IR 05000282/1997012

Insp Repts 50-282/97-12 & 50-306/97-12 on 970519-1001. Violations Noted.Major Areas Inspected:Fire Protection Program & Several App R Issues

ML20211P238
Person / Time
Site:	Prairie Island
Issue date:	10/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211P208	List: IR 05000282/1997012 ML20211P204 ML20211P224
References
50-282-97-12, 50-306-97-12, NUDOCS 9710200112
Download: ML20211P238 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli ,

Docket Nos: 50-282,50-306 License Nos: DPR-42, DPR-60 Report No: 50-282/97012(DRS); 50-306/97012(DRS)

Licensee: Northern States Power Company i

Facility: Prairie Island Nuclear Generating Plant Location: 1717 Wakonade Drive East Welch, MN 55089 Dates: May 19 - October 1,1997 Inspectors: D. Schrum, Peactor Inspector Approved by: R. Gardner, Chief Engineering Specialists Branch 2 Division of Reactor Safety

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9710200112 971014 PDR ADOCK 05000282 G PDR

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EXECUTIVE SUMMARY Prairie Island Nuclear Generating Plant, Units 1 & 2 NRC Inspection Report 50-282/97012(DRS), 50-306/97012(DRS)

. This regional inspection reviewed the licensee's fire protection program and several Appendix R issues. The following strengths and weaknesses were identified:

Plant Sucoort e Four violations were identified for failure to ensure that a revision to the Fire Hazards Analysis was submitted to the NRC (Section F3.1), to ensure that a surveillance was complete (Section F3.2), to ensure that surveillance records were not discarded (Section F3.4), and to ensure that the fire brigade members were meeting training requirements (Section FS).

• There were a low number of fire protection impairments requiring a fire watch (Section !

F6).

• There were no plant fires during the past three years. This was an indicator that hot work was being safely performed (Section F3.2),

e Most fire protection equipment was well maintained and most transient combustibles

- were well controlled (Section F2.1).

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Report Details IV. Plant Sunnort F1 Control of Fire Protection Activities F Motor-Ooerated Valve (MOV) Hot Shorts insoection Scone The inspector reviewed the licensee's response to Information Notice (IN) 921 Findings and Observations On February 28,1992, the NRC issued Information Notice (IN) 92-18 " Potential for Loss of Remote Shutdown Capability During a Control Room Fire." This IN identified a potential common mode failure of MOVs in which a postulated fire could cause hot shorts in the valve control circuit and bypass the valve protective features (i.e., limit and torque switches). The spurious operation of the MOVs could cause physical damage to the valves which were required to be operated to achieve and maintain safe shutdown condition The licensee's initial evaluation of IN 92-18 was performed in 1992. The licensee did not take corrective actions because it was believed that MOV thermo-overloads would protect the valves subject to hot shorts. In addition, the site's MOV thermo-overloads were not bypassed during r.ormal or safety operations. However, due to problems at other nuclear sites the licensee was aware through industry information that their previous response to hot short problems may not be adequate if the thermo-overloads do not trip before MOV damage occurs. The inspector was concemed that the licensee had not committed adequate resources to evaluate the hot short issue prior to this inspection. Pending completion of the licensee's evaluation of hot shoits and a determination of the plant's susceptibility to MOV damaga, this is considered an Unresolved item (50-282/97012-01(DRS); 50-306/97012-01(DRS)).

The licensee plans to perform additional reviews of the hot short problem following the completion of the safe shutdown analysis Completion of the analysis will provide an accurate list of MOVs susceptible to hot short Conclusion An Unresolved item was identified concerning the plant's susceptibility to MOV damage from hot short I

