IR 05000282/1996010

Insp Repts 50-282/96-10 & 50-306/96-10 on 960830-1008. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering & Plant Support Performed by Resident Inspectors

ML20134J443
Person / Time
Site:	Prairie Island
Issue date:	11/05/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134J395	List: IR 05000282/1996010 ML20134J392 ML20134J416
References
50-282-96-10, 50-306-96-10, NUDOCS 9611150213
Download: ML20134J443 (18)

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U.S. NUCLEAR REGULATORY COMISSION

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REGION III

Docket Nos:

50-282, 50-306 License Nos: DPR-42, DPR-60 i

i Report No:

50-282/96010; 50-306/96010 Licensee:

Northern States Power Company i

l Facility:

Prairie Island Nuclear Generating Plant j

i Location:

1717 Wakonade Drive East Welch, MN 55089 Dates:

August 30 - October 8, 1996 Inspectors:

S. Ray, Senior Resident Inspector R. Bywater, Resident Inspector Approved by:

B Jorgensen, Acting Chief, Projects Branch 7 Division of Reactor Projects i

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9611150213 961105 PDR ADOCK 05000282 G

PDR u

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EXECUTIVE SUMARY i

Prairie Island Nuclear Generating Plant, Units 1 & 2

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NRC Inspection Report 50-282/96-10,50-306/96-10

' This inspection included aspects of licensee operations, maintenance, engineering, and plant support performed by the resident inspectors.

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Operations l

The inspectors found the auxiliary feedwater system to be in good e

material condition.

(Section 02.1)

e The Safety Audit Committee (SAC) activities were observed to be in accordance with Technical Specifications. Technical discussions during a i

SAC meeting were thorough and candid.

(Section 08.3)

Maintenance e

Most observed maintenance and surveillance activities were well conducted with good' communications, proper planning, and safe work practices.

Electricians performing one surveillance identified several procedural enhancements..(Section M1.1)

e An error by a relatively inexperienced reactor operator during a surveillance resulted in an automatic start of a component cooling water pump.

(Section M1.2)

e The inspectors identified that required quarterly testing of two check valves in the chemical feed system had not been adequately performed for about'two years because test pressure gauges were isolated.

Weaknesses in configuration control and an inadequate questioning attitude by operators contributed to the problem.

(Section M3.2)

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During performance of a diesel breaker surveillance, the licensee identified that-the procedure was inadequate.

(Section M3.3)

Enaineerina e

The inspectors identified an error in an Updated Safety Analysis Report (USAR) drawing. The inspectors determined that the licensee was already aware of the error.

(Section E2.1)

Plant Supoort e

The inspectors determined that the material condition of the normally inaccessible spent resin storage tank room and the low level gas decay tank room was excellent.

(Section R2.1)

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l Report Details Summary of Plant Status

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Both units operated at or near full power for the entire inspection period.

During this period, the fifth dry spent fuel storage cask was inspected and prepared for loading.

l I. Doerations

Conduct of Operations 01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of plant operations.

In general, the conduct of operations was acceptable. However, operator performance during surveillance testing was a concern as discussed in Section M1.2 and M3.2 of this report.

Operational Status of Facilities and Equipment 02.1 Enaineerina Safety Feature System Walkdowns a. Insoection Scone (71707. 92903)

The inspectors used Inspection Procedures 71707 and 92903 to walk down selected portions of the auxiliary feedwater system. Updated Safety Analysis Report (USAR) Section 11.9, " Condensate, Feedwater and Auxiliary Feedwater Systems," revision 12, was reviewed as part of this inspection.

b. Observations and Findinas

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The system was found to be in good material condition.

No discrepancies were noted between system operation and the USAR description. On September 17, 1996, the #12 auxiliary feedwater pump to #12 steam generator throttle valve, MV-32382, failed to stroke during a surveillance test.

The inspectors observed the troubleshooting and repair of the valve. Although a definitive cause was not determined, a corrosion film on the torque switch contacts was thought to be the cause of the failure.

