ML20050L400

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IE Insp Repts 50-282/82-04 & 50-306/82-04 on 820201-28. Noncompliance Noted:Failure to Close Out Design Changes within 3 Month Period Following Installation
ML20050L400
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 03/29/1982
From: Burgess B, Feierabend C, Nelson R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20050L191 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.2.1, TASK-1.C.5, TASK-1.C.6, TASK-2.E.1.1, TASK-TM 50-282-82-04, 50-282-82-4, 50-306-82-04, 50-306-82-4, NUDOCS 8204140283
Download: ML20050L400 (11)


See also: IR 05000282/1982004

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No:

50-282/82-04; 50-306/82-04(DPRP)

Docket No:

50-282; 50-306

License No: DPR-42;DPR-60

Licensee: Northern States Power Company

414 Nicollet Mall

Minneapolis, MN 55401

Facility Name:

Prairie Island Nuc1 car Generating Plant

Inspection At: Prairie Island Site, Red Wing, MN 55066

Inspection Conducted: February 1-28, 1982

Inspectors:

A

5 /4/ ['

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C. D. Feierabend

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fu ^Ch

g

B. L. Burgess

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Approved By.

p

R.

Nelson, Acting Chief

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Reactor Projection Section 2C

Inspection Summary

Inspection on February 1-28, 1982 (Report No. 50-282/82-04 ; 50-306/82-04(DPRP)

Areas Inspected: Routine resident inspection of plant operation, maintenance,

surveillance, security, training, radiation protectio 1,

followup of TMI-2

items, review of plant trip, shipment of radioactive wasta and design change

control. The inspection involved a total of 121 inspector hours onsite by 2

NRC inspectors including 34 inspector hours onsite during off-shifts.

Results:

Of the ten areas inspected, no apparent items of noncompliance or

deviations were identified in nine areas, one item of noncompliance was iden-

tified in the area of design change control. (Paragraph 8)

8204140283 820329

PDR ADOCK 05000282

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PDR

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DETAILS

1.

Personnel Contacted

  • F. Tierney, Plant Manager

J. Brokaw, Plant Superintendent, Operations and Maintenance

  • E. Watzl, Plant Superintendent, Plant Engineering and Radiation Protection

D. Mendele, Superintendent, Operations Engineering

D. Schuelke, Superintendent, Radiation Protection

  • K. Albrecht, Superintendent, Quality Assurance
  • J. Goldsmith, Superintendent, Nuclear Technical Services

M. Klee, Superintendent, Nuclear Engineer

R. Lindsey, Superintendent, Operations

R. Stenroos, Assistant Radiation Protection Superintendent

J. Nelson, Superintendent, Maintenance

J. Iloffman, Superintendent, Technical Engineering

  • E.

Sabaitis , Project Engineer

D. Silvers, Quality Assurance Engineer

A. Ilunstad, Staff Engineer

A. Smith, Senior Scheduling Engineer

S. Northard, Nuc1 car Engineer

J. Curtis, Engineer

D. Brown, Engineer

B. Frazer, Engineer

G. Lenertz, Engineer

G. Miller, Engineer

T. Thomas, Engineer

B. Stephens, Engineer

K. Bendell, Engineer

R. Oc1schlager, Engineer Associate

D. Cragoe, Shift Supervisor

P. Ryan, Shif t Supervisor

M. Balk, Shif t Supervisor

D. Walker, Shift Supervisor

  • Denotes those present at the exit interview.

2.

Operational Safety Verification

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a.

General

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Unit 1 operated routinely throughout the month.

Unit 2 tripped from 1007. power on 2/24/82 and returned to power op-

eration the same day. The trip resulted from an operator failing to

place feedwater into manual control prior to performing steam genera-

tor level logic test.

The unit operated routinely through the rest

of the month.

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b.

