ML19350C992
| ML19350C992 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/09/1981 |
| From: | Baker K, Grobe J, Jackiw I, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19350C984 | List: |
| References | |
| 50-282-81-01, 50-282-81-1, NUDOCS 8104130038 | |
| Download: ML19350C992 (24) | |
See also: IR 05000282/1981001
Text
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U.S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION III
Reports No. 50-282/81-01; 50-306/81-01
Docket Nos. 50-282; 50-306
Licensee: Northern States Power Company
414 Nicollet Hall
Minneapolis, MN 55401
Facility Name:
Prairie Island Nuclear Generating Plant, Units 1 and 2
Inspection At: Red Wing, MN
Inspection Conducted: January 5-8, 1981
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Inspectors:
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- . A. Grobe
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Approved By:
K. 7Idker, Chief
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Nuclear Support Section 2
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Inspection Summary
Inspection on January 5-8, 1931 (Reports No. 50-282/81-01; No. 50-306/81-01)
Areas Insjected: Announced inspection in the following areas:
audit
program- receipt, storage and handling of equipment; records; document
contro'.; design changes; housekeeping and cleanliness; procurement; test
and reasurement equipment; and fire prevention and protection programs.
The inspection involved a total of 96 inspector-hours onsite by three NRC
inspectors including 0 inspector-hours onsite during off-shifts.
Results: Of the nine areas inspected, no apparent items of noncompliance
or deviations were identified in five areas, four items of noncompliance
were identified in four areas (failure to comply with audit requirements -
paragraph 6; failure to meet record storage requirements - paragraph 5;
failure to meet receipt, storage and handling requirements
paragraph 4;
failure to follow design change control procedures
paragraph 8).
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DETAILS
1.
Persons Contacted
- F.
P. Tierney, Plant Manager
- K.
J. Albrecht, Superintendent, Quality Assurancs
- D. J. Silvers, Quality Assurance Engineer
- W.
Gauger, I & C Supervisor
- T.
Reding, Document Control Coordinator
- R. Warren, Office Manager
- R. Hansen, Quality Assurance Engineer
- L. Brunner, Warehouse Supervisor
- J. Nelson, Superintendent of Maintenance
- E.
C. Liebeg, Administrative Aid
~*W.
R. Waldron, Training Supervisor
- D.
D. Althaus, Plant Services Supervisor
- J..B. Brokaw, Superintendent - Operations and Maintenance
- D. R. Brown, Production Engineer
- D. J. Mendele, Superintendent - Operations Engineering
- A. C. Johnson, Radiation and Chemistry Coordinator
- C. H. Harmsen, Production Engineer
- D. A. Schenlke, Superintendent Radiation Protection
NRC Region III
- I.
N. Jackiw, Reactor Inspector
- R.
D. Schulz, Reactor Inspector
- J. A. Grobe, Reactor Inspector
- C. D. Feierabend, Reactor Inspector
- B. L. Burgess, Reactor Inspector
- W.
S. Little, Chief, Project Section 2
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- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings
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(Closed) Unresolved Item (50-282/79-21; 50-306/79-18):
The periodic
audits which had not been conducted, were conducted in 1980. These
audits were:
3 ACD 2.2, 5 ACD 2.2, 5 ACD 2.3, 5 ACD 2.5, 5 ACD 7.1,
and 5 ACD 8.4 However, the licensee was in noncompliance with their
Operational Quality Assurance Plan in that an audit of 3 ACD 9.1,
Surveillance Program, had not been done since the directives inception
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in March of 1979.
(See paragraph 6.)
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18): The require-
ment for administrative controls to conduct periodic inspections of
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the storage areas as per ANSI N45.2.2 - 1972, paragraph 6.4.1 and the
actual conducting of such inspections was not implemented or performed.
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The requirement for administrative controls for handling of safety-
related material and for hoisting equipment used in the handling of
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safety-related equipment as per ANSI N45.2.2 - 1972, paragraph 7
were still not implemented or performed.
The above two items resulted in an item on noncompliance.
(See
paragraph 4.)
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18): The require-
ment for administrative controls for maintenance and care of items
in storage, including shelf life, as per ANSI N45.2.2 - 1972, para-
graph 6.4.2 was not implemented or performed. This resulted in an
item of noncompliance.
(See paragraph 4.)
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18):
Levels of
storage have been established in 5 ACD 8.2, Inventory Control.
Warehouses have been designated for "B" Levels of Storage and the
licensee has recognized the need for certain items to be stored
indoors, but care of items, including shelf life, to prevent damage,
deterioration, or contamination need to be firmly established. This
area will_be reviewed during subsequent inspections.
(Open) Unresolved Item (50-282/79-21; 50-306/79-18):
I&C Section
Work Instruction, SP-1 Revision 2, Inventory Control, does not have
a provision for QA inspection of QA-1 items returned to storage.
The I&C Supervisor, will propose a change to this procedure and it
will be reviewed during is subsequent inspection.
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18): A record
index has been established that lists retention times.
The licensee
is in the process of building a record vault, scheduled for completion
in 1981. Ilowever, access control has not been established and records
are located in many places, some not in fireproof cabinets. This has
resulted in a violation which is stated in Appendix A (See paragraph 5.)
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18): The authorized
users of the controlled drawing files in the I&C work area, electrical
work area, and electrical engineer work area were designated and the
responsible person for the files was aware of access control require-
ments.
Procedure, 5 ACD 4.4 was revised October 4, 1980 and addressed
the steps to be taken when a controlled drawing file was cancelled.