The valve was repaired and satisfactorily tested. All the other throttle valves in the system worked normally.

c. Conclusions No significant issues were identified.

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Miscellaneous Operations Issues s

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08.1 (Closed) Inspection Followun Item (IFI) 306/96002-03: Failure to Recognize Closed Control Valve During Power Change.

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i a. Insoection Scope (92701)

i This issue was discussed in Inspection Report 282(306)/96002, Section 1.6.

It involved operators failing to notice a deviation between actual

control valve position and programmed position during a power change when turbine control valve CV-4 failed closed. The inspectors reviewed

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i Operating Procedures 101.4, " Unit 1 Power Operation," revision 13, and j

2C1.4, " Unit 2 Power Operation," revision 13, as part of this inspection.

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b. Observations and Findinas

i Corrective actions included temporary procedure changes to direct i

operators to check control valve positions during power changes. These j

temporary changes were later replaced by permanent revisions (101.4 and

2.C1.4, revision 13).

In addition, figures showing the programmed

control valve positions versus power level were permanently attached to the control board at the turbine control station. The licensee also

issued work orders to add alarms to the Emergency Response Computer

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System to indicate when any turbine control valves deviate from the programmed positions.

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The inspectors verified that corrective actions were completed and

concluded that they should be sufficient'to prevent recurrence of the event.

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08.2 (Closed) IFI 282/96008-06:

Concerns with Technical Specification Interpretation.

l a. Inspection Scone (92901)

i This issue was discussed in Inspection Report 282(306)/96008, Section

M3.1.

During this inspection period, the licensee submitted an amendment

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request to change the Technical Specifications to allow the option of not i

realigning the "121" motor-driven cooling water pump for safeguards operation when one of the diesel-driven cooling water pumps was

inoperable. The inspectors reviewed the request dated September 11, 1996, and the licensee's Technical Specification Interpretation (TSI)

3.3-15, " Cooling Water System - Safeguards Cooling Water Pump Alignment and Operability," revision 0, as part of this inspection.

b. Observations and Findinas The inspectors had some concerns with the amendment request which were passed on to the licensee and the NRC reviewer.

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One concern was that the Determination of Significant Hazards i

Consideration section of the amendment request appeared to primarily

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compare the hazards of the proposed amendment to the configuration the i

plant was licensed to several years ago, before the modification which

upgraded the 121 cooling water pump. The hazards of the amendment

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request did not appear to be adequately compared to the current configuration.

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A second concern was that the amendment request stated that the TSs, as

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currently written, required the 121 cooling water pump to be placed in l

service any time one of the diesel-driven cooling water pumps was i

inoperable. However, TSI 3.3-15 stated that the licensee may elect not

to place the 121 pump in service as a safeguards pump. The licensee's l

position in the amendment request and the interpretation appeared to be in conflict.

The above inspector concerns would be addressed during the NRC review of

the amendment request and thus additional inspector followup was not i

required.

i A third concern was that neither the TSI nor the amendment request _

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contained sufficient guidance to operators on'whether it was preferable to realign the 121 pump or enter the 7-day limiting condition for operation with a diesel-driven pump inoperable. There was no guidance on the consideration of the relative risks of the two actions.

However, paragraph (a)(3) of 10 CFR 50.65 (The Maintenance Rule) provided NRC

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expectations that, prior to removing equipment from service, the licensee should conduct an assessment of the total plant equipment that is out-of-service to determine the overall effect on performance of safety functions. A separate NRC inspection (Report No. 282(306)/96012) of the-licensee's implementation of the Maintenance Rule addresses this inspector concern.

c. Conclusions Although inspector concerns remained regarding the issue, they will be dealt with through the license amendment request review process.

08.3 Review of Saf.ety Audit Committee (SAC) Activities a. Insoection ScgRL!iOlQQ.).

The inspectors observed the SAC meeting at the Prairie Island site on September 19, 1996. The inspectors also reviewed the meeting final agenda and a compilation of questions for meeting presenters-submitted in advance of the meeting by SAC members.

b. Observations and Findinas Requirements of the SAC were contained in TS 6.2.