Control Room Observations

The inspector observed control room operation, reviewed applicable

logs, conducted discussions with control room operators, and observ-

ed shift turnovers. The inspector verified the operability of selec-

ted emergency systems, reviewed equipment control records, and ver-

ified the proper return to service of affected components.

c.

Tours

Tours of the auxiliary and turbine buildings and external areas were

conducted to observe plant equipment conditions, including potential

fire hazards, and to verify that maintenance work requests had been

initiated for equipment in need of maintenance.

No items of noncompliance were identified.

3.

Surveillance

The inspector witnessed portions of surveillance testing of safety re-

lated systems and components. The inspection included verifying that

the tests were scheduled and performed within Technical Specification

requirements, observing that procedures were being followed by qualified

operators, that LCO's were not violated, that system and equipment re-

storation was completed, and that test results were acceptable to test

and Technical Specification requirements.

Tests witnessed included:

a.

SP-1093

Diesel Cencrator Manual and 4KV Voltage Rejection-

Restoration Scheme Test.

The surveillance was performed af ter preventive main-

tenance was completed on D-2 diesel generator. The

test was completed satisfactorily.

b.

SP-1113

Annual Steam Exclusion Damper Inspection.

The test is performed to verify that the steam ex-

clusion dampers are seated properly and that damper

seating surfaces are not distorted or damaged. A

visual inspection was made of each damper and minor

gaps were noted between damper seat mating surfaces.

Work requests were written to investigate and repair

as necessary. The dampers were inspected by plant

maintenance personnel. The gaps observed between

damper seat mating surfaces were determined to be

within damper design tolerance.

The licensee plans to revise the surveillance proce-

dure to provide acceptance criteria.

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No items of noncompliance were identified.

4.

Maintenance

a.

Review of Work Request (RR's) and Work Request Authorization (WRA's)

The inspectors selected and reviewed several WR's and WRA's to de-

termine the status of safety related systems, to verify that proper

priorities were given and to verify that design changes were initi-

ated where appropriate.

b.

Observations

The inspectors observed portions of safety related maintenance ac-

tivities to determine that the activities did not violate limiting

conditions for operatbn (LCO's), that administrative approvals

and equipment control tags were completed prior to initiating the

work, that approved procedures were used (or activity was within

the " skills of the trade"), that the procedures used were adequate

to control the activity, and that proper QA/QC controls were used.

Maintenance activities witnessed included:

1) No.122 Control Room Air Chiller IIcat Exchanger Visual and Eddy

.

Current Tube Inspection.

The work was completed satisfactorily and after maintenance sur-

veillance testing was performed prior to returning the No.122

Control Room Air Chiller to service.

2) Steam Exclusion Damper CD-31488.

The inspector observed repair of a steam exclusion damper identi-

fled as inoperabic during surveillance testing. WRA-F0592-VH-Q

documented the work requirements and parts used. A repair part

was installed and the damper tested satisfactorily prior to re-

turning the damper to service.

No items of noncompliance were identified.

5.

Licensee Event Report Followup

a.

P-RO-81-29

4.16 KV Bus Out of Service

(Closed)

The inspector reviewed the event report (LER) to de-

termine that reportability requirements were fulfill-

ed and corrective actions were accomplished to prevent

reoccurrence.

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The original report issued 1/15/82 inaccurately de-

scribed the event. The inspector discussed tha event

with the system engineer to determine exact event de-

tails. Af ter discussion of the event details, the

system engineer agreed to have the LER revised to

accurately describe the event. A revised LER was

issued on 2/12/82.

b.

P-RO-81-30

Degraded Voltage Relay for 4.16 KV Bus 25 Out of

Specification (Closed)

A revised report was issued correcting the event date,

c.

P-RO-81-26

Safeguards Bus Loss of Voltage Protection Relays

Found Out of Specification (Closed)

No items of noncompliance were identified.

6.

TMI-2 Lessons Learned Items

The inspector reviewed the status of several licensee actions in response

to NRC requirements as clarified by NUREG-0737.

Paragraph identification

relates to those paragraphs of NUREG-0737.

a.