(Open) Unresolved Item (50-282/79-21; 50-306/79-18): Discrepancies
noted in the licensee's procedure regarding the plant training
program. During a recent plant reorganization, the plant training
department has been assigned to report to the corporate office who
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now has responsibility for plant training and is ir. the process of
rewritting current training ACD's.
These procedures will be reviewed
during a followup inspection.
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18): The inspector
found that 5 ACD 2.1, Quality Assurance Program Boundry, has been
totally rewritten.
It now includes the Q-list and the Q-list extension.
The Q-list extension has been reviewed and approved for use.
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The inspector also noted that, in the new plant organization, the
Superintendent-Quality Assurance reports directly to the Plant
Manager.
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18):
Responsi-
bilities for review and incorporation of requirements into station
level ACD's. The inspector verified that the Operational Quality
Assurance Plan and station ACD's assign responsibility for review of
General Office ACD's to the station Quality Assurance Section. The
QA section is responsible for incorporating new General Office
requirements in station administrative control directives.
(Closed) Deviation (50-282/79-21; 50-306/79-18):
Commitment to
complete the requirements of IEB 78-05 was not met.
The inspector
verified that a method for tracking commitments has been implemented.
The licensee also stated that plana are underway to computerize the
commitment tracking system.
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18:
Duty Engineer
to act as Chairman /Vice Chairman of OC in their absence. The inspector
notes that it is acceptable for the Plant Manager to appoint the Duty
Engineer as Vice Chairman provided the Duty Engineer is a member of the
OC.
(Closed) Unresolved Item (50-282/79-21; 50-306/79-18):
Independent
verification of electrical jumpers and lifted leads. The inspector
verified that plant requirements regarding independent verification
had been upgraded. Plant 5 ACD 3.9, issued on August 29, 1980,
includes requirements for independent verification of bypass instal-
lation and removal. The verification is done by an individual
independent of the work activity and excludes the first line super-
visor responsible for the work activity.
(Closed) Noncompliance (50-282/79-21; 50-306/79-18):
Failure to
follow procedure concerning design change control. The inspector
verified that all corrective actions regarding this item of non-
compliance had been completed as stated in the licennee's response
dated October 31, 1979.
3.
Procurement Program
The procurement program was reviewed to ascertain its conformance
with regulatory requirements and commitments in the Operational
Quality Assurance Plan. Procurement documents were checked for
technical requirements, QA plan requirements, 10 CFR 21 provisions,
specific identification of items, and statements concerning access
to the supplier's plant or records for purposes of audit. Procedures
were reviewed to determine if responsibilities were assigned in
writing for:
(a) initiation of procurement documents, (b) review
and approval of procurement documents, (c) making changes to procure-
ment documents and (d) basis for classification of procurement
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items. An approved vendors list was reviewed, along with the basis
for classification.
Procurement documents for various systems were
checked, along with the supplied materials documentation, including
traceability to the item.
a.
Documentation Reviewed
OQAP 6.0, Procurement Document Control
5 ACD_7.0, Uniform Nuclear Plant Procurement Process
3 ACD 6.1, Uniform Nuclear Plant Procurement Process
b.
Findings
No items of noncompliance or deviations were identified.
4.
Receipt, Storage and Handling of Equipment and Materials Program
Receipt, storage and handling of equipment and materials was reviewed
to ascertain whether the licensee is implementing a QA program that
is in conformance with regulatory requirements and commitments in
the Operational Quality Assurance Plan and implementing procedures
The inspector verified that responsibilities were assigned for receipt,
acceptance, release, storage, and handling of items. Nonconforming
items were reviewed for identification, segregation, control, and
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release. Procedures were reviewed for levels of storage and appropriate
environmental conditions, including shelf life,
a.
Documentation Reviewed
3 ACD 6.1, Uniform Nuclear Plant Procurement Process
5 ACD 8.1, Receiving Process
5 ACD 8.2, Inventory Control
5 ACD 8.3, Weld Material Control
5 ACD 8.4, Control of Nonconforming Items
SWl-I&C-SP-1, Spare Parts Inventory Control
OQAP 15.0, Handling, Storage and Shipping
OQAP 10.0, Identification and Control of Materials, Parts and
Components
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OQAP 11.0, Inspection
OQAP 9.0, Control of Purchased Material, Equipment and Service
OQAP 17.0, Nonconforming Materials, Parts or Components
b.
Findings
Noncompliance (50-282; 306/81-01-01)
10 CFR 50, Appendix B, Criteria XIII states in part, " Measures
shall be established to control the handling, storage, shipping,
cleaning, and preservation of material and equipment in accordance
with work and inspection instructions to prevent damage or
deterioration."
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Prairie Island's OQAP commits to complying with ANSI N45.2.2 - 1972
and ANSI N18.7 - 1976 to fulfill the requirements of 10 CFR 50,
Appendix B, Criteria XIII.
Contrary to the ANSI requirements, Operational Quality Assurance
Plan, and implementing procedures, the following examples of non-
compliance were noted:
ANSI N45.2.2 states in paragraph 6.2 that periodic inspections
shall be preformed to assure that storage areas are being main-
tained in accordance with these requirements.
states in paragraph 6.4.1 that inspections and examinations
shall be performed and documented on a periodic basis to assure
that the integrity of the item and its container is being main-
tained. ANSI N45.2.2 states in paragraph 8 that inspection and
examination records shall be prepared as required by this
standard. Periodic inspections are not being done on the
storage areas or on items to assure their integrity or mainte-
nance, to prevent degradation, deterioration, physical change,
and loss of identification and traceability.
