L-PI-09-104, Response to an Apparent Violation in Inspection Report No. 05000282-09-012 (Drs); 05000306-09-012 (Drs); EA-09-193

Response to an Apparent Violation in Inspection Report No. 05000282-09-012 (Drs); 05000306-09-012 (Drs); EA-09-193

ML092730533
Person / Time
Site:	Prairie Island
Issue date:	09/30/2009
From:	Schimmel M Northern States Power Co, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-09-193, IR-09-012, L-PI-09-104
Download: ML092730533 (3)

Text

'@ Xcel Energym SEP 3 0 2009 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Response to an Apparent Violation in Inspection Report No. 0500028212009012~DRS);

05000306/2009012(DRS)~EA-09-193 The Northern States Power Company, a Minnesota corporation (NSPM), is submitting the response to the apparent violation contained in NRC Inspection Report 05000282/2009012(DRS);05000306/2009012(DRS)for the Prairie Island Nuclear Generating Plant (PINGP). Enclosure 1 to this letter contains the station's response.

NSPM accepts the fact that the violation, as cited, occurred. NSPM fully recognizes the importance of providing complete and accurate information to the NRC at all times.

NSPM has taken significant actions to strengthen our confidence in the completeness and accuracy of future submittals.

Summaw of Commitments This letter contains no new commitments and no revisions to existing commitments.

Mark A. ~ c h i m m e l Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc: Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC 1717 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1121

ENCLOSURE 1 Response to an Apparent Violation in lnspection Report No.

0500028212009012(DRS); 0500030612009012(DRS); EA-09-193 The Northern States Power Company, a Minnesota corporation (NSPM), is providing the response to the apparent violation contained in NRC Inspection Report 05000282/2009012(DRS);05000306/2009012(DRS)for the Prairie Island Nuclear Generating Plant (PINGP).

Apparent Violation:

On May 11, 2009, while reviewing an application to incorporate a medical restriction into a senior reactor operator's (SRO) license, an NRC inspector identified that Prairie Island Nuclear Generating Plant (PINGP) had provided incomplete and inaccurate information to the NRC when a license renewal was requested for the SRO in May 2007. The issue was considered to be of very low safety significance, but was considered to have important regulatory significance because the information was provided to the NRC under a signed statement and results in a licensing action that would not have been taken had complete and accurate information been provided to the NRC. This was an apparent violation of 10 CFR 50.9, "Completeness and Accuracy of Information."

Because the issue affected the NRC's ability to perform its regulatory function, it was evaluated using the traditional enforcement process. The finding was determined to be of low safety significance because the licensed operator had taken medications as prescribed and had not made errors during any emergency condition prior to the license being amended.

However, the regulatory significance was important because the incomplete and inaccurate information was provided under a signed statement to the NRC and impacted a licensing decision for the licensed operator. This was preliminarily determined to be an apparent violation of 10 CFR 50.9, "Completeness and Accuracy of Information." No cross-cutting element for this finding was assigned. This appears to be a misunderstanding of NRC reporting requirements since they changed in January 2006 and is not reflective of current plant standards or processes in this area.

(1) Reason for the Apparent Violation The reason for the apparent violation is that, in 2007 when the initial failure to add the restriction was made, the station had not yet incorporated the revised 2006 NRC Form 396 reporting requirements into the applicable processes and procedures.

(2) Corrective Steps That Have Been Taken and the Results Achieved The station has completed the following actions:

Prior to this violation, FP-T-SAT-74, "NRC Operator License Application and Renewal Requirements" had been revised to incorporate the revised 2006 NRC Form 396 reporting requirements.

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The event that led to this violation was reviewed against the current procedural requirements in effect to determine if additional changes were required. It was concluded that the current process incorporated in FP-T-SAT-74 is sufficient to eliminate this category of licensing error.

A review was conducted to validate that all operator license renewals after the 2006 change had appropriate restrictions placed on their licenses. This review concluded that all license renewals since the 2006 change included the appropriate restrictions.

A review was conducted to validate that all operator license amendments submitted after the 2006 change included all appropriate restrictions. This review concluded that all license amendments since the 2006 change included all appropriate restrictions.

A review of a recent Monticello root cause evaluation involving incomplete information sent to the NRC on an operator's license renewal application was conducted to determine if the corrective actions put in place will prevent similar violations from occurring which would indicate this is a legacy issue, and to determine if any new corrective actions are required. It was concluded that the changes made to FP-T-SAT-74 as a result of the Monticello root cause provided further enhancement to the process, that no additional corrective actions are necessary, and this violation does not reflect current performance in this area.

(3) Corrective Steps That Will Be Taken to Avoid Further Violations None.

(4) Date When Full Compliance Will be Achieved:

The station is in full compliance with the requirements. Full compliance was achieved on May I,2009 when NSPM submitted the corrected NRC Form 396 for the SRO license in question. The NRC issued the amended license on May 20, 2009.

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