The inspectors observed that membership, quorum, and meeting frequency requirements were met for the meeting. The inspectors also verified that each subject

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l required to be reviewed by the SAC as delineated in TS 6.2.A.5 were j

discussed in the meeting.

Discussions during the meeting were led by licensee staff members most familiar with the issues. Discussions were thorough and candid.

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Questions by the SAC members were either resolved or scheduled for j

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further discussion at the next meeting.

In this meeting, the SAC made no j

j recommendations to the Vice President Nuclear Generation.

c. Conclusions

'I The inspectors determined that the SAC activities observed adequately met J

the TS requirements.

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j II. Maintenance i

M1 Conduct of Maintenance

j M1.1 General Comments

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l a. Inspection Scope (61726. 62707)

The inspectors observed all or portions of the following maintenance

and surveillance activities.

Including in the inspection was a i

i review of the surveillance procedures (SP) or work orders (WO)

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activities.

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e SP 1130 Containment Vacuum Breakers, revision 27 l

e WO 9609013' Troubleshoot 2B Starting Air Compressor on D5 i

Emergency Diesel Generator

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e SP 1095 Bus 16 Load Sequence Test, revision 8

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WO 9609167 Repair MV 32382, #12 Auxiliary Feedwater Pump to #12 i

Steam Generator Throttle Valve

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WO 9609100 Measure and Adjust Annunciator Sound Level o

SP 1355 Checking Chemical Feed and Auxiliary Feedwater Check

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Valves - Unit 1, revision 6

.e SP 1306 D2 Diesel Generator Functional Test i

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e For SP 1095, the inspectors observed that the electricians performing the surveillance identified several procedural F

enhancements and submitted recommended changes. The

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inspectors noted that SP 1095 could be adequately performed

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e For SP 1355, the operators performing the surveillance promptly

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informed the shift supervisor of each section of the surveillance

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that had failed to meet.the acceptance criteria or for which the

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data was inconclusive. Additional discussions regarding this surveillance are contained in Section M3.2 of this report.

e SP 1306, which had been recently revised, proved inadequate as written. This is discussed further in Section M3.3.

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c. Conclusions l

Most observed maintenance and surveillance activities were well conducted with good communications, proper planning, and safe work practices. An

exception, where operators failed to demonstrate a questioning attitude, l

is discussed in Section M3.2.

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M1.2 Doerator Error Durina Surveillance i

i a. Inspection Scone (92700)

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f On September 7,1996, while performing a surveillance on the residual heat removal system pumps, an error by a reactor operator resulted in the automatic actuation of an engineered safety feature system. The j

inspectors reviewed the circumstances of the event. The inspectors also

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reviewed Surveillance Procedure SP 1089, " Residual Heat Removal Pumps and i

Suction Valves from the Refueling Water Storage Tank," revision 41, and l

Licensee Event Report (LER) 282(306)/96-16, " Auto-start of No. 11 l

Component Cooling Water Pump Due to Personnel Error," revision 0, as part j

of this inspection.

l b. Observations and Findinas i

i The surveillance required the operator to start the standby component i

cooling (CC) pump during a portion of the test. Step 7.3.17 of the

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procedure directed the operator to return the CC pumps to normal as j

directed by the shift supervisor. At the end of SP 1089, he was directed

to stop the #11 CC pump. A note before step 7.3.17 warned the operator j

that when stopping a CC pump, ensure the CC system stabilizes prior to

releasing the start /stop switch to prevent an inadvertent automatic restart.

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The reactor operator performing the surveillance was newly licensed and was unfamiliar with the amount of time required for the system to

i stabilize. He held the switch in the stop position for 2 1/2 seconds, j

according to the sequence of events recorder, and then released it.

However, system flow and pressure had not yet stabilized, resulting in an automatic restart of the #11 CC pump on low system pressure.

Later, the operator properly stopped the pump. The licensee reported the event to the NRC in accordance with 10 CFR 50.72 and issued LER 282(306)/96-16 as a followup. Corrective actions included reinforcing the proper use of the procedure with the operator.