ANSI N45.2.2 states in paragraph 7.4 that an inspection program
shall be established for equipment and rigging. An inspection
program has not been established for equipment and rigging.
ANSI N45.2.2 paragraph 6.2.1 states in part, " Access to storage
areas for Level A, B and C items shall be controlled and limited
only to personnel designated by the responsible organization."
Prairic Island's Inventory Control Procedure 5 ACD 8.2, establishes
this requirement in paragraph 6.1.3.
An access list of personnel,
authorized access to the Receiving Inspection, Hold, and Storage
Areas had not been generated.
In addition, the rear doors to
Warehouse A and B, Level B storage areas were not locked permit-
ting uncontrolled access.
Prairie Island's OQAP states in paragraph 15.2 that storage
facilities shall be arranged to facilitate control of the
safety-related items. ANSI N45.2.2 states in paragraph 6.3.1,
"All items shall be stored in such a manner as to permit ready
access for inspection or maintenance without excessive handling
to minimize risk of da7 age.
Storage of items in Warehouse A
and B indicate a storage system based on space availability and
convenience, rather than the categories of safety-related and
non-safety-related.
Numerous items, bath safety-related and
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non-safety-rclated, are stored in the same areas due to a short-
age of space.
Items are not arranged to permit ready access for
inspection or maintenance without excessive handling, to minimize
risk of damage, as isles are blocked with materials and items are
stacked high on racks or cribbing.
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The OQAP commits to ANSI N18.7, which requires in paragraph S.2.13
that procedures shall be established and implemented to ensure
that purchased materials and components associated with safety-
related structures or systems are properly documented to show
compliance with applicable specifications, identified and
stored to protect against damage, deterioration or misuse.
Flanges, fittings, nuts and bolts which had been turned over
from construction had not been inspected and documented for
damage, corrosion, or heat traceability. Documentation did not
indicate a review had been done of the original purchase order
and test report to assure compliance with applicable, safety-
related specifications, codes and standards. A three inch,
standard tee, was incorrectly identified as being a three inch,
X-Strong tee, with heat traceability number 680A. The heat
traceability number, 680A, was for the X-Strong tee, representing
its chemical and physical properties. These identification and
control measures do not protect against damage, improper substi-
tution, or misuse.
ANSI N45.2.2 paragraph 6.3.3 states, " Hazardous chemicals,
paints, solvents, and other materials of a like nature shall be
stored in well-ventilated areas which are not in close proximity
to important nuclear plant items." Materials marked " Flammable
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liquid" were in close proximity to important nuclear plant
items. A primer, designated Phenoline, and DOT were located
next to safety-related welding rod and a electric motor for a
containment fan coil unit.
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ANSI N45.2.2 paragraph 6.4.2 states, " Requirements for proper
maintenance during storage shall be documented and written
procedures or instructions shall be established.
Items in
storage shall have all covers, caps, plugs, or other closures
intact...The shafts of rotating equipment shall be rotated on a
periodic basis." ANSI N45.2.2 paragraph 6.1.2 states, " Items
shall be placed on pallets or shoring to permit air circulation."
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Valves, Flanges, pipe and fittings were found without cars,
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covers, or protectors to preclude end damage. There were also
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valves, flanges, and fittings on the stored floor loose on the
without cribbing or shoring. Measures have not been established
for the care of items with regard to shelf life conditions,
such as 0-Rings or diaphrams, to prevent degradation.
Requirements
for the periodic turning of rotating shafts had not been implemented
and documented.
ANSI N45.2.2 paragraph 7.5 requires that personnel engaged in
operating material handling equipment, demonstrate satisfactory
ability in operating similar lifting equipment.
Paragraph 8
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requires that personnel qualification records be prepared.
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Personnel engaged in operating material handling equipment did
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not have training records or personnel qualification records.
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Unresolved Item (50-282; 306/81-01-02)
Instrument and Control Procedure, SP-1 Revision 2 Inventory
Control, does not establish QA inspection on QA-1 items which
are unused and returned to storage. The Instrument and Control
Supervisor stated that Quality Assurance does inspect items
which are returned to I&C storage, and that a procedure change
may help clarify QA's role. This item will remain open and
will be reviewed at a subsequent inspection.
c.
Dis 52ssion
During discussions with warehouse and quality assurance / quality
control personnel, it appears that flanges, fittings, nuts and
bolts turned over from construction are classified as safety-
related solely on the basis of heat traceability to test reports.
This fails to take into account such things a N.D.E. requirements,
heat treatments, applicable specifications, quality inputs from
the original purchase order, specific marking requirements, and
vendor quality control on the original purchased item. The
ASME B and PV Code,Section III, requires times and temperatures
for heat treatment and nondestructive examination on material,
depending on class designation, specification and size.
It was
discussed with the licensee during the exit, that before an
item is released and installed in a safety-related system, it
should be evaluated for these type of factors by a documented
engineering evaluation to assure interchangeability, safety,
fit and function. Furthermore, quality assurance should verify
that the correct item was installed.
Since items turned over
from construction were purchased in the early 1970's, some being
manufactured prior to 1970, they should be analyzed the original
purchase order requirements and system designation for present
applicability, prior to installation.
In reviewing microfilm
records, a log designating material turned over from construction,
indicated only " material transfer" in the column marked purchase
order number.
Outside storage areas did not appear to be adequately controlled.
