ML20236L204
| ML20236L204 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/02/1998 |
| From: | Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wadley M NORTHERN STATES POWER CO. |
| References | |
| 50-282-98-06, 50-282-98-6, 50-306-98-06, 50-306-98-6, NUDOCS 9807100264 | |
| Download: ML20236L204 (2) | |
See also: IR 05000282/1998006
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,:
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July 2, 1998
Mr. M. Wadley, President
s
Nuclear Generation
Northem States Power Company
414 Nicollet Mall
Minneapolis, MN 55401
SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-282/98006(DRS);
50-306/98006(DRS))
Dear Mr. Wadley:
This will acknowledge receipt of your letter dated June 25,1998, in response to our
letter dated May 26,1998, transmitting a Notice of Violation associated with work instructions
for placing secure tags and an inadequate procedure for electrical system transfer at the Prairie
Island Generating Plant. We have reviewed your corrective actions and have no further
questions at this time. These corrective actions will be examined during future inspections.
Sincerely,
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n A. Grobe, Director
ivision of Reactor Safety
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Docket Nos. 50-282; 50-306
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Enclosure:
Ltr dtd 6/25/98 Mr Wadley
Prairie Island to USNRC
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cc w/o encl:
Plant Manager, Prairie Island
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cc w/ encl:
State Liaison Officer, State
of Minnesota
State Liaison Officer, State
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of Wisconsin
Tribal Council
Prairie Island Dakota Community
DOCUMENT NAME: G:DRS\\PRA98006.TY
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Project-Mgr'NRR w/shcl
C. Paperiello, Rlli w/enci
J. Caldwell, Rlli w/ encl
B. Clayton, Rill w/ encl
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Northtrn statzs Power Company
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Prairie Island Nuclear Generating Plant
1717 Wakonade Dr. E.
Welch, MN 55089
June 25,1998
U S Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
PRAIRIE ISLAND NUCLEAR GENERATING STATION
Docket Nos. 50-282 License Nos. DPR-42
50-306
Response to Notice of Violation (Inspection Report 98006)
Your letter of May 26,1998, which transmitted Inspection Report No. 98006,
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required a response to a Notice of Violation. Our response to the notice is
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contained in the attachment to this letter.
In this response we have made three new NRC commitments as noted by bold
italics under Corrective Steps to Avoid Further Violations. If you have any questions
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concerning this response, please contact John Stanton at 612-388-1121 x4083.
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Joel P. Sorensen
Plant Manager
Prairie Island Nuclear Generating Plant
c:
Regional Administrator-lli, NRC
NRR Project Manager, NRC
Senior Resident inspector, NRC
State of Minnesota, Attn: Kris Sanda
J. E Silberg
Attachment
Response to Notice of Violation (Inspection Report 98006)
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Attachment
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Response to Notice of Violation (Inspection Report 98006)
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Violation 1:
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Criterion V of 10 CFR Part 50, Appendix B, requires, in part, that activities affecting quality shall
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be accomplished in accordance with instructions, procedures, or drawings.
Step 6.10.4.c.2.b of Administrative Work Instruction 3.10.0, " Control and Operations of Plant
Equipment," Revision 7, requires that qualified personnel shall check molded case circuit
breakers open by " testing dead" when applying a safety tag for the "off" position.
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Contrary to the above, on April 1,1998, the inspectors observed a plant operator hang a secure
tag associated with work order 9801216 on the #21 safety injection pump motor control center
breaker without performing a dead test as required.
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This is a Severity Level IV violation (Supplement 1).
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Reason for Violation 1:
Background Discussion --- The violation involved a situation not fully covered by the
AWI (Administrative Work Instruction). The secure tag associated with work order 9801216 was to be applied to a breaker that was already tagged in the "off" position. It
had already been tested " dead" for the other tag. Testing " dead" again would have
required a temporary lift of the original card in order to open the motor control center
door. It is not desirable to do this and, for this reason, the operators have been trained
to not perform a temporary lift but rather to note on the new tag the isolation number of
the previous card. The problem illustrated by this violation is that the AWI did not detail
the action to take in the event that the breaker had already been tested " dead" and
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rnalntained in that position as evidenced by a safety tag documenting a " dead" test.