1.A.2.1.4.B

Upgrading of R0 and SRO Training and Qualifications.

The inspector has previously reviewed the training

requirements and has periodically monitored SRO and

technical staf f training sessions. The training pro-

gramwasagainreviewedandevaluatypduringreview

of the licensee's training program.-

(Closed)

b.

I.C.5

Provisions for Feedback of Operating Experience to

Plant Staff.

The inspector previously furnished information for

the Safety Evaluation

The evaluation has

beencompletedbyNRR.gyport.

(Closed)

c.

I.C.6

Procedures for Verifying Correct Performance of Op-

erating Activities.

The inspectors had furnished input for the Safety

EvaluatjpnReport. The evaluation has been completed

by NRR.-

(Closed)

1/ IE Inspection Report No. 50-282/81-24; 50-306/81-26.

2/ NRR Letter to NSP dated January 4, 1982.

3/ Ibid.

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d.

II.E.1.1.1

Auxiliary Feedwater (AFW) System Evaluation, Short

Term.

The inspector reviewed the status of completion gf

licensee commitments in response to NRR requests-

for additional information related to AFW system design.

1) Recommendation GS-1 which requires a more restrictive time limit

for inoperable motor-driven auxiliary feedwater pumps.

Licensee Amendments No.46 to OL No.DPR-42 and No.42 (Unit 1)

OL No.DPR-40 (Unit 2) provides the revised LCO.

(Closed)

2) Recommendation GS-2 which requires that the licensee lock open

valves in the AFW pump suction and that could interrupt all

AFW flow.

The licensee has included requirements for locks on the valves

and requirements for monthly verification in the plant Technical

Specifica tion s . The inupector confirmed that procedures have

been implemented.

(Closed)

3) Recommendation GS-4 which requires that emergency procedures be

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available for transfer to alternate water sources.

Emergency Procedure ES, Loss of Feedwater Supply, has been re-

vised to provide the requirements.

(Closed)

4) Recommendation GS-5 which requires capability of providing AFW

flow without an AC power source available.

This requirement was satisfied by eliminating all AC requirements

for system initiation per Recommendation GL-3.

(Closed)

5) Recommendation CS-6 which addresses surveillance procedures to

verify flow path availability of an AFW system flow train that

has been out of service.

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The inspectors have previously verified that licensee procedures

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require independent verification of system alignment by a second

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operator. License DPR-42 Amendment No.45; DPR-60 Amendment No.40

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added the requirement to verify the normal flow path from primary

AFW source to the steam generators.

(Closed)

4,/ NSP Letter to NRR.

Subject: Additb nal Feedwater System Information,

dated November 24, 1981.

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6) Recommendation GS-7 which requires the licensee to verify that

the automatic start AFW signals are safety grade.

The licensee cogfirmed safety grade and described the circuits

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in the response- to NRC request.

(Closed)

7) Additional Short Term Recommendation 1 which requires NSP to

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provide information on condensate storage tank level alarms.

The licensee has provided gydundant alarms as described in re-

sponse to the NRR request.-

The inspector reviewed Design

Change No.79L566 and confirmed that the alarms had been install-

ed as described.

In r

licensee has committed 9pponse to an additional NRR request the

to reroute instrument cables to meet

FSAR criteria for separation. The licensee has initiated Design

Change No.81L676 to provide the required separation. This change

is scheduled to be completed during the next refueling outage,

Unit i now scheduled for November 1982, Unit 2 for August 1982.

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(Open)

8) Additional Short Term Recommendation 2 which requires NSP to

provide information related to auxiliary feedwater pump endur-

ance tests.

The inspector has previously confirmed that the endurance tests

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were completed. Results were satisfactory.

(Closed)

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9) Additional Short Term Recommendation 3 which requires NSP to

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provide information on auxiliary feedwater flow instrumentation.

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This was reviewed in conjunction with NUREG-0737 requirement

Item II.E.1.2.2.C.2.