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Most of the items stored outdoors (pipe, fittings, valves, flanges),
were without end caps and some even have standing water on the in-
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side of the tubular products.
5.
Records Program
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The records program was reviewed to ascertain that the licensee is
implementing a program for the control of records that is in confor-
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mance with regulatory requirements, Operational Quality Assurance
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Plan, ANSI N18.7 - 1976 and ANSI N45.2.9 - 1974. Record storage
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controls were reviewed including the system of transferring records
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to the vault. Various records were reviewed for implementation of
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the program and personnel were interviewed concerning storage,
access, and retrievability. The record index was examined and
one-hour fireproof cabinets were checked.
a.
Documentation Reviewed
5 ACD 3.4, Records Management
3 ACD 3.8, Records Management
OQAP 19.0, Quality Assurance Records
b.
Findings
Noncompliance (50-282; 306/81-01-03)
10 CFR 50, Appendix B, Criteria XVII states in part that consist-
ent with applicable regulatory requirements, the applicant shall
establish requirements concerning record retention, such as dura-
tion, location, and assigned responsibility.
In order to meet 10 CFR 50, Appendix B, Criteria XVII the licensee
committed to ANSI N45.2.9 in section 19 of the Operational Quality
Assurance Plan.
ANSI N45.2.9 states in paregc'ph 6.2 that a list shall be generated
designating those personnel who shall have access to the files.
The Operational Quality Assurance Plan requires in paragraph 19.10
that records be stored in at leant one-hour rated fireproof
cabinets.
Contrary to the above, there are no personnel access lists for
records.
Access Control is very lax due to the fact that no access lists
are generated, and records are stored in many locations without
being maintained under appropriate supervision.
The auxillary
building log for 1980 was found on a bookcase, in an open office,
with no controls of any kind.
Furthermore, some records are not stored in fireproof cabinets.
Examples are snubber qualification records and the auxillary
building log mentioned previously.
6.
Audits
The licensee's audit program was reviewed to ascertain whether the
licensee has developed and implemented a program that is in confor-
mance with regulatory requirements and applicable industry guides and
standards. The inspection included verification of the following:
scope of the program is consistent with Technical Specification
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requirements, responsibilities for overall management of the program
have been assigned, and methods for identification and resolution of
audit findings have been defined.
s.
Documentation Reviewed
OQAP 18.0, Corrective Action
OQAP 20.0, Audits
5 ACD 2.2, Internal Audits
3 ACD 2.2, Audits
3 ACD 2.3, Quality Assurance Status Report
b.
Findings
Noncompliance (50-282; 306/81-01-04)
10 CFR 50, Appendix B, Criteria XVIII, states that a comprehen-
sive system of planned and periodic audits shall be carried out
to verify compliance with all aspects of the quality assurance
program and to determine the effectiveness of the program.
Section 20.3 of the OQAP states that required audits shall be
performed each year.
The Operational Quality Assurance Plan commits to ANSI N45.2.12
through ANSI N18.7 in order to meet 10 CFR 50, Appendix B,
Criteria XVIII.
ANSI N45.2.12 states in paragraph 4.3 that a brief pre-audit
conference shall be conducted with cognizant organization
management. At the conclusion of the audit process, a post-
audit conference shall be held with management of the audited
organization to present audit findings and clarify misunder-
standings.
t.NSI N45.2.12 also states in paragraph 4.3 that objective evidence
shall be examined for compliance with quality assurance program
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requirements.
Contrary to the above, the following items of noncompliance were
noted:
(1) A required audit, 3 ACD 9.1, Surveillance Programs, was
not audited since its approval date of March 29, 1979.
(2) Pre and Post audit conferences were not documented as being
held, and Administrative Control Directive 5 ACD 2.2 did not
require mandatory pre and post audit conferences, contrary
to ANSI N45.2.12 requirements.
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(3) Objective evidence was lacking on numerous audits with the
following audits listed as examples: 5 ACD8.2 dated
December 29-31, 1980; 5 ACD 8.4 dated December 17-19,
1980; 5 ACD 14.3 dat<.d October 9, 1980; 5 ACD 3.14 dated
October 21-22, 1980; 5 ACD 7.1 dated November 29, 1979;
5 ACD 8.4 dated November 1,1979; and 5 ACD 8.1 dated
December 29-31, 1980 (reference paragraph c).
c.
Discussion
The objective evidence required on audits was discussed with
the licensee, stressing the fact that objective evidence is
required not only on items of noncompliance but also on satis-
factory response to questions so as to determine the sample,
depth, auditor knowledge, and therefore, scope of the audit.
For example, the licensee audits the N.D.E. procedure,
5 ACD 14.3, once a year. The audit of 5 ACD 14.3 contained
only four questions that resulted in four "yes" answers. The
problems associated with the following audits are typical of
the lack of objective evidence:
5 ACD 3.14, Control of Measuring and Test Equipment
- Audit did not state what equipment was observed.
5 ACD 8.2, Ircientory Control
-Audit did not state what items were inspected for
damage.
-Audit did not state what items were returned to
storage.
-Audit did not state what items were inspected by
the Quality Control Engineer.
5 ACD 8.4, Control of Nonconforming Items
-Audit did not state what discrepancy reports were
reviewed.
-Audit did not state what reject tags were issued.
5 ACD 7.1, Uniform Nuclear Plant Procurement Process
-Audit did not state what change orders were
reviewed.
-Audit did not state what items or services had an
engineering evaluation.