In addition, the licensee installed caution labels on the control boards providing

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guidance on stopping the component cooling water pumps. The LER is j

closed in Section N8.6 of this report.

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c. Conclusions

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'The inspectors concluded that the automatic start of the CC pump was an.

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j unnecessary challenge to the system, but was not safety significant. The i

system performed as designed. Technical Specification 6.5.A.4 required,

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in part, that detailed written procedures be prepared and followed for i

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surveillance testing requirements that could have an effect on nuclear

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safety. Surveillance Procedure SP 1089, " Residual Heat Removal Pumps and i

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Suction Valves from the Refueling Water Storage-Tank," step 7.3.17, was not followed in that a note informing the operator to hold the switch in the stop position until the system stabilized was not adhered to. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section -IV of the NRC Enforcement Policy.

(282/96010-01)

N3 Maintenance Procedures and Documentation M3.1 Drawina Discrepancy in Updated Safety Analysis Report (USAR)

a. Inspection Scone (62707)

While reviewing a maintenance activity to perform a temporary repair of a steam leak on the connection between a chemical feed line and a feedwater line, the inspectors noted that a drawing in the USAR contained errors.

The inspectors reviewed the following documents:

e USAR Section 11.9, revision 12 e

USAR Figure 11.1-5, revision 13 e

USAR Figure 11.1-14, revision 13 e

Drawing NF-39240-1, revision A e

Drawing Request PI-96-154 b.

Observations and Findinas

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The inspectors noted that USAR Figure 11.1-5 (Drawing NF-39222, revision AT), showed a transition to drawing NF-39239 for a continuation of the chemical feed lines upstream of where they tie into the feedwater lines.

However, drawing NF-39239, revision AL (USAR Figure 11.1-14, revision

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13), was revised on January 18, 1995, to eliminate the chemical feed system from the drawing. The chemical feed system was actually continued on drawing NF-39240-1, Revision A.

The inspectors were informed by the chemical feed system engineer that he

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was aware of the drawing discrepancy and intended to take action to-correct it. Drawing Request PI-96-154 was submitted on September 20, 1996, to correct the problem.

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l c. Conclusions This issue is considered an IFI pending completion of the USAR update.

(282/96010-02)

M3.2 Failure to Adeauately Perform Check Valve Tests I

a. Insoection Scone (61726)

On September 30, 1996, the inspectors observed the performance of Surveillance Procedure SP 1355, " Checking Chemical Feed and Auxiliary

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i Feedwater Check Valves - Unit 1."

As part of this inspection, the inspectors reviewed the following documents:

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e Surveillance Procedure SP 1355, " Checking Chemical Feed and Auxiliary Feedwater Check Valves - Unit 1," revision 6 e

Surveillance Procedure SP 2355, " Checking Chemical Feed and

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Auxiliary Feedwater Check Valves - Unit 2," revision 2 e

Procedure H10.1, "ASME Section XI Inservice Testing Implementation

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Program," revision 6 e

Form 1190, " Unit 1 Chemical Feed System Pre-Startup Checklist,"

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e Form 1191, " Unit 2 themical Feed System Pre-Startup Checklist,"

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e Drawing NF-39240-1, revision A

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b. Observations and Findinas

Section 7.3 of SP 1355 contained instructions for performing ASME Section XI testing of check valves, CF-11-1 and CF-11-2, on t'ne chemical feed

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injection lines to the auxiliary feedwater system. During the i

performance of that section, operators noted that some valves were not in the positions indicated on SP 1355 and discussed the situation with a chemist and the shift supervisor.

They were informed by the chemist that the normal system lineup had been changed by the chemistry department about two years ago because the system was no longer operated in automatic. The shift supervisor authorized the operators to position the valves as specified in the surveillance procedure and continue with the test.

The test lineup consisted of measuring pressure on both sides of the check valves using temporarily installed gauges. A differential pressure with high pressure on the downstream side of the valves would indicate proper reverse seating. The operators recorded 735 psig on the downstream side of CF-ll-2 and 0 psig on the upstream side. They recorded on the procedure that the test results were acceptable. A similar test lineup was used for testing the unit 2 check valve, 2CF-II-2.

