ML20245L654
| ML20245L654 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/26/1989 |
| From: | Larson C NORTHERN STATES POWER CO. |
| To: | Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8907060030 | |
| Download: ML20245L654 (3) | |
Text
T h(
T o Northem States Power Company l
414 Nicollet Mall Minneapolis, Minnesota 55401 1927 i
Telephone (612) 330-5500 June 26, 1989 Mr E G Greenman, Director Division of Reactor Projects US Nuclear Regulatory Commission, Region III 799 Roosevelt Road
' Glen Ellyn, Illinois 60137 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Response to Notice of Violation RCIC Inoverability
References:
(a) Letter from Mr. E.G. Greenman, Director, Division of Reactor Projects, USNRC, " Notice of.
Violation" dated May 26, 1989.
(b) Licensee Event Report 89-006, " Technical Specification Violation Due to Inoperable High Pressure Injection Systems", May 15, 1989.
The purpose of this letter is to provide a writtes esponse to the Notice of Violation' enclosed in Reference (a).
Violation
' Technical Specification 6.5.C.3 states in part: " Detailed written procedures, including applicable check-off lists and instructions covering areas listed below shall be prepared and followed.
. The following maintenance and test I
procedures will be developed to satisfy routine inspection, preventive maintenance programs, and operating license requirements: preventive or i
corrective maintenance of plant and systems that could have an dfect on nuclear safety."
i Contrary to the above, Procedure 7140, Reactor Core Isolation Cooling (RCIC)
System Annual Instrument Maintenance Procedure, was inadequately prepared.
The procedure did not include: a time limit for the closure of RCIC steam line drain isolation valves, and precautions were not included for potential impact
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on this test procedure on RCIC operability.
This resulted in the inoperability of the RCIC system for approximately twenty-two hours on February 8, 1988 during performance of this test procedure, i
l This is a Severity Level IV violation.
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E G Greenman:
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- Resoonse A complete description of the circumstances surrounding the event was provided
~in Reference (b).
L Procedure 7140 was inadequate in the method used to test the RCIC steam line drain level switch..The procedure provided for testing of the level switch
- after the RCIC system was functionally tested and declared operable.
Additionally, no time limit was specified in the procedure for closure of the drain line isolation valves to limit the amount of time that condensation could buildup in the drain line.
Corrective Steos Which Have Been Taken and Results Achieved Test procedure 7140 (and the similar test for the HPCI level switch) was revised to: 1) perform the system operability test after the completion of the level switch test, and 2) limit the time that the steam line drain valve is closed.
Corrective Steps Which Will Be Taken to Avoid Further Violations
- 1) Maintenance and surveillance procedures will be reviewed and revised where necessary to insur6 that systems are not declared operable prior to completing the test and time limits are provided to avoid lsimilar situations.
Scheduled completion date: March 30, 1990.
- 2) Additional instructions on preparing maintenance and surveillance procedures will be added to Plant Administrative Work Instructions.
Scheduled completion date: August 30, 1989.
- 3) The lessons learned from this event will be covered in the Technical Staff Training program.
Scheduled completion date: December 31, 1989.
The Notice of Violation letter also requested actions to ensure operators are sensitive to the impact of test activities on equipment operability, and to ensure prudent actions to fix unreliable equipment are implemented promptly.
The following two actions are provided in response to this request:
- 4) The lessons learned i' rom this event including impact of testing
)
on equipment operability will be covered in the Licensed Operator I
Continuing Training Program.
Scheduled completion date: December 31, 1989 f
i
- 5) A weekly management review of safety related equipment work request
]
authorizations will be initiated to ensure prompt actions in repairing i
safety related equipment. Scheduled completion date: July 30, 1989.
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I Nodhem States Power Company E G Greenman June 26, 1989 Page 3 1
Date When Full Compliance Will Be Achieved An administrative HOLD was applied to procedure 7140 immediately following the event. The procedure was permanently revised on May 11, 1989 to require all testing to be complete before declaring system operable and to provide a time limit on isolating the drain line. The procedure is in full compliance with Technical Specifications.
i l
l Please contact us if you have any questions relating to our response to this violation.
4 C E Larson Vice President Nuclear Generation c: Regional Administrator - III, NRC NRR Project Manager, NRC Resident Inspector, NRC C Charnoff
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