(Closed)

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e.

II.E.1.1.2

Auxiliary Feedwater Systems Long Term Modification,

1) Recommendation GL-3 which requires independence of the turbine-

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driven auxiliary feedwater pumps from all AC power.

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The inspector had previously monitored installation and testing

of both AFW steam driven pumps following completion of the design

change.

(Closed)

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5/ NSP Letter to NRR.

Subject: Auxiliary Feedwater Systems, dated Novem-

ber 21, 1979.

6/ NRR Letter to NSP. Subject:

NRR Requirements for AFW Systems at Prairie

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Island, dated October 16, 1979.

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7,/ Ibid.

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2) Recommendation GL-4 which requires auxiliary feedwater pumps

to be protected against loss of suction.

The licensee has committed to install los of suction protection

for all AFW pumps.

In response to NRC questions the licensee

has revised the proposed design and has revised Design Change

No.80L579toprovfjetheappropriatepumptripcircuitry. The

licensee response- commits to complete the modification prior

to startup following the next refueling outage of each unit.

The next scheduled outage for Unit 1 is November 1982, and for

Unit 2 is August 1982.

(0 pen)

3) Recommendation GL-5 which requires auxiliary feedwater pump

actuation circuitry to meet safety-grade standards.

The licensee provided documentation for staff review.

No addi-

tional requirements were identified.

(Closed)

4) AFW System Flow Design Basis.

licensee provided9/ the evaluation requested.

(Closed)

The

No items of noncompliance were identified.

6.

Shipment of Radioactive Waste

The inspector monitored licensee activities in preparation for and ship-

ment of radioactive resins via exclusive use vehicle for burial at the

Barnwell, S.C. site.

The inspector observed security and radiation pro-

tection controls established and maintained while the exclusive use vehi-

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cle was onsite, observed receipt inspection of the cask and liner and

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observed portions of the operations associated with filling the cask and

reinstalling the cask covers. The shipment consisted of 107 cubic feet

of resin, activity content approximately 160 C1.

The licensee ALARA program was evident in planning to minimize exposure

to personnel during cask filling operations. This included installation

of additional lead shielding and use of a TV camera to observe fill sta-

tus, minimizing exposure time in the high radiation areas. The licensee

also restricted access to adjacent areas to limit exposure to personnel

involved in performing necessary operation and monitoring the shipment.

8/ NSP Letter to NRR.

Subject: Modification to Provide Auxiliary Feed-

water Pump Protection, dated January 27, 1982.

9,/ NSP Letter to NRR.

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ject: Auxiliary Feedwater System Information,

dated Februa ry 4,1981.

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The inspector reviewed the shipment records, confirmed that required

documentation for the cask was included in the records, verified that

the cask serial number matched the documentation and confirmed that the

shipping records identified the route that the shipment will follow and

that the appropriate state agencies were notified prior to release of

the vehicle from the site.

The inspector independently monitored radiation levels in working areas

during the filling process, during replacement of the cask cover and

after loading was completed. Radiation levels were within acceptable

levels for shipment by exclusive use vehicle. The shipment departed

the site at approximately 1700 on 2/22/82.

No items of noncompliance were identified.

7.

Plant Trip

Prairie Island Unit 2 tripped from 1007. reactor power at 1117 on 2/24/82.

The trip occurred during reactor protection logic surveillance testing

of the loop "A" steam generator (SG) level signal. During a preliminary

step of the procedure, an operator failed to transfer feedwater (FW) to

manual control. When the instrument technician applied a high level sig-

nal to the SG 1evel transmitter the FW control system responded, reducing

feedwater flow. This resulted in a reactor trip by the combined FW/ steam

flow mismatch and SG low level. All systems responded as expected and

systeme were stabilized at hot shutdown conditions.

The inspector observed operator and supervisory response, including re-

sponse of the shif t technical advisor, and observed identification of

the cause prior to authorizing restart. The inspector observed the shift

supervisor notify NRC via the ENS telephone. The inspector also notified

RIII of the plant trip.

