the valve be closed. When independently verifying this card on the handwheel, the operator attempted to confirm that MO-2078 was closed. Administrative work instructions identify two methods for determining valve position. The preferred valve position indication, control board valve light indication, could not be used since there was no power for this indication. The second method, visually observing the position of the valve stem, was not conclusive. The verifier chose a third method which was not in the administrative work instructions, the verifier engaged the manual clutch and attempted to close the valve. The valve was determined to be closed.
On January 21,1998, the valve was being returned to service and was given an open signal but did not open. After partially opening the valve with the handwheel, the clutch was engaged, and the valve was electrically stroked and declared operable.
I l
REPLY TO NOTICE OF VIOLATION Attachm:nt A Page 2 April 17,1998 Reason For Violation The verifier used a verification method not described in the administrative work instructions.
The verifier was not aware that when a motor operated valve is manually closed, it needs to be manually opened prior to motor operation.
The administrative work instructions do not provide a conclusive method for determining motor operated valve position when control board light indication is not available.
Corrective Action Taken and Results Achieved The valve was tested and determined to be operable.
Corrective Action to be Taken to Avoid Further Violations The process of placing a Hold card (and verification of the card) on motor operated valve handwheels will be evaluated to determine if valve position determination is necessary.
The administrative work instruction on motor operated valve position determination will be revised to qualify or remove the use of stem position as a method for valve position determination.
Training will be provided to operations personnel on the lessons leamed from this event.
These actions will be completed by September 30,1998.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Violation No. 2 Step 4.4.2 of Administrative Work Instruction 4AWi-04.05.05, Revision 8, "WO Closeout and Disposition," states, in part, that the shift supervisor shall coordinate the permanent clearing of an isolation to facilitate required testing and the return-to-service of components or systems.
Contrary to the above; On January 29,1998, the inspectors identified that the shift supervisor failed to remove a hold-and-secure card attached to the control room handswitch for the #13 residual heat removalservice waterpump prior to declaring the system operable. The hold-and-secure tag instructed the operators not to operate the pump.
NSP Response to Violation NSP acknowledges the above Notice of Violation
REPLY TO NOTICE OF VIOLATION Attachm:nt A Pcgs 3 April 17,1998 Reason For Violation The primary cause of this violation is failure to perform an operability verification upon restoration of a system which has been out of service. Operations Work Instruction owl-03.02, " Safety Related System Operability Verification," Section 4.1.5 C, includes the following requirement for the Shift Supervisor.
Ensure that safety related systems operability verifications are performed as required and for the following cases:
C. When a system has been out of service and it is subsequently required to restore operability of the system.
Section 4.1.6 provides considerations for performing an operability verification, which include:
Assuring that no safety tags or bypasses (bypass keys, Jumpers, etc.) are installed which will defeat or adversely affect automatic initiation and/or operations of the system as may be required.
The Shift Supervisor made a cognitive error in failing to recall the placement of the hold-and-secure card and verifying its removal prior to declaring the system operable. Control room personnel were deficient in maintaining awareness of plant status as required in owl-01.06,
" Duty Operations Personnel Requirements and Responsibilities".
A contributing cause of this event is the use of the Shift Supervisor's Hold and Secure Card Book to provide isolations that are not associated with a work document. In this instance the isolation was not associated with the Work Order, but was initiated using the Hold and Secure Card Book. The pump handswitch was tagged for the Duty Shift Supervisor. The previous Shift Supervisor had placed the card for precautionary purposes because the pump was inoperable until an alternate means of motor cooling could be provided. Subsequently, when the work order was cleared, there were no isolations associated with the work order and removal of the card had to occur during operability verification.
As noted in the inspection Report, the safety significance of this event was minimal since the pump was physically capable of performing its safety function. Manual actions are required to place the pump in service and the Duty Shift Supervisor could have readily released the card if a pump start had been required.
Corrective Action Taken and Results Achieved The Duty Shift Supervisor was contacted and the card was released. The Control Room Log entry regarding exiting the Limiting Condition for Operation (LCO) was corrected.
Corrective Action to be Taken to Avoid Further Violations The violation regarding a hold-and-secure card attached to the control room handswitch will be reviewed in Operations training. This review will reiterate the operability verification considerations as delineated in owl-03.02 and the plant status awareness requirements of owl-01.06. The review will be completed by September 30,1998.
}
REPLY TO NOTICE OF VIOLATION Attachm:nt A P ge 4 April 17,1998 Use'of the Shift Supervisor's Hold and Secure Card Book to provide isolations that are not associated with a work document will be reviewed and necessary improvements implemented by July 31,1998.
Date When Full Compliance will be Achieved Full compliance has been achieved.
Violation No. 3 Step 4.1.1 of 4 awl-06.06.01, Revision 6, " Material Handling and Control of Heavy Loads," defines a heavy load as any load weighing greater than 1500 pounds. Step 4.2.1 requires the licensee to determine if the use of the heavy load procedures is necessary using Figure 5.1, ' Heavy Load Decision Flow Chart."