Although the operator knew the correct approach to the situation from previous training,
this approach could not be supported by the existing AWI.
The cause of this violation was the discrepancy between the intent of the AWI and a strict
reading of the words of the AWIin this case where the AWI did not address the situation directly
confronted by the operator. The operator proceeded based upon prior training without
recognizing the discrepancy between the words of the AWI and the action being taken.
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Violation 1 - Corrective Actions Taken and Results Achieved:
SAWI 3.10.0, " Control and Operation of Plant Equipment" was revised by an Admin Control
Document Memorandum that details the action the operator is to take when a currently applied
safety tag documents a " tested dead" condition. The instruction now directs the operator to take
credit for the previous " dead" test by documenting the isolation number of the previous ccrd on
the " Test dead"line of the subsequent card.
Violation 1 - Corrective Steps To Avoid Further Violations:
Instruction 5AWI 3.10.0 is being reviewed to verify that there are not other similarpitfalls,
this review will be completed by September 30,1998.
As a short term action, a memo was issued to all plant personnel by the plant manager re-
emphasizing procedure adherence concems and the need to initiate procedure changes when
the procedure can't or shouldn't be performed as written.
Long term actions regarding improvements in the area of procedure adherence have been
initiated in response to earlier problems. These initiatives are considered to be still appropriate
to improve procedure adherence performance.
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Violation 1 - Date When Full Compilance Will Be Achieved:
Full compliance has been achieved.
Violation 2:
Criterion V, " Instructions, Procedures, and Drawings," of Appendix B of 10 CFR Part 50 requires
in part, that activities affecting quality be prescribed by documented instructions, procedures, or
{
drawings, cf a type appropriate to the circumstances.
Temporary memo 1997-0178, initiated October 31,1997, instructed operators to delete
Step 5.1.6.H.8 (for 1MA2) and Step 5.3.4.D.5 of procedure 1C20.8," Instrument AC distribution
System," Revision 9, until a modification for the transfer capability was completed. Step 5.1.H.8
provided instructions for operators to restore normal Unit 1 power to motor control center 1MA2
if necessary. Step 5.3.4.D.5 provided instructions for operators to transfer the power source
from Unit 2 to Unit 1 for motor control center 1MA2.
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Contrary to the above, the inspectors identified that during the period of November 10,1997,
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and April 7,1998, procedure 1C20.8 did not contain adequate instructions for transferring power
sources for motor control center 1MA2 since temporary memo 1997-0178 was still in effect. The
modification for the transfer was completed on November 10,1997, and the licensee did not
cancel the temporary memo.
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This is a Severity Level IV violation (Supplement 1).
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Reason for Violation 2:
The cause of this event was an inadequate review of the plant operating procedure status
associated with the modification prior to tumover for operation and failure to assign an expiration
date for the temporary memo consistent with expected completed of the plant modification.
Violation 2 - Corrective Actions Taken and Results Achieved:
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Temporary Memo 1997-0178 was deleted on April 8,1998 such that procedure 1C20.8,
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correctly identified the transferability of MCC 1MA2.
Violation 2 - Corrective Steps To Avoid Further Violations:
This violation will be reviewed by allpersonnel with plant design change Project
Engineer responsibilities to ensure they understand their responsibility associated with
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plant operating procedures when filling out form PINGP 1218, Turnover Checklist.
A new procedure temporary change process has been developed. Training on the new
process will be completed forplant staff prior to implementation. The training will review
this violation and stress the need to assign expiration dates for temporary changes that
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should be deleted by a specified date, for example, when a plant modification is expected
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to be completed.
The procedure temporary change process will be investigated to determine whether all active
temporary memos should be reviewed for continued applicability on a periodic basis.
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Violation 2 - Date When Full Compilance Will Be Achieved:
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Full compliance has been achieved.
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