IR 05000282/1998016
| ML20205G908 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/30/1999 |
| From: | Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Wadley M NORTHERN STATES POWER CO. |
| References | |
| 50-282-98-16, 50-306-98-16, EA-98-526, NUDOCS 9904070416 | |
| Download: ML20205G908 (4) | |
Text
March 30, 1999
SUBJECT:
ENFORCEMENT DISCRETION (NRC FIRE PROTECTION FUNCTIONAL INSPECTION (FPFI) REPORT NUMBER 50-282/306-98016)
Dear Mr. Wadley:
This refers to the FPFI conducted from August 10 through 28,1998, at the Prairie Island (PI)
Nuclear Generating Plant. The inspection reviewed the Pl staff Appendix R self-assessment and the Pi fire protection program. The results of our inspection were sent to you by letter dated October 9,1998. Subsequent to the inspection report, the Pl staff provided additional written information on this subject to the NRC on October 24,1998. The NRC reviewed this information in the Region Ill office from November 2 through 6,1998.
The NRC determined thct three violations of NRC requirements occurred. This determination was based on information~ developed during the inspection; provided in Licensee Event Reports (LERs) 98010,98012-02,98014-01, and 98015-01; and documented in correspondence from the licensee to the NRC on November 24,1998. These violations included: (1) motor operated valves (MOVs) being potentially unable to satisfy their post-fire safe shutdown function; (2) spurious actuation or mal-operation of nonessential systems and equipment due to fire damage that could adversely affect safe shutdown capability; and (3) the removal of fire barriers such that post-fire safe shutdown components would not be free of fire damage.
The first violation addressed the PI engineering staff identification that thirty-two MOVs were potentially unable to satisfy their post-fire safe shutdown function. The post-fire safe shutdown
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function is specified in Section Ill.G of Appendix R to 10 CFR Part 50, " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979." The MOVs could be mechanically damaged due to fire induced spurious operation (hot shorts) that bypassed the valve limit or torque switches. If a valve suffered mechanical damage, an operator may not be able to manually reposition the valve to support safe shutdown during a fire. The NRC acknowledges that the probability of a fire occurring as described in Appendix R is low.
However, the consequences of such an event could have been high since the ability to maintain the plant in het standby, as required by Appendix R, could only have been achieved by
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significant operator actions, troubleshooting, and repair activities to compensate for the design deficiencies. Therefore, the NRC has categorized this violation of Appendix R in accordance with NUREG-1600," General Statement of Po; icy and Procedure for NRC Enforcement Actions i
(Enforcement Policy)," at Severity Level Ill.
9904070416 990330 l
PDR ADOCK 05000282
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The second violation was NRC identified and addressed an inadequacy in the PI fire protection i
plan. The fire protection plan is required by 10 CFR 50.48, " Fire Protection." Tht: plan was
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inadequate because it failed to consider the effect of spurious actuation caused by fire damage
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g to _ equipment not directly ' required to accomplish an essential shutdown function. Specifically,
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j valves in the residual heat removal (RHR) suctio'n lines from the containment sump were not i
protected from fire damage such that spurious opening of these valves could provide a flow
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diversion path from the refueling water storage tank (RWST) into the containment sump.
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Therefore, the RWST inventory may be depleted (drained to the sump) and not available to fully
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support the operation of safe shutdown equipment as evaluated in the fire protection plan. The l
failure of the fire protection plan to limit fire damage in a system needed to support safe J
shutdown of the plant is a violation of 10 CFR 50.48 (a). The risk of inventory depletion is low
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due to the availability of proceduralized makeup water from sources that would be free of fire i
damage. In addition, due to the system configuration of the RWST and the containment sump,
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at least eight hours would be available for the operators to diagnose the water depletion problem and provide makeup water. Therefore, based on the low risk, this 10 CFR 50.48 violation has been categorized in accordance with the Enforcement Policy at Severity Level IV.
' The third violation was NRC identified and addressed the removal (approximately four months
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before the inspection) of a one-hour fire barrier to the credited motor-driven auxiliary feed water
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(MDAFW) pump suction valve control circuit. Fire protection features are required to protect the MDAFW pump from fire damage, per the requirement of Appendix R, Section Ill.G.1,
' because the MDAFW pump is required to achieve and maintain hot shutdown conditions. The failure to limit fire damage to a system needed to safely shut down the plant is a violation of
Appendix R. The risk of not providing core cooling with the MDAFW pump is relativity low due to the availability of an alternate core cooling method (feed and bleed) that would remain free of fire damage, The alternate core cooling method was specified in emergency operating procedures and operators were trained on this procedure during simulator training cycles.
Therefore, based on the availability of the alternate core cooling method, this violation of Appendix R has been categorized in accordance with the Enforcement Policy at Severity Level IV.
For the first violation, escalated enforcement was considered. However, to recognize the l
efforts of the Pl staff in identifying problems affecting safety and to give credit for prompt corrective action, I have been authorized, after consultation with the Director, Office of Enforcement, to exercise enforcement discretion, pursuant to Section Vll.B.3 of the Enforcement Policy and not issue a Notice of Violation or a Civil Penalty. The NRC's decision to exercise discretion for this old design issue was based on the following: (1) the violation was identified as the result of a voluntary initiative subsequent to PI engineering staff reviews of -
generic NRC correspondence that addressed hot shorts; (2) prompt and effective compensatory actions were implemented by the Pl staff; (3) the violafion would not likely have been identified by routine licensee efforts such as normal surveillance and quality assurance activities; and (4) LER 98010 documented appropriate long-term corrective actions to resolve the hot short issue associated with the MOVs.
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. For the remaining violations, the NRC concluded that information regarding the reasons for each violation; and the corrective actions taken, planned to correct, and to prevent recurrence were already adequately addressed on the docket in LERs 98012-02, 98014-01, and 98015-01.
Therefore, these violations are being treated as Non-Cited Violations (NCVs), consistent with
' Appendix C of the Enforcement Policy.-
If you contest this enforcement action, you should provide a response within 30 days of the date of this enforcement action, with the basis for your denial, to the United States Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001, with copies to the Regional Administrator, Region Ill, and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
In accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter and your response (if you choose to provide one) will be placed in the NRC Public Dor.ument Room.
Sincerely, h
dV James. Dyer Regional Administrator Docket Nos. 50-282; 50-306
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License Nos. DPR-42; DPR-60 cc:
Plant Manager, Prairie Island K. Sanda, Commissioner, Minnesota Department of Public Service State Liaison Officer State of Wisconsin Tribal Council, Prairie Island Dakota Community
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DISTRIBUTION:
PUBLIC IE-01 SECY CA WTravers, EDO MKnapp, DEDE LChandler, OGC JGoldberg, OGC SCollins, NRR Enforcement Coordinators
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RI, Rll and RIV Resident inspector, Prairie Island JGilliland, OPA HBell, OlG
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GCaputo, Ol OE:ES OE:EA (2)
RAO: Rill SLO:Ritt PAO: Rill OCFO/LFARB w/o encl.
DRP Docket File
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l 070055
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