February 20, 2001

EA-00-282

Mr. J. Sorensen

Site General Manager

Prairie Island Nuclear Power Plant

Nuclear Management Company, LLC

1717 Wakonade Drive East

Welch, MN 55089

SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND

NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-282/00-13 (DRS);

50-306/00-13 (DRS))

Dear Mr. Sorensen:

The purpose of this letter is to provide you with the final results of our significance

determination analysis of the inspection finding, identified in the subject inspection report,

involving inadequate design control for the deep draft cooling water (service water) pumps.

The inspection finding was assessed using the Significance Determination Process (SDP) and

was initially characterized as a Yellow finding (i.e., an issue with substantial importance to

safety that will result in additional NRC inspection and potentially other NRC action). However,

as stated in our letter to you dated February 12, 2001, we identified an error in the NRC’s initial

Phase 3 analysis of the finding. Upon re-analysis of the finding, we have determined the

finding should be characterized as a White finding (i.e., an issue with low to moderate

increased importance to safety).

During our recent conversation, you declined the opportunity to discuss the NRC’s risk

characterization of this finding during a regulatory conference. Consequently, after considering

the information developed during the inspection, the NRC has concluded that the inspection

finding is appropriately characterized as a White finding, which may require additional NRC

inspections. You have 10 business days from the date of this letter to appeal the staff’s

determination of significance for the identified White finding. Such appeal will be considered to

have merit only if it meets the criteria given in NRC Inspection Manual Chapter 0609,

Supplement 3.

The NRC has also determined that the failure to assure that the original cooling water pump

lubricating water filter backwash systems were provided with electrical power from a vital bus

and the failure to maintain a safety-related quality standard for the cooling water pump

lubricating water supply following a 1977 design change modification was a violation of 10 CFR

Part 50, Appendix B, Criterion III, “Design Control,” as cited in the enclosed Notice of Violation

(Notice). The circumstances surrounding the violation are described in detail in the subject
J. Sorensen -2-

inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, Revision 1,

the Notice is considered an escalated enforcement action because it is associated with a White

finding.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

Because plant performance for this issue has been determined to be in the Regulatory

Response Band, we will use the NRC Action Matrix to determine the most appropriate NRC

response for this finding. We will notify you, by separate correspondence, of that

determination.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/ RA /

John A. Grobe, Director

Division of Reactor Safety

Docket No. 50-282, 50-306

License No. DPR-42, DPR-60

Enclosure: Notice of Violation

See Attached Distribution
J. Sorensen -3-

cc w/encl: Plant Manager, Prairie Island

M. Wadley, Chief Nuclear Officer

G. Eckholt, Site Licensing Manager

S. Northard, Nuclear Asset Manager

J. Malcolm, Commissioner, Minnesota

Department of Health

State Liaison Officer, State of Wisconsin

Tribal Council, Prairie Island Dakota Community

J. Silberg, Esquire

Shawn, Pittman, Potts, and Trowbridge

P. Tester, Assistant Attorney General

Minnesota Office of Attorney General

S. Bloom, Administrator

Goodhue County Courthouse

Commissioner, Minnesota Department

of Commerce
J. Sorensen -2-

inspection report. In accordance with the NRC Enforcement Policy, NUREG-1600, Revision 1,

the Notice is considered an escalated enforcement action because it is associated with a White

finding.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. The NRC will use your response, in part, to

determine whether further enforcement action is necessary to ensure compliance with

regulatory requirements.

Because plant performance for this issue has been determined to be in the Regulatory

Response Band, we will use the NRC Action Matrix to determine the most appropriate NRC

response for this finding. We will notify you, by separate correspondence, of that

determination.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and

its enclosure will be available electronically for public inspection in the NRC Public

Document Room or from the Publicly Available Records (PARS) component of NRC's

document system (ADAMS). ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room).