Procedure 8151, Revision 4, " Heavy Load Movement Procedure," provides instructions for the movement of heavy loads.
Contrary to the above; WO 980042, ' Move New Channels / Blades to RB1027[reactorbuilding,1027-foot elevation] and Remove Empty Boxes,' was not appropriate to the circumstances in that it did not specify the number of crates to be lifted simultaneously.
As a result, on January 21,1998, maintenance personnellifted two crates, weighing about 1400 pounds each, from the ground level to the refueling floor area using the reactor building crane. The inspectors identified that lifting the two crates simultaneously constituted a heavy load and an evaluation should have been performed in accordance with 4 awl-06.06.01 and Procedure 8151.
NSP Response to Violation NSP acknowledges the above Nctice of Violation.
Reason for the Violation The tailure to communicate important information and expectations as part of job planning and a pre-job brief resulted in the violation as described below:
l
- 1. The maintenance crew involved thought that a heavy loads procedure issued for tne movement of scaffolding prior to lifting the channel boxes also covered the channel box lifts.
- 2. The individual who prepared the work order did not realize that the information in the electronic work order system that included the weight of the channel boxes did not appear on the printed copy used by maintenance personnel.
- 3. The maintenance supervisor coordinating the work did not realize that the crew had decided to lift two boxes at once.
(
L
REPLY TO NOTICE OF VIOLATION Attachmrnt A Pag 3 5 April 17,1998 lt sh'ould be noted that the lifting equipment and practices used when lifting the two boxes simultaneously were in compliance with the requirements of procedure 8151, " Heavy Load Movement Procedure," even though a copy of the procedure was not present at the work location.
Corrective Action Taken and Results Achieved This event was discussed with the maintenance supervisor, riggers and work order preparer.
Subsequent boxes were lifted individually. Since one box, by itself, is not a heavy load, lifting the boxes individually did not require a heavy loads procedure.
Corrective Action to be Taken to Avoid Further Violations Administrative procedures will be revised to require completion of a work planning checklist for all mechanical maintenance work packages, include heavy load review requirements on the work planning checklist and require pre-job briefs for all heavy load lifting.
Work order preparation processes will be evaluated to determine if further training is required for work order preparation.
During maintenance continuing training, the violation regarding heavy loads, heavy loads procedural requirements and actions taken in response to the violation, will be reviewed.
These actions will be completed by August 31,1998.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Violation No. 4 Technical Specification (TS) 3.7.B.2.a(3) states that the laboratory carbon sample analysis for standby gas treatment charcoal absorber cartridges shall show 294 percent methyl iodine (iodide) removal efficiency when tested at 30* Celsius and at 95 percent humidity.
Surveillance Test 0149, Revision 5, " Standby Gas Treatment Charcoal Absorber Cartridge Test," was developed by the licensee to meet the requirements of TS 3.7.B.2.a(3).
Contrary to the above; Surveillance Test 0149 was not appropriate to the circumstances in that it did not contain the appropriate acceptance criteria. Specifically, the inspectors identified that since October 2,1995, the requirements of TS 3.7.B.2.a(3) were not containedin I
Surveillance Test 0149. The test acceptance criteria providedin the test was 290 percent methyllodine (iodide) removal efficiency when tested at 130
- Celsius and at 95 percent relative humidity.
$'~#
REPLY TO NOTICE OF VIOLATION Attichm:nt A Page 6 April 17,1998 NSP'Reshnse to Violation NSP acknowledges the above Notice of Violation.
Reason For Violation The cause of the violation was cognitive failure of the responsible engineer to implement Technical Specification Ucense Amendment #94. The responsible engineer failed to place an administrative control on Surveillance Procedure 0149, Standby Gas Treatment Charcoal Adsorber Cartridge Test which would have prevented its use. In addition, the responsible
)
engineer also failed to perform a proper biennial review on the procedure. The responsible
)
engineer should have realized that the unrevised Procedure 0149 could have been initiated by i
other plant personnel, who were not familiar with the License Amendment, and the wrong test criteria and acceptance criteria could have been applied for charcoal testing by a laboratory.
The correct surveillance requirements were incorporated into the instructions for preventive maintenance activities that were performed on 1P/10/96,12/16/96,2/2/98, and 2/9/98. This preventive maintenance included removal of charcoal samples for laboratory testing to meet the surveillance requirements of Tech Spec 4.7.B.2.a.(3). In each case, the correct testing requirements and acceptance criteria of Tech Spec 3.7.B.2.a.(3) as revised by Amendment
- 94 was specified, however, this method of satisfying Tech Spec surveillance requirements does not meet management expectations. At no time was Procedure 0149 used with the incorrect testing requirements and acceptance criteria.
Corrective Action Taken and Results Achieved An administrative control was immediately placed on Procedure 0149. It was subsequently revised on March 30,1998 with the correct testing requirements and acceptance criteria.
Corrective Action to be Taken to Avoid Further Violations The administrative process for implementation of License Amendments will be revised to assure that the appropriate changes are made to affected procedures or administrative controls are applied which prevent use of affected procedures. This will be completed by July 31,1998.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
-