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F2 Status of Fire Protection Facilities and Equipment F Observation of Plant Areat insoection Scoce The inspector toured the site's buildings to observe the control of combustibles, fire doors, hose stations, detection equipment, extinguishers, sprink!er systems, emergency lights, and housekeeping, Observations and Findings Control of combustibles was goc 4 with few translent combustibles noted in the plan Flammable liquids were stored appropriately in fire proof cabinets and safety can There was a minimal amount of oil below rotating equipmen The material condition of the majority of the fire protection equipment was good. The fire brigade equipment was in good condition. Most fire doors in the plant were in good conditiori. Only a few doors did not latch when they self-closed. Zebra mussels were being monitored and were not an equipment proble Conclusion Control of combustible material in the plant appeared to be good. The material condition of the majority of the fire protection equipment was goo F3 Fire Protection Procedures and Documentation F3,1 FHA Uodates Insoection Scooe Review changes to the Fire Hazards Analysis (FHA). Qbservations and Findings The inspector identified that the July 1,1994, FHA update was not submitted to the NRC for review. Substantial changes were made to the FHA during the update. By reference, the FHA is considered part of the FSAR. Generic Letter (GL) 86-10 stated:

"All changes to the approved program shall be reported annually to the Director of the Office of Nuclear Reactor Regulation, along with the FSAR revisions required by 10 CFR 50.71(e)." Failure to submit the revised portions of the FHA to the NRC for review is a violation of 10 CFR 50.71(e) (50-282/97012-02(DRS); 50-306/97012-02(DRS)).

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. . Conclus!20 The failure to submit revised portions of the FHA to the NRC for technical review was a violatio F Fire reopds and Surveillances insoection Scoce Inspector review of fire raports and surveillance Observations and Findinos There were no plant fires during the past three years. This was an injicator of good transient combustible controls and safely performed hot wor During a review of surveillaMes, the inspector identified that eight penetrations had not been inspected during Surveillance Procedure (SP) 1192, " Safeguards Electrical and M3chanical Penetrations. Surveillance inspection," Revision 7. This surveillance had received several reviews by plant staff following its performance, including the system engineer who signed this surveillance test as acceptable on April 7,199 Plant Safety Procedures F5 Appendix K," Fire Detection and Protection Systems,"

Revision 3, Paragraph 8.7," Penetration Fire Barriers," stated: " Penetration fire barriers in fire area boundaries protecting safety rela'ed equipment SHALL be demonstrated operable as follows: 8.7.1 A visualinspection of fire barrier penetration fire barriers SHALL be conducted every 18 months."

Prairie Island Technical Specification 6.5.A.7 required that detailed written implementing procedures be prepared and followed for the fire protection program SP 1192 was not followed in that plant staff failed to complete the surveillance. Eight penetrations were not inspected. This is violation of Technical Specification (TS) 6.5. (50-282/97012-03(DRS); 50-306/97012-03(DRS)). I During the inspection, Work Order (WO) 9704500 was written to ensure that the eight missed penetrations were inspected to determine if the fire barriers were operable. As part of the corrective actions, the licensee submitted Surveillance Procedure 1192 to the Error Reduction Task Force for a review with suggestions on changes necessary to improve the human performance aspects of this procedur Conclusiqa The failure to carefully implement and review the completed results of SP 1192 was a violatio F Inadeauate Procedure Insocction Scoce Review emergency lighting surveillance procedur _ - _ _ - - _ .

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. . Observations and Findings The inspector identified that SP 1351, " Emergency Lighting 18 Month Test 8 Hr Test,"

Revision 1, did not include acceptan::e criteria for determining the voltage (i.e.,5.25V) at which an emergency battery would be considered to have failed the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> discharge ,

tests. The licensee found the test acceptable if the Ismps were stilllit. As a result, the inspector had a concern that there was no method to verify that there was acceptable illumination to perform safe shutdown procedures, in addition, the inspector noted that several emergency lights in the plant were not correctly aimed. During the inspection the licensee had taken steps to review these concerns. Pending the licensee's corrective actions for these problems, this is an Inspection Followup Item (50-282/97012-04(DRS); 50-306/9 /012-04(DRS)). Conclusion Not having an acceptance criteria for determining failure of ELU batteries and emergency lights not correctly aimed were an inspection Followup Ite F No Record Storace for Detector Surveillances hgoection Scope Identiff surveillance records not available for review, Observations and Findings The inspector identified that detector surveillance data documented during SP 1189,