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i However, the inspectors noted that two manual valves (CF-2-35 and CF-2-j 36) between CF-ll-2 and the upstream pressure gauge had not been included l

in the procedure to be verified in the correct position.

Because other valves had been found out of position, the inspectors asked the operators

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to check the positions of those two valves. They were found to be

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closed. This invalidated the results of the test since the upstream

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j pressure gauge had been isolated from the check valve being tested.

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The shift supervisor then abandoned the surveillance and informed the i

system engineer of the situation. The shift supervisor isolated both the i

unit I and unit 2 chemical feed check valves from the auxiliary feedwater

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system until the situation was clarified. The next day the system i

engineer and shift supervisor approved a temporary change to the unit I

surveillance procedure to correct the valve lineup problems. The test

was reperformed and CF-11-2 was found to be acceptable. The surveillance l

was completed within the periodicity required by the Technical Specifications and ASME Section XI.

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The licensee evaluated previous performances of the surveillance and i

determined that the tests for both CF-11-2 on unit I and 2CF-11-2 on unit

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2 had most likely been invalid for each quarterly test performed in

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approximately the previous two years due to the temporarily installed

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gauges being isolated. At the conclusion of the inspection period, 2CF-l 11-2 remained isolated until it could be properly tested with a revised

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procedure.

I The significance of the failure to properly test the valves was reduced i

because the valve lineup change conducted by the chemistry department had

also isolated the chemical feed check valves from the auxiliary feedwater system except when actually in use for adding chemicals or for the

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l quarterly tests. Normally, chemicals were only added through these paths

during shutdown periods. Thus the untested check valves were probably

isolated during most of the period in question.

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c. Conclusions l

l-Technical Specification 4.2.A.2 required that inservice testing of ASME i

Code Class 1, Class 2, and Class 3 pumps and valves be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code

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and applicable Addenda as required by 10 CFR 50, Section 50.55a(g),

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The licensee war turrently required to follow the 1989 revision of

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Section XI, which stated that valve testing shall be performed in j

accordance with the requirements stated in ASME/American National

Standards Institute Operations and Maintenance Standards, Part 10,

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1988 (ASME/ ANSI OM-10), " Inservice Testing of Valves in Light-Water

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Reactor Power Plants." Paragraph 4.3.2.4(a) of OM-10 required

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quarterly verification that the disk of a normally open check valve

traveled to its seat on cessation or reversal of flow by observing a

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position indicating device or changes in system pressure, flow rate, i

level, temperature, seat leakage testing or other positive means.

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Because valves CF-2-35 and CF-2-36 on unit I and 2CF-2-35 and 2CF-2-36 on

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i unit 2, were closed and effectively isolated the temporary upstream pressure gauges, the check valves CF-11-2 and 2CF-ll-2 were not

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adequately tested quarterly from about March 1994 until October 1,1996.

This was a violation.

(282/96010-03)

In addition to the fact that the surveillance procedures did not require i

verification of the positions of valves CF-2-35, CF-2-36, 2CF-2-35, and 2CF-2-36, the inspectors concluded that the event indicated a weakness in

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the licensee's configuration control program because chemistry department J

personnel had significantly changed the normal lineup of the chemical

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feed system from that shown on plant drawing NF-39240-1 and assumed in SP

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1355 and SP 2355 without informing operations or engineering personnel or

adequately considering the effect on other plant procedures. The normal system lineup was established by Form 1190(1191), " Unit 1(2) Chemical

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Feed System Pre-Startup Checklist." However, those forms were not required to be controlled as " procedures fer systems involving nuclear

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safety of the facility" according to Technical Specification 6.5.A and thus had not been reviewed by the Operations Committee for potential

effects on other procedures.

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The inspectors also concluded that the operators performing the test and the shift supervisor failed to display an adequate questioning attitude when several valves were found out of their expected positions.

SP 1355 i

included a system diagram figure which showed that valves CF-2-35 and CF-2-36 needed to be open to establish a valid test lineup-and the operators should have anticipated that they could be out of position too.

