ML20147B421
| ML20147B421 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 01/27/1997 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9701310328 | |
| Download: ML20147B421 (6) | |
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4 Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 1
January 27,1997 10 CFR Part 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 l
50-306 DPR-60 Reply to Notice of Violation (Inspection Report 96014),
Discrepancies in Diesel Generator Surveillance Testing Your letter of December 27,1996, which transmitted Inspection P.eport No. 96014, required a response to a Notice of Violation. Our response to the violation is contained in the attachment to this letter.
In this response we have made four new Nuclear Regulatory Commission commitments:
A pilot process for the improvement of surveillance procedure revisions is being developed and will be implemented by March 1,1997, This process will then be evaluated and if beneficial, it will be fully incorporated by e
December 31,1997.
A consulting firm will perform an Operations Department Performance Assessment.
Corrective actions from the assessment's root cause analysis will be determined by April 1,1997 and implemented by December 31,1997.
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9701310328 970127 POR ADOCK 05000282 G
i USNRC NORTHERN STATES POWER COMPANY January 27,1997 Page 2 Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions related to this letter.
/22 Y)0LON Michael D Wadley Plant Manager Prairie Island Nuclear Generating Plant i
c:
Regional Administrator - Region Ill, NRC Senior Resident inspector, NRC NRR Project Manager. NRC J E Silberg
Attachment:
RESPONSE TO NOTICE OF VIOLATION I
IR96014. DOC
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i RESPONSE TO NOTICE OF VIOLATION i
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VIOLATIOtti t
j Technical Specification 6.5.A.4 required that detailed written procedures covering j
surveillance and testing requirements that could have an effect on nuclear safety
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i shall be prepared and followed. Surveillance Procedure SP 1305, "D2 Diesel Generator Slow Start Test," revision 13, was one procedure prepared in L
accordance with that specification.
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- Contrary to the above, on October 30,1996, SP 1305 was not followed in that licensee operators failed to perform steps 7.67.3 and 7.67.4 to ensure the diesel i
engine would not start during an air roll.
This is a Severity Level IV Violation (Supplement I).
l RESPONSE TO VIOLATION 1 i
l Reason for the Violation i
The procedure for the air roll of the Unit 1 diesel generators included time limits to complete performance due to the logic used to prevent engine start. These time limits i
were felt by the operators in the engine room as very constraining and this feeling l
contributed to improper performance of these steps which resulted in the engine l
starting. Lack of co-ordination of the performance of these procedure steps by the assigned operators also contributed to this event.
Corrective Steos Take n and Results Achieved The diesel was shutdown. The air roll was subsequently performed per the procedure by the same two operations personnel.
Corrective Steos That Will Be Taken To Avoid Further Violations:
1 The Surveillance Procedures SP 1305 and SP 1093 have been revised to place the diesel generator START /STOP CS in " PULLOUT" to energize the shutdown solenoid before performing the air roll portion of the procedures. After completing the air roll the i
CS is returned to the " NEUTRAL" position. This method ensures the engine will not start without putting time constraints on the steps performed locally at the engine. The procedure revisions have been completed. Operations shift management has reinforced expectations with operators regarding coordination of procedere steps and I
communications. Additionally, Operations shift management has been. asked with i
ensuring that self-checking techniques are demonstrated in all tasks performed by Operations personnel.
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Attachment
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January 27,1997 l
Page 2 1
i Northern States Power Co. management is also very concerned about improper actions i
during the performance of surveillance and testing. Actions being taken to understand and reverse this negative trend fall into the two broad areas of Surveillance Procedures j
and Operator Performance, j
Actions in the area of Surveillance Procedures include more system engineer field j
observations of surveillance and testing performed by operators to help identify procedure enhancements. This management expectation is being implemented.