" Safety Related Fire Detector Check," Revision 16, was not available for inspector review because it had been discarded. Only the cover sheets of surveillances were saved. The licensee stated this was allowed by the licensee's Administrative Work Instruction, SAWI 1.5.0, Revision 2, in Paragraph q. Prairie Island Administrative Work Instruction 5AWI 3.4.0, "QA Records Control,"

Revision 4, stated in Paragraph 6.2.1," Records that document information of enduring significan :e to the quality of an item or activity SHALL be classified as Record Management System (RMS) Records." Also, Paragraph 6.2.3 stated: " Records Giat meet one or more of the following criteria SHALL be classified as lifetime records: Would be of significant value in demonstrating capabilit/ for safe operation o' a safety related or fire protection related item."

The detector surveillance data required by SP 1189 was of significant value in demonstrating capability of a fire protection related item. The detectors are important to safe shutdown during an Appendix R fire. The detector data demonstrates that the

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surveillance was performed, performed accurately, who performed the steps of the surveillance, and ensures compliance to the licensee's fire protection program.

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Praine Isis.ad Technical Specification 6.5 A.7 required that detailed written implementing procedures be prepared and followed for the fire protection program. SAWI 3.4.0 was not followed in that the December 12,1996, detector surveillance data documented during SP 1189, * Safety Related Fire Detector Check' was not available for inspector

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review because it had been discarded. This is a violation of TS 6.5. (50 282/97012-05(DRS); 50 300/97012 05(DRS))

c. Conclusion The licensee's failure to maintain fire protection records was a violatio F5 Fire Protection Staff Training and Quallfication a. 10spection S. cope The inspectors reviewed firo brig 6 4 :ialning, r;ualification records, and fire brigado critiques, b. Findings rand Obt.ervations During a review cf fire brigade drill records the inspector llentified that not all of the fire brigade members had annually participated in fire brigade drills. Prairie Island Administrative Work Instruction SAWI 3.13.0, " Fire Preventive Practices," Paragraph 6.9.6 stated: " Individual Fire Brigade members SHALL actively participate in at least one drill per year." In addition, Plant Safety Procedure F5 Appendix J," Fire Drills,"

Revision 3, stated in Paragraph 1.2.4: " Individual Fire Brigade members SHALL actively participate in at least one (1) drill per year."

A review of fire brigade dri .a indicated that seven brigade members had not met the requirement to actively participate in brigade training. The licensee stated that they give credit for control room coverage during fire brigade dri'Is for meeting the annual drill requirement. However, this does not meet the requirements for active training as a fire brigade membe Prairio Island Techrical Specification 6.6.A.7 required that detailed written irrplementing procedures be prepared and followed for the fire protection program. The failure to correctly implement SAWI 3.13.0 is a violation of TS 6.5.A.7. (50-282/97012-06(DRS);

e 50-306/97012-06(DRS))

During the inspection, the licence performed fire brigado drills that included the seven unqualified fire brigade member The inspector identified that the licensee did not have an administrative process to track the qualifications and training of fire brigade members. As a result, the licensee could not easily determine which brigade members had actually participated in drills and trairing. During the inspection, the licensee committed to develop a process to track brigade qualifications and training. Pendir.g the completion of the training tracking system, this is an Inspection Followup Item. (50-282/97012-07(DRS);

50-306/97012-07(DRS))

QIllis Der Year in a May 2,1979 letter to the NRC entitled," Administrative Controls and Quality Assurance" the licensee stated in Paragraph 4.1: " Drills will be scheduled so that each

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fire brigade memberf. vill participate in at least two drills per year." This regulrement was consistent with the two drills per year required in GL 861 However, Prairie Island Administrative Work Instruction SAWI 3.13.0, " Fire Preventive Practices," Paragraph 6.9.6 stated: " Individual Fire Brigade members SHALL actively participate in at least one drill per year." The site's procedure was not consistent with the original requirement. Pending additional Information from the lice 7see on how the requirement was changed, this is an Unresolved item. (50 282/97012-08(DRS);