5 ACD 8.1, Receiving Process
-Audit did not indicate what RIF's, Hold tags, Dis-
crepancy Reports or Purchase Orders were reviewed.
Basically, audits should indicate what the auditor reviewed, to
assure compliance with the quality assurance program and to
determine the scope of the audit.
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7.
Document Control Program
The inspector reviewed the program to verify the administrative
controls and implementation of the program were within the require-
ments as setforth in the Prairie Island Operational Quality Assurance
Plan.
a.
Documentation Reviewed
OQAP 8.0, Document Control
OQAP 7.0, Instruction, Procedures and Drawings
5 ACD 4.4, Drawing Control
b.
Findings
No items of noncompliance or deviations were identified.
8.
Design Change / Maintenance Programs
These areas were reviewed to verify that they are being controlled
inaccordancewiththeOperationalQualityAssurancePla9('andthat
previous concerns in these areas had been adegaately resolved,
a.
Documentation Reviewed
5 ACD 6.1, Design Change Control
5 ACD 3.2, Work Request and Work Request Authorization
5 ACD 14.5, Inspection Program
5 ACD 3.1, Prairie Island Plant Organization
5 ACD 3.9, Bypass Control
b.
Findings
Noncompliance (50-282; 306/81-01-05)
10 CFR 50, Appendix B, Criterion V states"... Activities affecting
quality shall be prescribed by documented instructions, procedures
...and shall be accomplished in accordance with the e instructions
procedures, or drawings."
5 ACD 6.1, Design Change Control, revision 7 requires that the
Responsible Engineer shall be responsible for ensuring timely
(three months after installation) close out of design changes
and preparing training material and assuring that affected
plant staff personnel are appropriately trained.
Contrary to the requirement in procedure 5 ACD 6.1, the inspector
found that the following design change packages had not been
closed out three months after installation:
79L519; 80L574;
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79L564.
In addition, for design change 79L564 it was found
that training, regsrding this change, had not been documented
on form 3-3017-10 as required in section 6.3.12 of 3 ACD 4.1.
With regard to the close out of design changes three months
af ter installation, the inspector notes that the plant staf f
has been completing design changes in a timely manner. However,
it appears that delays in close out of design changes are being
encountered in the General Office. These delays appear to
involve drawing revisions,
c.
Discussion
The following concerns were discussed with licensee personnel:
(1) Procedure revisions resulting from Design Changes are not being
issued at the time that the modified system or equipment is re-
turned to service.
In one case, a modification was completed and
put into service and two months later procedure revisions were
issued.
(2) QA/QC is not reviewing the design change packages when they
are closed out.
When the quality section reported to the
PlantSuperintendent Engineering and Radiation Protection he
was responsible for reviewing the completed design change
package.
(3)
Inspection Program procedure 5 ACD 14.5, has not been fully
implemented. This was identified in a licensee internal audit.
(4) The licensee has identified that annunciator response procedures
do not meet the format requirements of ANSI N18.7.
The licensee
has formed a Task Group (No. 80-04) to upgrade the existing an-
nunciator procedures.
Completion of this task is scheduled for
January, 1982.
These items will be reviewed during subsequent NRC inspections.
9.
Fire Fighting Equipment and Systems
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a.
Manual Fire Fighting Equipment
The inspector examined the licensees manual fire fighting equip-
ment including hose and standpipe stations, fire extinguishers,
self contained breathing apparatus, fire fighting protective
clothing and other equipment available for fire fighting. The
equipment availability was reviewed using the commitments contained
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in the Fire Protection Safety Evaluation Report (FPSER) dated
September 6, 1979 with supporting licensee transmittals and re-
quirements contained in the plant technical specifications.
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(1) Documents Reviewed
SP 1606, Monthly Respiratory Protection Check
SP 1183, Monthly Fire Extinguisher / Hose Station Inspection
and Annual Hose Station Inspection
SP 1183a, Containment Fire Extinguisher Placement and Hose
Station Inspection
SP 1203, Fire Hose Hydrostatic Test
SP 1664, Monthly Fire Fighting Equipment Check
FS, Fire Fighting
(2) Findings
No apparent items of noncompliance or deviations were iden-
tified in this area.
,
,
(3) Discussion
The inspector reviewed the results of the surveillance
procedures for manual fire fighting equipment listed below.
Procedure No.
Compeletion Dates of Reviewed Procedures
SP 1606
August 1980, September 1980, October 1980,
November 1980 and December 1980
SP 1183
November 1980 and December 1980
SP 1183a
Unit I: July 1980, September 1980 and
October 1980
Unit II: May 1980
SP 1664
December 1980
The documentation and results of these surveillance pro-
cedures are acceptable. The procedures have been performed
during the required periods of time.
Applicable Technical
Specification surveillance requirements for fire fighting
equipment have been satisfied.
Surveillance procedure SP 1203 is a new procedure.
SP 1203,
concerning fire hose hydrostatic tests, will be implemented
starting this year. Hoses were hydrostatically tested by the
manufacturer when they were purchased.
The inspector verified
documentation of the manufacturer testing on randomly selected
hoses *.hroughout the plant by examining the test results sten-
ciled on the hose jacket.
SP1203 was reviewed for content and
appeared adequate. No results from this surveillance were
examined.
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.
The inspector examined selected fire fighting equipment
lockers in the following locations during three plant tours.
Auxilliary Building Access Control
Turbine Building Access Control
Unit I Turbine Building 695 foot Level
Breathing Oxygen Bottle Refill Station
The equipment at these locations agreed with the equipment
list in FS, Fire Fighting and satisfied the equipment re-
'
quirements in the FPSER modifications sections 3.1.8, 3.1.10,
3.1.11 and 3.1.15.
