ML20065D986

Responds to NRC Re Violations Noted in Insp Repts 50-282/90-12 & 50-306/90-12.Corrective Actions:Procedures Governing Surveillance Schedule Changes Will Be in Place by 901031

ML20065D986
Person / Time
Site:	Prairie Island
Issue date:	09/24/1990
From:	Eliason L NORTHERN STATES POWER CO.
To:	Beverly Clayton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9010010179
Download: ML20065D986 (5)

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D"s - Northem States Power Company -

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P< , Prairie Island Nuclear Generating Plant _

1717 Wakonade Dr. East-Welch, Minnesota $5089 M

1 1 Septiember 24, 1990 L .,

t h - dr B Clayton, Chief _ '

Projects- Branch 2. Region III

- U S. Nuclear Regulatory Commission

? 799: Roosevelt Road

. - Glen Ellyn,f1111nois E 60137 PRAIRIE IS1AND NUCLEAP, GENERATING PIANT Docket Nos. 50 282 License Nos. DPR-42 50-306 DPR 60 Response to Notice of Violation Insoection Reoorts No. 50-282/90012(DRP) and 50-306/90012(DRP) s s

.In response to your letter of August 27, 1990, which transmitted Inspection-Reports'No. 282/90012 and 306/90012, the following information is offered.

_-o Violation #1'

' Technical Specification 3.6.H. Shield Building' Ventilation System allows-only one train to be inoperable with reactor coolant system x average. temperature abovel200* F. With both trains inoperable.

Technical ~ Specification 3.0'.C applies and states in part; when a Limiting Con'dition for operation is not met, and required action is nct specified or cannot be' satisfied, within one h.ur initiate the ..

action necessary to place the affected' unit in-a condition in which, the equipment is not required to be:0PERABLE.

Contrary to the .above, on June 27, 1990, with Unit 1 above 200* F, from approximately 8:20-_a.m, to 10:10 a.m., both the Number 11 and 12 Shield Building Ventilation Systems were rendered inoperable by the improper opening = of the Number 11 exhaust fan breaker. Action was not initisted to place' Unit 1-in a. condition for which the. Shield Building V ntilation System was not required to be operable ~ within one hour (132/90012-02).

This u, a Severity Level IV Violation (Supplement ;I) .

Resoonse O '10 F' Preveritive maintenance was scheduled for the No.12 Shield Building 9010010179 900924 PDR O

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-September 24, 1990-  ;

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' Ventilation System. Exhaust Fan, the' Recirculation Fan, and the filter heater

-contactors. Prior to maintenance.beginning,.the three respective isolation

' breakers were to be turned off. The breakers-for the Recirculation' Fan and '

the- filter ; heater were properly turned off. When maintenance was to begin_at

1005,itfwas;discoveredthatNo. 11 Exhaust Fan-breaker had been turned off instead of No. 12~ Exhaust Fan breaker. This made~the No. 11 Exhaust Fan-inope rable '. .Since the No. 12 Exhaust Fan (whose-breaker was left on) is  ;

interlocked with No. 12 Recirculation Fan (whose breaker was turned off), the No. 12 Exhaust Fan was also inoperable. 'The exhaust fan can only run when the-recirculation fan is running. The initial evaluation concluded that both trains of the Shield Buildins Ventilation System had been made inoperable, '

since no Shield Building Exhaust Fans were operable. At 1010, the breaker for No. 11 Shield Building Exhaust Fan was turned on.

The violation states that no action was taken within one hour to change the plant condition. Technical Specifications Section 3.0.C states, " Time- ,

limitations specified by the applicable Limiting Condition for Operation L actions are measured from the time of discovery of the failure to meet the Limiting Condition for Operation." Section 3.0.C allows one hour to initiate action to place the affected unit in a condition in which the equipment is not required to be operable. 'No action was taken to place-Unit 1 in a condition for'which the Shield ' Building Ventilation ' System operability was not required, l

.since the No. 11 Shield Building Exhaust Fan breaker was turned on within 5' minutes of discovering it in the off position. ,

f The incorrect breaker had been turned off. the preventive maintenance procedure contained an error in component numbering,- The motor number and component description given in the text of the procedure were correct, but the  !,

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H Motor Control Center number given at the top.of each page of the. preventive

-maintenance procedure was incorrect. The workman turned off the breaker L corresponding to the incorrect Motor Control' Center number.

I I l :The safeguards function of the Shield Building Ventilation System is to

, collect, mix and filter air leakage from the containment vessel to the-annulus

'- following a postulated accident before it is either recirculated or discharged to.the atmosphere. If the Shield Building Ventilation System had been called

, uoon to actuate while in this condition, only No. 11 Shield Building

! kecirculation Fan and its particulate absolute charcoal filter would have l

operated. However, a test performed on June 13, 1990, shot-d that with both  ;

exhaust fans and one recirculation fan disabled, the required drawdown and performance characteristics of the Shield Building Ventilation System detailed

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Note that the recirculation fan provides in. Tech Spec 4.4B-1 were still met.

l- both recirculation and exhaust flow. Flow capacity of a recirculation fan is 5000-cfm,-while the flow capacity of an exhaust fan is only 200 cfm.

Therefore, the Shield Building Ventilation System was capable of performin5 L its safeguards function in this degraded eondition.

This event was reported as Unit 1 LER 90-008.

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September 24, 1990 Page.3~

t Corrective ~ Action Taken and Results Achieved i At' discovery, the' breaker for No. 11 Shield Building Exhaust-Fan was turned on "

-and an operability test for Train A was done. Motor Control Center preventive

= maintenance procedures for all other safeguards equipment were reviewed for similar errors. One other error was found and corrected.

