ML20217Q534
| ML20217Q534 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 08/15/1997 |
| From: | Hill W NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-263-97-08, 50-263-97-8, NUDOCS 9709030174 | |
| Download: ML20217Q534 (5) | |
Text
l Northem States Power Company Monticello Nuclear Generating Plant 2807 West Hwy 75 Monticello, Minnesota 55362-9637 August 15,1997 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. 50-263/97008 Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our reply to the notice of violation contained in your letter of July 17,1997, is provided in Attachment A.
Attachment A, Reply to Notice of Violation, contains the following new NRC commitment:
Evaluate administrative hold tagging practices and the need for training on valve tagging /mispositioning. The evaluation and any training found to be necessary will be completed by March 15,1998.
Please contact Marcus Voth, Project Manager - Licensing, (612-2715116) if you require further information.
>wls William J Hill Plant Manager Monticello Nuclear Generating Plant
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Regional Administrator-lit, NRC
).t NRR Project Manager, NRC Sr Resident inspector, NRC State of Minnesota Attn: Kris Sanda J Silberg Attachments A - Reply to Notice of Violation 9709030174 970815 PDR ADOCK 05000263 G
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I 805/97 MHV J tlCENSEWlOLuFi978NOV DOC
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REPLY TO NOTICE OF VIOLATION Att: chm:nt A Pag 31 August 18,1997 Violation:
During an NRC inspection conducted on May 28 through July 7,1997, a violation of NRC l
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," required that activities affecting quality be prescribed by, and accomplished in accordance with, documented instructions, procedures, or drawings.
a.
Administrative Work Instruction (AW ) 04.04.01, " Equipment isolation," step 4.2.1, stated that safety-tagged equipment shall not be operated until the safety tag has been properly released.
Contrary to the above:
\\1.) On May 29,1997, the inspectors identified that reactor building closed cooling water (RBCCW) valve 2-2 and its associatedpiping were removed from the RBCCW pump; however, a safety tag (a hold-and-secure card) on the valve had not been properly released.
(2.) Also, on June 6,1997, the inspectors identified that the refueling bridge air compressor blowdown valve was repositioned from the OPENposition to the CLOSED position; however, a safety tag on the valve had not bssn properly released.
b.
Northern States Power Company Operational Quality Assurance Plan, Revision 20, Section 8.5, " Drawing Control," required that drawings which represent physical and functional aspects of the operating nuclear plant which are critical to safe plant operation shall be maintained in a current status.
Administrative Work Instruction 4 awl-02.04.01, " Drawing Control," Revision 5, section 4.3.2, required that Class 1 and 2 drawings shall be revised to represent current plant status.
Contrary to the above:
On June 9,1997, the inspectors identified eight examples where Class 1 and 2 drawings did not represent current plant status. These examples included installed fuses different from that specified in drawings, protection fuses not shown on drawings, and differences between Class 1 and 2 drawings.
' REPLY TO NOTICE OF VIOLATION Attachm:nt A Paga 2 August 18,1997 Violation Response - Part a.[1]
NSP Response to Violation NSP acknowledges the above Notice of Violation.
Reason For Violation:
4AWI 04.05.04," Conduct of Maintenance, Alterations and Design Changes", step 4.4.2.J, gives explicit worker instructions for this situation which were not followed.
Although the component involved had to be physically removed to accomplish the maintenance, this AWI instructs the worker to have the tag released by the Shift Supervisor prior to removal.
The cause of the event was personnel error.
Corrective Action Taken and Results Achieved:
The Shift Supervisor was notified immediately and the tag was released. The worker involved was counseled by line supervision.
The procedural requirement was reinforced b all maintenance workers.
Corrective Action to be Taken to Avoid Further Violations:
No further actions are required.
'Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Violation Response - Part a.[2]
NSP Response to Violation NSP acknowledges the above Notice of Violation.
Reason For Violation:
During the 1996 refueling outage the refueling bridge air compressor failed. This is a 3/4 horsepower compressor mounted on a 10 gallon rcceiver tank. Service Air was provided to the air receiver tank for air operated equipment on the refueling bridge. A
- REPLY TO NOTICE OF VIOLATION Att chment A Piga 3 i
August 18,1997 hose was run between the service air station and a valve on the receiver tank. A temporary bypass tag was placed on the hose and a
- Hold" card was placed on the receiver tank valve to maintain it in the open position.
On June 6,1997, one of the NRC resident inspectors found the valve on the receiver tank closed with the " Hold" tag on the valve. " Hold' cards are required to be used to protect personnel and equipment. They are also used for administrative reasons.
An investigation was conducted on this incident. A team of three individuals has interviewed personnel and reviewed plant documents. The valve was last documented to be the open position in March 1997 during the quarterly valve check. No reason for the change in position has been identified.
Corrective Action Taken and Results Achieved:
The valve was promptly opened upon discovery of the error. A review of the " Hold" tag determined that the tag was not necessary to protect personnel or equipment. The card was removed.
Corrective Action to be Taken to Avoid Further Violations:
The " Hold" card in this case was being used as an administrative hold. Use of " Hold' cards for administrative holds may dilute the importance of the " Hold" card. Another way of performing administrative holds will be considered.
Consideration of training on valve mispositionings/ tagged valve importance is being eva!uated. These two steps, including any training considered necessary, will be completed by March 15,1998.
Date When Full Compilance Will Be Achieved Full compliance has been achieved, f-Violation Response - Part b.
NSP Response to Violation NSP acknowledges the above Notice of Violation.
Reason For Violation:
The as built discrepancies found in the 250 VDC MCC drawings occurred mainly due to redundant information on multiple drawings that were not properly updated during original construction and early plant modification activities. For example, the Bechtel panel schedules were updated without recognizing that GE panel schedules also existed which were overlooked. Contributing to this issue was the untimely drawing
...w REPLY TO NOTICE OF VIOL.ATION Att: chm:nt A Paga 4 August 18,1997 L
updates by the system engineer who was aware of many of the discrepancies but was accumulating the changes with the intent of making a comprehensive revision to the drawings.
No documentation was found to explain how the 61/4 Amp fuse was mistakenly installed in place of the 6 Amp fuse, it is believed the improper fuse was installed prior to' detailed Fuse Replacement Controls implemented in 1986.
Corrective Action Taken and Results Achieved:
The 250 VDC MCC fuses and configuratiom were walked down to davalop a comprehensive list of discrepancies. All fuse discrepancies were reviewed and -
resolved by either changing the fuse or clarifying the drawing information. No operabihty issues were founo with the identified discrepancies. Drawings were marked up to correct errors and to climinate redundant information. The critical drawing file was updated on 8/26/97 before plant startup. A Drawing Revision Request has been processed and plant drawing files are being updated. The System engineer has been counseled on the importance of timely drawing updates.
Corrective Action to be Taken to Avoid Further Violations:
Drawing discrepancies will be reviewed with Engineering Staff to point out the type of errors that may develop when redundant information is on multiple drawings and the importance of timely correction when found.
L Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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