Also, during the plant tours, the inspector examined selected
fire extinguisher and hose and standpipe stations. Minor
problems were identified. The licensee was made aware of
these concerns during the exit interview and agreed to examine
them.
b.
Automatic Fire Detection and Suppression Systems
The inspector examined the licensee's automatic fire detection
and suppression systems including the fire water system, cardox
,
system, detection system, pentration fire barriers and fire
doors. These systems were reviewed using information in the
Prairie Island Nuclear Generating Plant Fire Hazards Analysis,
commitments in the FPSER with supporting licensee transmittals
on fire protection and requirements in the plant Technical
Specifications.
(1) Documents Reviewed
SP 1189, Safety-Related Fire Detector Check
SP 1187, Diesel Driven Fire Pump Battery Inspection
PM 3122-1, Diesel Driven Fire Pump Annual Inspection
l
PM 3122-2. Diesel Driven Fire Pump Two Year Inspection
SP 1197, Fire Protection System Header Flush
SP 1660, Winterization of Hydrant and Roof Hose Station.
SP 1053, Monthly Fire Pump Running Test
SP 1524, Diesel Driven Fire Pump Weekly Running Test
SP 1202, Fire Pump Test
SP 1195, Fire Protection System Valve Cycle Checklist
SP 1200, Fire Protection System Supply Valves to Safety-Related
Areas
SP 1196, Fire Protection System Spray and Sprinkler Test
SP 1188, CO System
2
SP 1194, Fire Protection System Cardox (CO ) System Test
2
SP 1192, Safeguard Electrical and Mechanical Penetration
Surveillance Inspection
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SP 1601, Fire Alarm and Emergency Evacuation Test
.
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PM 3122-3, Fire Door Mechanical Inspection
5 ACD 9.2, Control of Electrical Penetrations / Openings and
1
Cable Runs
>
D.52, Inutallation Guidelines for the Permanent and Temporary
Sealing of Electrical and Mechanical Openings between
Established Fire Zones
(2) Findings
No apparent items of noncompliance or deviations were iden-
tified in this area.
(3) Discussion
The inspector reviewed the results of the surveillance pro-
cedures for automatic fire detection and suppression systems
and equipment listed below.
Completion Dates
Procedure No.
Frequency
Of Reviewed Procedures
SP 1189
6 Months
January 1980 and July to
September 1980
SP 1187
1 Week
January 1980 through November 1980
PM 3122-1
1 Year
June 1978, June 1979 and May 1980
PM 3122-2
2 Years
June 1978 and May 1980
SP 1197
1 Year
May 1980
'.
SP 1660
1 Year
October 1980
SP 1524
1 Week
October 1980 through December 1980
SP 1202
18 Months
April 1930
SP 1195
1 Year
July 1979 and July 1980
SP 1200
1 Month
January 1980 through December 1980
SP 1188
1 Week
January 1980 through December 1980
SP 1194
18 Months
June 1979
SP 1192
18 Months
June 1979
SP 1601
1 Month
January 1981
Surveillance procedure SP 1196, concerning the spray and
sprinkler systems is a new procedure. A work request was
used the last time that this surveillance was performed.
The inspector reviewed the procedure and results on the
wark request.
The documentation and results of the above referenced surveil-
lance procedures appeared to be acceptable. The procedures
have been performed during the required periods of time.
Ap-
plicable Technical Specification surveillance requirements for
i
fire protections systms are being satisfied.
'
no a plant tour, the inspector examined ten percent of
4
u.
the fire system valves. These valves were found to be in
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.
the proper position and supervised with wire seals.
Selected
penetration fire barriers and fire doors were examined and
found to be intact and operable. The inspector examined the
fire detection system panel in the control room. This panel
appeared operational.
c.
Procurement Control of Fire Protection Equipment
The inspector examined the licensees fire protection equipment
procurement control. The controls were reviewed using the require-
ments contained in 5 ACD 3.13, Revision 2.
(1) Documents Reviewed
5 ACD 3.13, Fire Preventive Practices
Purchase Orders
(2) Findings
No apparent items of noncompliance or deviation were iden-
tified in this area.
(3) Discussion
The inspector examined the following purchase orders to
verify implementation of 5 ACD 3.13, Section 6.10.1.
Purchase
Fire Protection
Review Completed And
Order No.
Review Specified
Equipment Specs. Listed
MQ 05690
Yes
Yes
MQ 05341
Yes
Yes
MQ 05375
Yes
Yes
M 42033
Yes
Yes
MQ 05202
Yes
Yes
M 07167
Yes
Yes
G 631660*
Yes
Yes
- Purchase Requisition
The fire protection system procurement control appears to be
adequately implemented.
10.
Fire Protection / Prevention Administrative Controls
'
a.
Fire Emergency and Fire Fighting Procedures
The inspector examined the licensees emergency response procedures
and fire fighting stratagies. The procedures and stratagies were
reviewed using the commitments contained in the FPSER dated
September 6, 1979 with supporting licensee transmittals.
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.
(1) Documents Reviewed
5 ACD 13.3, Fire Preventive Practices
FS, Fire Fighting
F5 Appendix A, Fire Stratagies
(2) Findings
No apparent items of noncompliance or deviations were identified
in this area.