Corrective Action to Avoid Further Violations Routinely, isolations for Motor Control Center preventive maintenance have .

been performed by the personnel performing the maintenance. Procedures will.

be revised to involve operations personnel in the performance of equipment isolations; this will-have the effect of getting another review of these isolations.

Date When Full Como11ance Will be Achieved Full compliance has been achieved.

Violation 42 Technical Specification 4.1 specifies minimum frequency and types of surveillance to be applied to plant equipment and conditions. l Technical Specification 4.0 states, in part, that the specific time intervals between tests may be adjusted plus or minus 25 percent to accommodate normal test schedules. Technical Specification 4.1.A requires calibration, testing and checking of instrument channels be

+ performed as specified by Table T.S. 4.1-1.

Contrary to the above:

a. The instrument channels (item 32) for RTD (reactor coolant) i Bypass Flowneter are to be functionally tested monthly by L Surveillance Procedure SP1042, Resistance Temperature Detector L (RTD) Bypass Flowmeter Functional Monthly Test. Surveillance l procedure SP1042 was due to be performed no later than April 16, l

1990, and was not completed until April 24, 1990 (282/90012-03A; L

306/90012-03A),

b. The instrument channels (item 35b) for radiation monitors (listed in Table T.S. 3.15-2) are to be functionally tested monthly by Surveillance Procedure SP1028, Radiation Monitoring System Test. Surveillance Procedure SP1028 was due to be

• performed no later than April 18, 1990. The test was not performed until April 20, 1990 (282/90012-03B; 306/90012-03B).

This is a Severity Level IV Violation (Supplement I).

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.Resoonse to' Violation 42a.

SP10421s' a monthly functional test of the reactor coolant system RTD-bypass .

Eloop flow meters.1 The scheduled-due date for completion of SP1042 for the  ;

month of April was April 16, 1990. Technical Specification Section 4.0 allows f surveillance test due dates to be adjusted plus or minus 25% to accommedate e normal test schedules.. The last day of the 25% grace period for the April performance of SP1042 was April 23rd. ' +

The I&C supervisors, one assigned to each unit, are responsible for the' I

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i scheduling and performance of the I&C surveillance procedures. The Unit 1 I&C supervisor was aware that April 23 was the last day of 25% graco period -

for the completion of SP1042 for the month of April. F - .ser, the Unit 1 I&C 4 supervisor. was not'onsite on April 23, and he failed to assign an I&C s -technician to: perform SP1042 prior to his departure.

The Unit .1 I&C supervisor noticed on his return to work on April 24, 1990 that

-SP1042 had not been performed on April 23 as required. The Unit.1 I&C

supervisor immediately assigned an I&C technician to perform SP1042 and it was satisfactorily completed on April 24, 1990.

l This : event was reported as Unit 1 LER 90-004.

Corrective Action Taken and Results Achieved l N

SP1042 was satisfactorily performed immediately upon discovery that it had not f been completed within the required time period.

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L M Corrective Action to Avoid Further Violations As;a result of this event, the two I&C supervisors (one for each unit) will <

perform daily reviews of each other's surveillance schedules. This will provide increased assura .ce that surveillance procedures will be performed i within the required time periods.

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-Date When Full Comoliance Will be Achieved h .

. Full compliance has been achieved.

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c- 1 F -B Clayton L September 24, 1990 V Page S:

t Resoonse t'o Violation d2b h .

i SP1028 is a' monthly functional test of the Radiation Monitoring Sysrem. .The scheduled;due date for completion of SP1028 for the month of April was April. $

' 4, 1990. Technical Specification Section 4.0 allows surveillance test due 1

- dates to be adjusted plus or minus 25% to accommodate normal test schedules.

The'last day of the 25% grace period for the April. performance of SP1028 was '

April 11, 1990, but the test was not done until April 20, 1990.

Plant surveillance testing is done in accordance with a master surveillance 4 < schedule. .The Radiation Protection group uses the master schedule to generate '

their own surveillance schedule which is then incorporated into an

.all-inclusiJ work schedule for the group.

On March 15, 1992 *he plant Quality Assurance group pointed out, for a few surveillance proceu. '- hat there were discrepancies between the due dates ,

shown on the master - " _ilance schedule and the Radiation Protection group' schedule. =Between h. con 15 and March 21, 1990, the Radiation Protection Supervisor and the plant Surveillance Coordinator conferred to resolve the discrepancies. As a-result, both the. master schedule and the Radiation Protection group's schedule were changed. SP1028 was rescheduled from April 4-to April' 25, 1990. The Surveillance Coordinator pointed out the need for an L. - additional test,.since the-new due date had been advanced three weeks. Later discussions batween the Radiation Protection Supervisor and his supervisor

• resulted in the mistaken belief that the additional test was not' required and  ;

. was not performed. ,

Radiation Protection personnel misunderstood the necessity for performing an l' additional test. Contributing to the cause was the lack of a written policy l on rescheduling surveillance tests.

l This event was reported as Unit 1 LER 90 010.

' Corrective Action Taken and Results Achieved.

I 1 Plant administrative control documents governing surveillance schedules have been modified to prevent the need for similar rescheduling.

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Corrective Action to Avoid Further Violations

- Procedures governing surveillance schedule changes will be in place by October

. 31, 1990.

l Date When Full Como11ance Will be Achieved Full compliance has been achieved.

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,'B'Clayton-J ti, ' q, September, 24,.1990  ;

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,. Please contacc: us if. you have' any questions related to our response to th,e

+l o . ,.  : subj ect inspection- reports , .

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n.. ' nLeon- R~ Eliason - i Vice President' -j p ,

Nuclear Generation- l tj c: Regional Administrator III, NRC

'1 Senior Resident: Inspector, NRC

, NRR Project Manager, NkC .i G Charnoff- '

.NRC Document Control' Desk ,

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