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the test had been performed each quarter for both units for approximately

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the previous two years, multiple opportunities were missed by the operators to recognize the lineup problems.

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The licensee intended to issue LER 282(306)/96-17 for this event. The

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inspectors will review the LER when issued.

M3.3 Inadeauate Procedure for Diesel Generator Trio Test i

a. InsDection Scope (61726)

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On September 25, 1996, the inspectors observed the performance of

Surveillance Procedure SP 1306, "D2 Diesel Generator Functional Test,"

revision 2.

The above procedure was reviewed as part of this inspection.

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l b. Observations and Findinos This was the first performance of the test after a significant revision

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to the procedure. The test was to verify that certain trips of the diesel generator were defeated when the diesel was operating during a loss of offsite power in conjunction with a safety injection signal, as t

required by TS 4.6.A.3.b.4.

In the past, the test was done without

actually physically tripping the generator output breaker, but the revision added steps to trip the breaker.

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Step 7.15.2 of the procedure required the operators to close the output breaker from the control room in preparation for the trip test (with the

diesel not operating). Operators attempted to close the breaker, but

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They then determined that the breaker would not close j

unless the synchro-check relay was energized. This was impossible with j

the engine not running. The surveillance was stopped and a temporary change was made to the procedure to add a step to jumper out the synchro-

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check relay. The surveillance was then successfully completed.

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j c. Conclusions The inspectors concluded that SP 1306 was not appropriate for the

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circumstances because it did not require jumpering of the synchro-check relay. This was a violation of 10 CFR 50, Appendix B, Criteria V, which

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i required that activities affecting quality be prescribed by documented i

instructions, procedures, or drawings, of a type appropriate to the circumstances. However, the procedure problem was not safety significant l

because the inadequacy simply resulted in the inability to complete the l

test until it was corrected. This failure constitutes a violation of I

minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy.- (282/96010-04)

M8 Miscellaneous Maintenance Issues' (92700, 92902)

As part of the inspection for each LER discussed in this section, the

inspectors reviewed the LER itself.

M8.1 (Closed) IFI 306/94015-01:

Performance of Foreign Material Exclusion (FME) Inspections. This issue was discussed in Inspection Report 282(306)/94015, Section 3.c.

Inspectors' observations during maintenance activities since that time indicated no significant problems with FME controls.

M8.2 (Closed) Unresolved Item 306/94015-02: Verbal Authorization for Equipment Control. This issue was discussed in Inspection Report 282(306)/94015, Section 5.b.a.

Inspectors' observations during plant activities since that time indicated only one significant instance of verbal authorization for equipment control that was not properly documented. That case, discussed in Inspection Report 282(306)/96002, Section 1.1.1, involved manipulation of disconnect switches ordered by the shift supervisor and then not recorded in the appropriate log. That issue was considered an example of a violation (282/96002-Olb) cited in the report. The unresolved item is considered closed and any additional corrective actions will be reviewed in followup on the violation.

M8.3 (Closed) LER 306/96-02. revision ~0:

Reactor Trip Caused by Loss of Instrument Air Pressure. This event was discussed in Inspection Report 282(306)/96006, Sections 01.2, M1.2, and M8.3.

The inspectors determined that the corrective actions in the LER were completed and concluded that the actions should prevent recurrence'of the event. One corrective action, to implement a modification to add an automatic isolation valve to the instrument air dryer exhaust purge line, was not completed but

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i parts had been obtained and plans were in place to install it. That modification, when completed, would isolate the exhaust purge line on low

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air header pressure which would prevent a stuck exhaust valve from

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depressurizing the air header. Until the modification could be

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installed, the licensee was operating the system with the manual exhaust

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purge isolation valve throttled in order to give operators sufficient

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time to respond to a stuck valve.