(3) Discussion
The inspector reviewed the fire emergency response procedures
in Section F5. The procedures outline acceptable actions to be
followed by the individual discovering the fire, the control
room personnel, the fire brigade, and other plant personnel in
the event of a fire.
The inspector reviewed the fire stratagies contained in Sec-
tion FS, Appendix A for fire detection zones 1, 4, and 12.
The fire stratagies contain all of the information which the
licensee committed to provide. The stratagies are functionally
organized and appear to provide acceptable fire brigade re-
sponse information when used in conjunction with a modified set
of plant drawings that show zone boundries and detector loca-
tions. A set of all these documents and drawings is on file
in the control room. These documents satisfy the modification
requirements in the FPSER Section 3.1.14.
b.
Ignition Source and Combustible Materials Control
The inspector examined the licensee's administrative controls of
ignition sources and combustible materials. These controls were
reviewed using the commitments contained in the FPSER dated
September 6, 1979 with suppozting licnesee transmittals.
(1) Documents Reviewed
5 ACD 3.13, Fire Preventive Practices
Hot Work / Flammable Material Use Permit
Extended Hot Work / Flammable Material Use Permit
5 ACD 8.5, Housekeeping and Cleanliness
SWI-0&M-3, Nuclear Plant Helper Claaning Assignments
SWI-0&M-9, Control of Combustible Materials at Job Sites
SWI-0&M-12, Housekeeping Zone Designation and Maintenance
(2) Findings
No apparent items of noncompliance or deviations were iden-
tified .
this area.
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.
(3) Discussion
The inspector reviewed 5 ACD 3.13 and 8.5 and SWI-0&M-3, 9
'
and 12. These documents describe acceptable controls for
the use, storage and movement of combustible materials.
5 ACD 3.13 also deliniates acceptable controls for ignition
sources. The inspector reviewed the following work requests
to verify proper review for fire hazards and, when required,
proper implementation of the hot work / flammable material use
pe rmit .
Work
Fire Hazards
Pe rmit*
Permit
Request No.
Analysis Completed
Required
Completed
D 2461-SE-Q
Yes
No
-
D 7367-FP
Yes
No
-
D 7230-SE-Q
Yes
No
-
E 0057-MP
Yes
Yes
Yes
E 0003-DC-Q
Yes
No
-
D 7000-RD-Q
Yes
No
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E 0053-C0
Yes
No
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D 6701-ZG-Q
es'
Yes
Yes
D 6702-ZG-Q
Yes
Yes
Yes
D 7189-DE
Yes
No
-
D 6810-SI
Yes
No
-
D 6802-MP
Yes
No
-
- Hot Work / Flammable Material Use Permit
During a plant tour the inspector observed acceptable control
of combustible materials and ignition sources including smoking.
Combustibles were stored in designated areas and lockers and
these areas were neat and orderly. Welders had followed
appropriate precautions in performing their work.
c.
Fire Protection Audits And Inspections
The inspector examined the audits and inspections of the licensee's
fire protection and prevention program. These audits and inspec-
tions were reviewed using the commitments contained in the FPSER
dated September 6, 1979 with supporting licensee transmittals and
the plant Technical Specifications.
(1) Documents Reviewed
5 ACD 3.13, Fire Preventive Practices
Prairie Island Nuclear Generating Plant Technical Specifications
QA Audits of 5 ACD 3.13
Fire Issuance Inspection
NSP Corporate Fire Protection Inspection
Kopp and Associates Fire Protection Inspection
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(2) Findings
No apparent items of noncompliance or deviations were
identified in this area.
(3) Discussion
.
The inspector reviewed the QA audits of 5 ACD 3.13 condected
on July 30, 1979 and June 26, 1980. The audits satisfac-
torily examined the provisions in the ACD. Two open items
remain from these audits.
' .
The first open item, QAF No. 31 (December 18, 1978), con-
cerned incomplete fire hazards reviews on work reguests.
The inspector reviewed twelve work requests which all had
completed fire hazards analysis. The second open item,
QAF No. 43 (December 30, 1979) concerned the lack of fire
extinguishers on contractors welding / burning equipment.
Since this item was identified, 5 ACD 3.13 has been revised
and this is no longer a requirement.
The inspector reviewed three audits by offsite organization.
The first audit in February, 1979, by Kopp and Associates,
i
a fire protection consultant, was an indepth analysis of
fire protection at Prairie Island. All recommendations
resulting from the audit were acceptably closed. The
second audit performed by NSP corporate office personnel
in June,1980 and the third audit performed by the licenees
fire insurance company in June, 1980 were acceptably closed.
These audits satisfy the plant Technical Specification re-
quirements, part 6.3.1 for special inspections and audits.
11.
Fire Protection and Prevention Training Program
a.
General Employee and Contractor Training
The inspector examined the licensee's fire protection and
prevention training program for general employees and contrac-
tors. The program was reviewed using the requirements in the
FPSER dated September 6, 1979 with supporting licensee trans-
mittals as modified by the letter from the licensee dated
November 1, 1979.
(1) Documents Reviewed
3 ACD 3.5, Training
5 ACD 3.11, Plant Training Program
Employee Training Records
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(2) Findings
Unresolved Item (50-282; 306/81-01-06)
The letter from the licensee to the Office of Nuclear
Reactor Regulation dated November 1, 1979, concerning fire
protection administrative controls indicated that the fire
protection training program would be implemented through
revision to plant procedures and ACD's.
The revision to
the training program procedures and ACD's was not cor- 4eted
at the time of this inspection. This is considered an
unresolved item and will be examined during a future in-
spection.