Additionally, improvements in the surveillance procedure revision process are being i
developed to ensure incorporation of consistent writers' guide requirements, operator user review, and operator training. Process improvements have been identified and a phot process has been developed. The pilot process will be implemented by March 1, 1997, and evaluated for full incorporation by year end.
in the area of Operator Performance, FPI International has been contracted to perform j
an Operations Department Performance Assessment. In Phase 1 of this assessment a Common Cause Analysis (CCA) of all recent Operations performance issues is conducted. This CCA is then used to identify underlying Organizational &
Programmatic (O&P) issues, including management issues, responsible for past events and conditions. As such, these O&P issues are global in nature and cannot be identified by an assessment of a single event. Phase 1 has been completed. The majority of inappropriate actions identified in Phase 1 were associated with
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unintentional slips or lapses versus decision making errors; occurred during simple versus complex activities; and occurred during both frequently and infrequently performed activities. These facts obtained from Phase 1 are used to prioritize and guide the investigation efforts of Phase 2. Phase 2 will confirm the issues identified in Phase 1 and determine the root cause(s) and most effective corrective actions. In Phase 2 a global Operations Quality index will be determined, the effectiveness of Management i
Control Loop in the Operations organization will be evaluated, a Human Error i
Propensity Index will be determined, and the capabilities of the Operations organization in the detection and correction of performance issues will be assessed through interviews, field observations, and surveys. Corrective actions from this root cause
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analysis will be determined by April 1,1997 and implemented by year end.
j The Date When Full Comoliance Will be Achieved:
Full compliance has been achieved.
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4 Attachment January 27,1997 Page 3 VIOLATION 2 i
l Technical Specification 3.7.B.1 required, in part, that during startup or power operation, one diesel generator may be inoperable for 7 days provided that operability of the other diesel generator is demonstrated by performance of surveillance requirement 4.6.A.1.e within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. That requirement applied i
unless the diesel generator was inoperable due to pre-planned preventive l
maintenance or testing.
Contrary to the above, on November 14,1996, while Unit 2 was operating at full power, the D5 diesel generator was declared inoperable due to a problem with its l
ventilation system. Surveillance requirement 4.6.A.1.e was not performed to demonstrate operability of the redundant D6 diesel generator.
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This is a Severity Level IV Violation (Supplement 1).
RESPONSE TO VIOLATION 2 Reason for the Violation The. Operations Committee initially focused on the operability of the redundant diesel generator support ventilation. Based on the information from the investigation into the l
ventilation system problems for DS, the committee concluded that there was no j
common mode failure potential with the redundant diesel generator (D6) support ventilation.
1 Since the non-common mode failure was evident without performing the actions of TS 3.7.B.1, the committee concluded that there would be no overall nuclear safety benefit i-from running the redundant diesel per TS 3.7.B.1.
In the committee's evaluation of the Technical Specification and its intent, the Technical Specification Bases and information contained in the improved Standard Technical j
Specifications were reviewed. This supported the committee's conclusion that, since the inoperability of DS Diesel Generator clearly did not affect both diesel generahrs, i
there was no need to run the redundant diesel generator, i'
The committee inappropriately based its conclusion on comparison of Imp, roved Standard Technical Specifications and its Bases and the Prairie island Technical Specifications Bases and lost focus on the Prairie Island Technical Specification wording.
i IR96014. DOC i
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Attachment January 27,1997 Page 4 l
Corrective Steos Taken and Results Achieved As discussed in the Inspection Report, the cause of the inoperable ventilation system for DS Diesel Generator was identified and repaired the same day and it was determined that the same condition did not exist in the D6 Diesel Generator. Following discussions with the NRC resident inspectors, the Operations Committee was informed 1
ofits misinterpretation of the Technical Specification.
C_orrective Steos That Will Be Taken To Avoid Further Violations
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A letter was sent to all Prairie Island superintendents, supervisors, and system 2
engineering personnel that made it clear what Prairie Island's obligations are regarding diesel generator testing per TS 3.7.B.1.
i The Operations Committee has been reminded that to deviate from Technical Specifications requires NRC approval and that it is inappropriate to change the actual l
requirements of the Technical Specifications by interpretation.
3 The Date When Full Comoliance Will be Achieved i
Full compliance has been achieved.
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l IR96014. DOC "t
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