ML20217K307

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Forwards Response to Violations Noted in Insp Repts 50-282/97-15 & 50-306/97-15.Corrective Actions:Background Info on Operability Determination for Irpi & Rod Position Deviation Monitor Sent to Shift Managers
ML20217K307
Person / Time
Site: Prairie Island  
Issue date: 10/20/1997
From: Sorensen J
NORTHERN STATES POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-282-97-15, 50-306-97-15, NUDOCS 9710240253
Download: ML20217K307 (3)


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Northom States Power Company Prairie Island Nuclear Generating Plant ch nnesota 5 9 October 20,1997 10 CFR Pad 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 97015), Failure to declare rod deviation monitor inoperable as required by procedure Your letter of September 19,1997, which transmitted Inspection Report No. 97015, required a response to a Notice of Violation. Our response to the violation is contained in the attachment to this lotter.

We have made one new Nuclear Regulatory Commission commitment, indicated as the statement in italics.

Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions related to this letter, s

7DkkI Joel P Sorensen Plant Manager

[O Prairie Island Nuclear Generating Plant c:

Regional Administrator - Region Ill, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg

Attachment:

RESPONSE TO NOTICE OF VIOLATION

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10CFR50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by documented instructions and procedures of a type appropriate to the circumstances and be accomplished in accordance with these instructions or procedures.

Procedure SP2319, " Rod Position Verification," Revision 5, as revised by Temporary Memorandum TMA 1997-0122, required that the rod deviation monitor be declared inoperable if this monitor indicated that control rods were misaligned and the licensee determined that the rods were actually not misaligned and that the individual rod position indicators were operable.

Contrary to the above, the inspectors determined that on July 26,1997, SP2319, as revised by Temporary Memorandum TMA 1997-0122, was completed and the rod deviation monitor was not declared inoperable after the licensee determined that control rods were not actually misaligned and that the individual rod position indicators were operable following receipt of control rod indication deviation alarms.

This is a Severity Level IV violation (Supplement 1).

Response to Violation Reason for the Violation TMA 1997-0122 was issued to address recent concerns pertaining to the operability of the Individual Rod Position Indicators (IRPI) and the Rod Position Deviation Monitor (RPDM). Due to insufficient information in the Temporary Memorandum and insufficient training, TMA 1997-0122 was not adequately complied with in that the RPDM was not declared inoperable as required by SP2319.

Corrective Actions Taken Background information on operability determination for the IRPI and RPDM was sent to Shift Managers and Shift Supervisors.

PINGP 1224, ' Crew Meeting Review of Noteworthy Event /Near Miss/ Change," was issued to inform all operating crews of the Temporary Memo change to SP1319 and SP2319.

New Temporary Memos were issued to clarifiy the flow chart of SP1319 and SP2319 and to add words concerning RPDM operability.

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Attachment October 20.1997

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A Request for Training, for Operations, on Tech Spec 3.10 has been issued.

The Administrative Work Instruction and associated form for Temporary Memorandums was revised to require the SRO approver to determine if training is needed for euch Temporary Memorandum.

Corrective Stoos That Will Be Taken to Avoid Further Violations:

Procedures SP1319[SP2319), ' Rod Position Verification," will be revised to include the required actions identified in the current Temporary Memorandums for determining IRPI and RPDM operability. Input from users of the procedures willbe factored into the revisions. The revisions will be completed by December 31,1997.

Equipment functionality and operability requirements for the IRPI and RPDM will be reviewed to determine if more appropriate requirements should be applied. A result of this review may be proposed changes to procedures, Technical Specifications, or the USAR.

The Administrative Work Instruction on ' Change Management' will be reviewed to determine if any changes are required based on the revision to the Temporary Memorandum process.

Calibration methods will be evaluated to determine if IRPI indications can be optimized in the 120 to 200 step range.

Physical modification of the IRPI circuitry is being considered to improve the linearity of the IRPl.

Date When Full Compliance Will Be Achieved Full compliance has been achieved.

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