Sincerely,

/ RA /

John A. Grobe, Director

Division of Reactor Safety

Docket No. 50-282, 50-306

License No. DPR-42, DPR-60

Enclosure: Notice of Violation

See Attached Distribution

DOCUMENT NAME: C:\Pra NOV00-13DRS.wpd

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE R-III R-III R-III R-III R-III

NAME KO’Brien:jb RGardner RLanksbury KLambert for

BClayton

JGrobe

DATE 02/ 15 /2001 02/ 20 /2001 02/ 20 /2001 02/ 20 /2001 02/ 20 /2001

OFFICIAL RECORD COPY
J. Sorenson -3-

cc w/encl: Plant Manager, Prairie Island

M. Wadley, Chief Nuclear Officer

G. Eckholt, Site Licensing Manager

S. Northard, Nuclear Asset Manager

J. Malcolm, Commissioner, Minnesota

Department of Health

State Liaison Officer, State of Wisconsin

Tribal Council, Prairie Island Dakota Community

J. Silberg, Esquire

Shawn, Pittman, Potts, and Trowbridge

P. Tester, Assistant Attorney General

Minnesota Office of Attorney General

S. Bloom, Administrator

Goodhue County Courthouse

Commissioner, Minnesota Department

of Commerce

ADAMS Distribution:

CMC1

DFT

TJK3 (Project Mgr.)

J. Caldwell, RIII

G. Grant, RIII

B. Clayton, RIII

SRI Prairie Island

C. Ariano (hard copy)

DRP

DRSIII

PLB1

JRK1

BAH3
NOTICE OF VIOLATION

Nuclear Management Company, LLC Docket No.(s) 50-282 and 50-306

Prairie Island Nuclear Power Plant License No.(s) DPR-42 and DPR-60

EA-00-282

During an NRC baseline inspection completed on November 3, 2000, a violation of NRC

requirements was identified. In accordance with the "General Statement of Policy and

Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Title 10 of the Code of Federal Regulations, Part 50, Appendix B, Criterion III, “Design

Control,” requires, in part, that design control measures shall verify the adequacy of

design and shall assure that appropriate quality standards are specified.

General Design Criteria 38, “Reliability and Testability of Engineered Safety Features,”

dated July 1967, required, in part, that all engineering safety features, and support

systems such as the cooling water system, shall be designed to provide high functional

reliability.

General Design Criteria 39, “Emergency Power for Engineering Safety Features,” dated

July 1967, required, in part, onsite power systems shall be provided and designed with

adequate independency, redundancy and capability to permit the functioning required of

the engineered safety systems, and support systems such as the cooling water system,

assuming a single failure.

Contrary to the above, as of November 3, 2000:

A. The licensee did not verify that the original design provided adequate

independence, redundancy, or capability for the Units 1 and 2 cooling water

pump lubricating water filter backwash systems. Specifically, the licensee did

not verify that the original design provided safety related electrical power from a

vital bus to these systems to assure continued functionality, assuming a single

failure.

B. The licensee did not maintain a quality standard for the cooling water pump

lubricating water filter backwash systems, consistent with its safety related

function. Specifically, a 1977 safety evaluation incorrectly reduced the

classification of the drive shaft bearing lubricating water supply from safety

related to non-safety related.

This violation is associated with a White SDP finding.

Pursuant to the provisions of 10 CFR Part 2.201, Nuclear Management Company is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the

Regional Administrator, Region III, and a copy to the NRC Resident Inspector at the facility that

is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of

Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and

should include for each violation: (1) the reason for the violation, or, if contested, the basis for

disputing the violation or severity level, (2) the corrective steps that have been taken and the
results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4)

the date when full compliance will be achieved. Your response may reference or include

previous docketed correspondence, if the correspondence adequately addresses the required

response. If an adequate reply is not received within the time specified in this Notice, an order

or a Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response, with

the basis for your denial, to the Director, Office of Enforcement, United States Nuclear

Regulatory Commission, Washington, DC 20555-0001.

Because your response will be made available electronically for public inspection in the NRC

Public Document Room or from the Publicly Available Records (PARS) component of NRC’s

document system (ADAMS), to the extent possible, it should not include any personal

privacy, proprietary, or safeguards information so that it can be made available to the

public without redaction. ADAMS is accessible from the NRC Web site at

http://www.nrc.gov/NRC/ADAMS/index.html (the Public Electronic Reading Room). If personal

privacy or proprietary information is necessary to provide an acceptable response, then please

provide a bracketed copy of your response that identifies the information that should be

protected and a redacted copy of your response that deletes such information. If you request

withholding of such material, you must specifically identify the portions of your response that

you seek to have withheld and provide in detail the bases for your claim of withholding (e.g.,

explain why the disclosure of information will create an unwarranted invasion of personal

privacy or provide the information required by 10 CFR Part 2.790(b) to support a request for

withholding confidential commercial or financial information). If safeguards information is

necessary to provide an acceptable response, please provide the level of protection described

in 10 CFR Part 73.21.

In accordance with 10 CFR Part 19.11, you may be required to post this Notice within two

working days.

Dated this 20th day of February 2001