No apparent items of noncompliance or deviations were iden-
tified in this area.
(3) Discussion
The inspector reviewed 3 ACD 3.5 and 5 ACD 3.11 and partic-
Ipated in the general employee training for clean and
controlled areas. This program is not in accordance with
the proposed program as described in the letter from the
licensee dated November 1, 1979. Topics that were not
covered completely include fire chemistry and physics and
fire detection systems. This is referred to as Level I
training in the licensee's program description.
The training records for 15 plant employees were reviewed.
All of the employees had received the required training
and documentation was complete.
b.
Fire Brigade Training and Qualifications
The inspector examined the licensee's training and qualifica-
tion program for the fire brigade including classroom training
practice sessions, drills, respiratory protection training, and
medical qualifications. The program was reviewed using the re-
quirements in the FPSER dated September 6, 1979 with supporting
licensee transmittals as modified by the letter from the licensee
dated November 1, 1979.
(1) Documents Reviewed
3 ACD 3.5, Training
5 ACD 3.11, Plant Training Program
Fire Brigade Training and Practice Records
Fire Drill Critique Records
5 ACD 3.13, Fire Preventive Practices (Revisions 1 and 2)
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.
(2) Findings
Unresolved Item (50-282; 306/81-01-07)
The letter from the licensee to the Office of Nuclear
Reactor Regulation dated November 1, 1979 concerning fire
protection administrative controls indicated that the fire
brigade training program would be implemented through
revision to plant procedures and ACD's.
The revision to
the training program procedures and ACD's was not completed
at the time of this inspection. This is considered an un-
resolved item and will be examined during a future inspection.
No apparent items of noncompliance or deviations were iden-
tified in this area.
I
(3) Discussion
The inspector examined the training records for twenty
percent of the fire brigade members. This included approx-
imately twenty percent of the personnel in the following
!
job categories: shift supervisors, lead plant equipment
and reactor operators, plant equipment and reactor operators,
assistant plant equipment operators and plant attendants.
Records were examined for each individual in the areas of
classroom training and retraining, practice sessions,
medical qualifications and respiratory protection training.
All of the individuals, except one, had received classroom
training in May, 1979. The exception was one new employee
who had received classroom training in June, 1980. No
evidence of the annual retraining (as required in the
letter of November 1, 1979) could be identified. All
of the individuals, except one, had attended a practice
session in October, 1980. The exception was one shift
!
supervisor who was physically unable to attend the session
j
due to a medical problem. There was no identifiable
i
evidence that this individual has been required to partic-
ipate in the alternate training as prescribed in 5 ACD 3.13,
Revision 2.
All of the individuals had received the re-
quired annual medical examination and respiratory training.
The inspector reviewed the training syllabus for the
classroom training and practice sessions. The topics
covered in these training sessions cover an acceptable
spectrum of fire protection principles.
Records for the fire drills and the drill critiques for
drills conducted in 1980 were reviewed. Attendance was
checked for all fire brigade members. The NRC position
on fire drills for each brigade as stated in 10 CFR 50,
Appendix R, paragraph III.I.3.b. is that there should be
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four drills per year at regular intervals not to exceed
three months. Also stated in this paragraph is the NRC
position on fire brigade member participation in drills
which reads as follows: "Each fire brigade member should
participate in each drill, but must participate in at
least two drills per year."
The drill attendance records revealed that 58% of the fire
brigade leaders (shift supervisors) and 14% of the brigade
members (assistant plant equipment operators and plant
attendants) had not participated in the minimum acceptable
member of drills for qualification as a fire brigade
member (two drills per year).
None of the licensed plant
equipment and reactor operators had participated in the
minimum number of drills.
Persons not participating in the minimum number of drills
per year are not considered qualified to satisfy the
minimum staffing requirements for the fire brigade.
12.
Housekeeping / Cleanliness Program
The inspector reviewed the licensee's housekeeping and cleanliness
program to verify that proper administrative controls have been
implemented to assure the quality of safety related systems. The
program was reviewed using the requirements contained in ANSI
N45.2.1 - 1973Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.1 - 1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. and ANSI N45.2.3 - 1973 as modified by ANSI
N18.7 - 1976Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7 - 1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
a.
Documents 3eviewed
5 ACD 8.5, Housekeeping and Cleanliness
SWI-0&M-3, Nuclear Plant Helper Cleaning Assignments
SWI-0&M-9, Control of Combustible Materials at Job
Sites
SWI-0&M-12, Housekeeping Zone Designation and
Maintenance
b.
Findings
No items of noncompliance or deviations were identified in this
area.
c.
Discussion
The requirements of ANSI N45.2.3 - 1973 are satisfied by
5 ACD 8.5 and SWI's-0&M-3, 9 and 12.
Zone designations have been
established with cleanliness requirements for each zone.
Cleaning
instructions have been established and icplemented. A requirement
has been established for periodic housekeeping inspections, but
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.
the inspection procedure has not been implemented. The inspector
indentified minor housekeeping problems in various areas of the
p l a n +. . These items were discussed with the licensee at the exit
interview.
The licensee has not established fluid systems cleanliness pro-
cedures. The requirements of ANSI N45.2.1 - 1973 are implemented
through special instructions on the WR/WRA forms.
13.
Exit Interview
The inspectors met with the licensee representatives (denoted in
paragraph 1) at the conclusion of the inspection on January 8, 1981.
The purpose and scope of the inspection was summarized and the in-
spectors then discussed the enforcement findings in each area.
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