50 306/97012 08(DRS))

c. Conclusion The inspector identified a violation for not havin] qualified brigade members. An unresolved item was identified concerning the number of fire brigade drills required per yea F6 Fire Protection Organlaation and Administration insoection Scope The inspectors reviewed fire protection impairments and fire watch program, Observations and Findings The inspectors noted that the number of impairments requinng a fire watch was lo This was e program strength. However, the inspector identified a weakness with the fire watch program in that fire watches did not observe or know what the impairments were during their fire watch rounds. For example, by not knowing that a fire door was impaired the fire watch could not ensure that transient combustibles were kept away from the door. Any nearby combustibles could significantly increase the risks associated with the impaired door, Coriciusion The inspector identified a weaknen in the use of fire watches who did not know the fire protection impairments in the plan F7 Quality Assurance in Fire Protection Activities Licensee QA audits were effective at identifying fire protection program problem F8 Miscellaneous Fire Protection issues (Closed) VIO 50-282/308/94004-01afDRS): This violation was issued for not taking timely corrective actions for an impaired safety injection pump fire barrier and not assigning an impairment to this condition. Compensatory fire watch was assigned and a file barrier was installed. This item is close =

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i (Closed)VIO 50-282/306/94004 01bfDRS): Fire Hazards Analysis not updated and the modification process not changed to ensure that fire loading changes are included in the FHA. The FHA had been updated to include all modifications and design changes that had occurred since the last update in 1986. In addition, procedure SAWI 1.13.1 was developed to enhance the review process for modifications to assure timely up%tes to

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the FHA, This item 's close V. Management Meetings X1 Exit Meeting Summary The inspector presented Interim inspection results to members of the licensee management at the conclusion of the onsite portion of the inspection on May 23 and June 5,1997. Following additional reviews to resolve some of the inspection issues, a final exit was conducted by telephone on October 6,1997. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials axamined durin0 the inspection should be considered proprietary. No proprietary information was identifie _=_ =

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PARTIAL LIST OF PERSONS CONTACTED Uce.0ften K. Albrecht, General Superintendent Engineering, Electrical /l&C T. Amundson, General Superintendent Engineering, Mechanical E. Ballou, Fire Protection Engineer J. Hoffman, Senior Consultant Engineer J. Sorensen, Plant Manager M. Wemer, Site Safety and Fire Protection Administrator INSPECTION PROCEDURES USED IP 61726: Surveillance Observations IP 64704: Fire Protection ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 282/300/97012 01 URI Hot Shorts with Valve Damage 282/306/97012 02 VIO FHA Changes Not Submitted to NRC for Review 282/306/97012-03 VIO Penetrations Not inspected 282/306/97012-04 IFl ELU Acceptance Criteria /Alming 282/306/97012 05 VIO QA Recordkeeping 282/306/97012 06 VIO Fire Brigade Drill Not Performed 282/306/97012 07 IFl Tracking Brigade Qualificaiions 282/306/97012-08 URI Fire Biigade Drill Requirements G01 /306/04004 01a VIO Failure Timely Corrective Actions 282/306/94004-01b VIO Fire Hazards Analysis Not Updated

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LIST OF ACRONYMS USED ANSI American National Standards Institute AWI Administrative Work Instruction CFR Code of Federal Regulations ELU Emergency Lighting Unit FHAR Fire Hazards Analysis Report FSAR Final Safety Analysis Report IN Information Notice GL Generic Letter MOV Motor-operated Valve NRC Nuclear Regulatory Commission PDR Public Document Room RMS Records Management System SIR Safety Evaluation Report SP Surveillance Procedure

-- TS Technical Specifications URI Unresolved item USAR Updated Safety Analysis Report USQ Unreviewed Safety Question VIO Violation WO Work Order

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