The inspector observed preparations for restart, and periodically ob-

served plant operation during restart and return to power. The plant

was back on line at 1413 on 2/24/82.

No items of noncompliance were identified.

8.

Quality Assurance (QA) - Design Changes

During verification of the status of the AFW system and other TMI-2

related modifications, the inspector observed weaknesses in the lic-

ensee's control of design changes. Several design change packages re-

viewed were for work that had been completed several months before the

inspection, but documentation was not complete. Additionally, design

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change packages that could contain QA type records were not being main-

tained in locked cabinets.

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a.

Impicmenting Procedures

The licensee's plant procedure, 5 ACD 6.1 - Design Change Control,

requires that design change be controlled in accordance with cor-

porate procedure 3 ACD 4.1 which implements the licensce's approved

Operational Quality Assurance Plan.

Plant Procedure 5 ACD 6.3 -

Design Change Impicmentation provides additional guidance for imple-

menting the design control process. Review of the impicmenting pro-

cedures and discussions with cognizant licensee personnel confirm

that there is a need to provide requirements for physical security

of QA records and to provide realistic controls for timely compic-

tion of all associated records.

Control for assuring that all areas are addressed prior to approval

appear to be sufficient, however, after approval of the design change

for installation there were no apparent management controls, after

assignment to a Responsible Engineer, until the design change was

complete including all documentation.

The inspector discussed the apparent need for additional controls

with several of the plant technical and support engineers, with

plant QA staff and with plant management at the exit interview. It

was apparent that some of the personnel were either not aware of the

requirement to close a design change within 3 months or were not able

to close them because of the length of time necdal to obtain "as built"

drawing documentation fran architect engineer support contractors.

In two instanceg design changes

No. 80Y105 and No. 80Y109, drawing

change requests had not been submitted although the design changes

had been installed for more than 3 months. For design change No.

80Y129the design change package appeared to be complete, with the

exception of "as built" drawings and data files. The change requests

had been submitted, but revised d. mwings had not been completed.

Failure to ensure timely closcout of design changes is considered to

be not in accordance with the requirement of 10 CFR 50 Appendix B,

as described in the Appendix to the letter forwarding this inspec-

tion report.

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b.

Security of Design Change Packages

The inspector determined that some of the rerords he had reviewed

in the design change package were copies of QA records and others

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had been microfilmed, so were not necessarily QA records, however,

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the probability existed that QA records were included in the pack-

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ages for periods of time. The licensee acknowledged this and has

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taken actions to provide for control of the design package by the

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newly assigned coordinator.

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Contrpffg{jQA records has been discussed . in previous inspection re-

ports

and has been identified as an unresolved item (50-282/

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81-10-01; 50-306/81-11-01). Control of design change records will

be included in future reviews of QA record control with regard to

the unresolved item.

9.

Exit Interviews

The inspector conducted interim interviews during the inspection period

and met with Mr. Tierney and members of his staf f, as identified in Par-

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agraph 1, at the conclusion of the inspection.

The inspector discussed the results of the inspections and stated that

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his observations during recovery from the plant trip and in monitoring

the resin shipment showed that the plant operators and radiation pro-

tection staff performed well.

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The inspector discussed his findings with regard to design change con-

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trols and stated that it was his opinion that the item of noncompliance

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(Paragraph 8) resulted f om a gap in the design change control process

between approval for implementation and the requirement for closeout.

The licensee did not disagree.

The licensee stated that it had been recognized that additional controls

were needed, that additional controls of design change packages were in

the process of being implemented and that discussions of the need for

revising the design change controls were also in progress. These dis-

cussions involve the corporate QA staff and the Monticello staff.

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10/ IE Inspection Report No. 50-282/81-10; 50-306/81-11.

11/ IE Inspection Report No. 50-282/81-24; 50-306/81-26.

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