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M8.4 (Closed) LER 282(306)/96-14. revision 0: Simultaneous Inoperability of

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i Cooling Water Pumps. This event was discussed in Inspection Report

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282(306)/96008, Section M1.2, and a violation for the licensee's failure

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to issue the LER in a timely manner was discussed in Section M8.1 of the

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l same report. The LER was issued on September 5, 1996, 41 days after the

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event was discovered by the licensee. The remaining corrective action

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was to review the diesel cooling water pump surveillance test procedure i

against the plant's Writer Guide to verify that it was well-written from

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a human-factors perspective. As discussed in Section M3.2 of Inspection

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Report 282(306)/96008, the licensee discovered a typographical error in

the procedure which contributed to the event reported as LER 282(306)/96-i 15.

Since one of the corrective action for LER 96-15 was also to review i

j the procedure for possible revisions, LER 96-14 is closed to avoid l

i duplicate tracking and the remaining corrective action will be verified i

when LER 96-15 is closed.

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i M8.5 (Ocen) LER 282(306)/96-15. revision 0: Auto-start of No. 22 Diesel j

Cooling Water Pump on Low Header Pressure During Surveillance. This j-event was discussed in' Inspection Report 282(306)/96008, Section M3.2, as

mentioned in the section above. At the time of that inspection the LER i

had not yet been issued. The LER was issued on September 23, 1996, and i

the inspectors' review determined that it met the requirements of 10 CFR j

50.73. The LER remains open pending the completion of the corrective

l actions discussed therein.

M8.6 (Closed) LER 282(306)/96-16. revision 0: Auto-start of No. 11 Component Cooling Water Pump due to Personnel Error. This event was discussed in

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Section M1.2 of this report. The LER is closed based on the inspectors'

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verification of the completion of all corrective actions and the

determination that the corrective actions should be adequate to prevent recurrence.

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III. Eneineerina i

E2 Engineering Support of Facilities and Equipment E2.1 Review of USAR Commitments (37551)

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While performing the inspections discussed in this report, the inspectors I

reviewed the applicable portions of the USAR that related to the areas inspected and used the USAR as an engineering / technical support basis document. The inspectors compared plant practices, procedures, and/or parameters to the USAR descriptions as discussed in each section.

In Section M3.1, an error in a USAR drawing was discussed.

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j E8 Miscellaneous Engineering Issues (92903)

i E8.1 (Closed) Unresolved Item 282/96006-01

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(Closed) Annarent Viol ation 282/96007-02

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(Ocen) Licensee Event Report (LER) 282(306)/96-10: Auxiliary Feedwater

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Pumps Not Protected Against Runout For All Conditions. This issue was

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discussed in Inspection Report 282(306)/96006, Section 01.3, and

282(306)/96007, Section E1.1.

In a letter to the licensee from the NRC dated October 1,1996, the NRC elected to exercise enforcement discretion and not issue a Notice of Violation for this issue. Thus, the Unresolved Item and Apparent l

Violation are closed.

LER 96-10 regarding the issue remains open pending

NRC review of the licensee's completion of longer term corrective actions

to remove reliance on operator action to preclude pump damage.

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i IV. Plant Suonort

R1 Radiological Protection and Chemistry Controls (71750)

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During normal resident inspection activities, routine observations.were conducted in the areas of radiological protection and chemistry controls using

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j Inspection Procedure 71750. No discrepancies were noted.

R2 Status of Radiological Protection and Chemistry Facilities and Equipment j

R2.1 Condition of Radioactive Waste Storaae Tanks j

As discussed in Inspection Report 282(306)/96002, Section 4.6, the inspectors looked at all accessible radioactive waste storage tanks to determine if their condition had degraded. At that time there was no access to the spent resin

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storage tank room or the low level waste gas decay tank room. During this i

i inspection period the licensee took down block walls to gain access to the i

rooms in order to perform a modification. The rooms had not been entered for j

over 20 years. The inspectors entered the rooms for an inspection after the

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blocks were removed. The tanks, piping, supports, valves, and the rooms in i

general appeared to be in excellent material condition.

