ML20249C666
| ML20249C666 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/25/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-282-98-06, 50-282-98-6, 50-306-98-06, 50-306-98-6, NUDOCS 9806300560 | |
| Download: ML20249C666 (4) | |
Text
_
Northern states Power Company l
I Pralrie Island Nuclear Generating Plant 4
4 1717 Wakonade Dr. E.
Welch, MN 55089 i
June 25,1998 10 CFR Part 2 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 DPR-60 Response to Notice of Violation (Inspection Report 98006)
Your letter of May 26,1998, which transmitted inspection Report No. 98006, i
required a response to a Notice of Violation. Our response to the notice is 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 nave any questions cancerning this response, please contact John Stanton at 612-388-1121 x4083.
l i
f' Joel P. Sorensen Plant Manager Prairie Island Nuclear Generating Plant c:
Regional Administrator-lli, NRC NRR Project Manager, NRC Senior Resident inspector, NRC 1
State of Minnesota, Attn: Kris Sanda J. E Silberg Attachment Response to Notice of Violation (Inspection Report 98006) 9806300560 990625 PDR ADOCK 05000282 G
PDR j
Attachment Response to Notice of Violation (Inspection Report 98006) t i
Violation 1:
Criterion V of 10 CFR Part 50, Appendix B, requires, in part, that activities affecting quality shall 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 Pla 1t 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.
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.
This is a Severity Level IV violation (Supplement 1).
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" aga!n 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 maintained 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 supoorted by the existing AWI.
The cause of this vio!ation 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.
Attachm nt l
Pags 2 j
i l
Violation 1 - Corrective Actions Taken and Results Ach:eved:
SAWi 3.10.0, " Control and Operation of Plant Equipment" was revised by an Admin Control Document Memorandum that details the action the operatoris 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 card 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 concerns and the need to initiate proceduro 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 esponse to earlier problems. These initiatives are considered to be still appropriate to improve procedure adherence performance.
Violation 1 - Date When Full Compliance 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, of 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 modificatica for the transfer capability was conipleted. 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.
Contrary to the above, the inspectors identified that during the period of November 10,1997, and April 7,1998, procedure 1C20.8 did not conta:n adequate instructions for transferring power sources for motor control center 1MA2 since temporary memo 1997-0178 was stillin effect. The modification for the transfer was completed on November 10,1997, and the licensee did not cancel the temporary memo.
Attachmsnt
]
Paga 3 This is a Severity Level IV violation (Supplement 1).
l Reason f,
, Violation 2:
The cause of this event was an inadequate review of the plant operating procedure status associand with the modification prior to turnover 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:
l Temporary Memo 1997-0178 was deleted on April 8,1998 such that procedure 1C20.8, correctly identified the transferability of MCC 1MA2.
Violation 2 - Corrective Steps To Avoid Further Violations:
1 This violation will be reviewed by all personnel with plant design change Project Enginear responsibilities to ensure they understand their responsibility associated with 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 should be deleted by a specified date, for example, when a plant modification is expected 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.
Violation 2 Date When Full Compilance Will Be Achieved:
Full compliance has been achieved.
1
-