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Additional issues with the licensee's activities in the rooms were discussed l

in. Inspection Report 282(306)/96011.

j P1 Conduct of Emergency Preparedness Activities (71750)

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l During normal resident inspection activities, routine observations were i

conducted in the area of emergency preparedness using Inspection Procedure

71750. No discrepancies were noted. The inspectors noted that one of the

i evacuation routes from the plant was restored when bridge construction was i

completed on Dakota County Highway 68. The road had been closed for most of i

the summer.

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S1 Conduct of Security and Safeguards Activities (71750)

During normal resident inspection activities, routine observations were conducted in the areas of security and safeguards activities using Inspection

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Procedure 71750. No discrepancies were noted.

An additional inspection of licensee activities in this area was conducted

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during this period and was discussed in Inspection Report 282(306)/96013.

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F1 Control of Fire Protection Activities (71750)

i During normal resident inspection activities, routine observations were conducted in the area of fire protection activities using Inspection Procedure

71750. No discrepancies were noted.

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V. Manaaement Meetinas

i X1 Exit Meeting Sunnary The inspectors presented the inspection results to members of the licensee

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management at the conclusion of the inspection on October 8,1996. The

licensee acknowledged the findings presented.

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i The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

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i PARTIAL LIST OF PERSONS CONTACTED Licensee

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M. Wadley, Plant Manager K. Albrecht, General Superintendent Engineering i

J. Goldsmith, General Superintendent Design Engineering J. Hill, Manager Quality Services G. Lenertz, General Superintendent Plant Maintenance D. Schuelke, General Superintendent Radiation Protection and Chemistry M. Sleigh, Superintendent Security J. Sorensen, General Superintendent Plant Operations INSPECTION PROCEDURES USED IP 37551:

Onsite Engineering IP 40500:

Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726:

Surveillance Observations

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IP 62707:

Maintenance Observations i

IP 71707:

Plant Operations IP 71750:

Plant Support Activities IP 92700:

Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901:

Followup - Operations IP 92902:

Followup - Maintenance IP 92903:

Followup - Engineering ITEMS OPENED, CLOSED, AND DISCUSSED Opened 282/96010-01 NCV Failure to Follow Surveillance Procedure 282/96010-02 IFI Drawing Error in USAR 282/96010-03 VIO Failure to Adequately Perform ASME Check Valve Tests 282/96010-04 NCV Inadequate Procedure for Diesel Breaker Surveillance 282(306)/96-15 LER Auto-start of No. 22 Diesel Cooling Water Pump on Low Header Pressure During Surveillance Closed 306/96002-03 IFI Failure to Recognize Closed Control Valve During Power Change 282/96008-06 IFI Concerns with Technical Specification Interpretation 306/94015-01 IFI Performance of Foreign Material Exclusion Inspections 306/94015-02 URI Verbal Authcrization for Equipment Control 306/96-02 LER Reactor Trip Caused by Loss of Instrument Air Pressure 282(306)/96-14 LER Simultaneous Inoperability of Cooling Water Pumps 282(306)/96-16 LER Auto-start of No. 11 Component Cooling Water Pump on Low Header Pressure due to Personnel Error 282/96006-01 URI Auxiliary Feedwater Pumps Not Protected Against Runout For All Conditions

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282/96007-02 VIO Auxiliary Feedwater Pumps Not Protected Against Runout For All Conditions Discussed 282/9600?-Olb VIO Failure to Log Manipulation of Disconnect Switches 282(306)/96-10 LER Auxiliary Feedwater Pumps Not Protected Against Runout For All Conditions

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I LIST OF ACRONYMS USED ASME American Society of Mechanical Engineers ANSI American National Standards Institute

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CC Component Cooling i

CF Chemical Feed j

CFR Code of Federal Regulations l

FME Foreign Material Exclusion

IFI Inspection Followup Item i

IP Inspection Procedure LER Licensee Event Report i

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission PDR Public Document Room

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PSIG_ Pounds per Square Inch - Gauge

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SAC Safety Audit Committee

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SP Surveillance Procedure

TS Technical Specification l

TSI Technical Specification Interpretation

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j URI Unresolved Item

USAR Updated Safety Analysis Report

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VIO Violation i

WO Work Order

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