ML20135D412
| ML20135D412 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/25/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135D385 | List: |
| References | |
| 50-282-97-02, 50-282-97-2, 50-306-97-02, 50-306-97-2, NUDOCS 9703050227 | |
| Download: ML20135D412 (21) | |
See also: IR 05000282/1997002
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION 111
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Docket Nos: 50-282, 50-306
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Report No: 50-282/97002, 50-308/97002 )
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Licensee: Northern States Power Company
Facility: Prairie Island Nuclear Generating Plant
Location: 1717 Wakonade Drive East
Welch, MN 55089
Dates: January 8 - February 20,1997
Inspectors: S. Ray, Senior Resident inspector
R. Bywater, Resident inspector
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Approved by: J. Jacobson, Chief, Projects Branch 4
Division of Reactor T':clects
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9703053227 970225
PDR ADOCK 05000282
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EXECUTIVE SUMMARY
Prairie Island Nuclear Gencrating Plant, Units 1 & 2
NRC Inspection Report 50-282/97002, 50-306/97002
This inspection included aspects of licensee operations, maintenance, engineering, and
plant support performed by the resident inspectors.
Ooerations ,
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e No significant problems were noted with routine plant operations and the conduct
of operations was generally good. (Section 01.1)
e A project engineer showed awareness and a good questioning attitude in identifying
that the auxiliary building crane was not operating as expected. (Section 01.2)
e Failure to identify wiring change in the auxiliary building crane controls during the
purchasing process, receipt inspection, or preventative maintenance prior to its use
for moving a spent fuel cask, indicated weaknesses in the licensee's programs and
was considered a Non-cited Violation. (Section 01.2)
e Operations performance during refueling operations was excellent. Significant
improvements were noted, especially in fuel handling operations, compared to the
previous refueling outage. There were several examples of operators averting
problems by the use of self-checking and a questioning attitude. (Section 01.3)
e The inspectors noted that the licensee had implemented a new fuel movement log
with significant human-factors improvements in its format. (Section 08.1)
Maintenance
e The inspectors identified questions regarding whether the January diesel cooling
water pump surveillance met the requirements of Technical Specifications. The
issue was considered an Unresolved item. (Section M1.1)
e The inspectors identified questions regarding whether the diesel cooling water
pumps needed to be tested from the control room to demonstrate that they could
meet their design basis. The issue was considered an inspection Followup item.
(Section M1.1)
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e The inspectors identified a main steam safety relief, ready to be installed, that was
missing a piece. The inspectors concluded that the system engineer would have
identified the missing piece before the valve was put into service. However, the
finding indicated a potential weakness in the control of salvaging parts from
equipment in the warehouse. (Section M1.1)
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- The licensee identified that they had moved a heavy load over irradiated fuel
without meeting the requirements of their procedures. The event was considered
an Apparent Violation. (Section M1.2)
- The inspectors concluded that refueling outage planning, scheduling, and execution
continued to be a licensee strength. (Section M1.3)
- The inspectors identified that the licensee's heavy load procedure was inadequate
because it did not contain instructions or controls for moving heavy loads using of
mobile cranes near or over safe shutdown equipment. This was considered a
Violation. (Section M3.1)
Enaineerina
- ' The inspectors concluded that system engineer support of the outage activities was
excellent. (Section E2.2)
Plant Suonort
- The licensee was adequately monitciing a major roa>. construction project that
could have an effect on emergency evacuation from the area and emergency
response to the plant. (Section P1)
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Report Details
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Summarv of Pl ant Status
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Unit 1 operated at or near full power for the entire inspection period except for brief power !
reductions for various testing and maintenance activities. Unit 2 operated in a gradual l
power coastdown from full power to about 86% power. On January 24,1997, Unit 2 l
was taken off line for a refueling outage and remained in cold shutdown for the remainder
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of the inspection period. During this inspection period the sixth dry cask was transported ,
to the Independent Spent Fuel Storage Insta!.ation (ISFSI) and the seventh dry cask was I
loaded with spent fuel and also transported to the ISFSI.
I. Operations
01 Conduct of Operatiens
01.1 General Comments
a. Insoection Scone (71707) ,
Using Inspection Procedure 71707, the inspectors conducted frequent reviews of
plant operations. These reviews included observations of control room evolutions,
shift turnovers, operability decisions,logkeeping, etc. Updated Safety Analysis
Report (USAR) Section 13, " Plant Operations," was reviewed as part of the
inspection.
b. Observations and rindinas
The inspectors noted that control ronm operators were attentive to their panels and
knowledgeable of plant conditions and activities in progress. Communications were i
consistently clear. Shift turnover briefings were thorough but concise. Pre-job l
briefings for infrequent or complex evolutions were excellent. No significant
. problems were noted with routine plant operations.
c. Conclusions
The inspectors observed that the conduct of routine plant operations was generally
good. Additional comments on the conduct of refueling operations is contained in
Section 01.3 of this report.
01.2 Auxiliarv Buildina Crane Protective Features Defeated by Wirina Chances
a. jnicethun Scooe (93702)
On January 8,1997, the licensee reported via the Emergency Notification System '
that they had discovered that the auxiliary building crane was used to move a spent
fuel cask when it may have been in a condition that prevented it from meeting its
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single failure proof design. The inspectc,rs reviewed the circumstances of the event i
and reviewed associated Licensee Event Report (LER) 282(306)/97-01. The ;
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inspectors also reviewed Updated Safety Analysis Report Sections 10.2.1.2.2, l
' Major Equipment Required for Fuel Handling," and 12.2.12.1.3, " Auxiliary Building
Crane Evaluation."
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b. Observations and Findinas l
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As discussed in the LER, the licenese purchased a replacement radio control
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transmitter for the crane and did not realize that the vendor had changed the wiring
I of the critical /non-critical switch from the design of the old transmitter. Thus an
emp'- spent fuel cask was moved into the spent fuel pool and then the loaded cask
was moved out of the pool while the crane was actually in the non-critical !
condition. In that condition two of the crane protective features, the main hoist
drum overspeed protection and the spent fuel pool slot limit switch interlock, were
defeated. However, the licensee determined that the crane was still considered
single failure proof in the non-critical mode.
Other drum overspeed protection features were still active and there were
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alignment lights that were used to verify the crane remained within the spent fuel i
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pool roof slot. Thus the event was of minor safety significance. Since the new
wiring scheme was an improvement over the old, the licensee's corrective action
included incorporating the new design into their procedures, obtaining updated
drawings from the vendor, and changing the old transmitter to match it. Other
l corrective actions were discussed in the LER.
Failure of the licensee to adequately verify the new radio control box conformed to
the expected design was a violation of 10 CFR 50, Appendix B, Criterion Vil, !
l " Control of Purchased Material, Equipment, and Services." However, this licensee-
identified and corrected violation is being treated as a Non-Cited Violation,
consistent with Section Vll.B.1 of the NRC Enforcement Policy. (282/97002-01) l
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c. Conclusions
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The difference between the critical and noncritical functions of the crane were
subtle and the fact that the project engineer identified the condition showed
awareness and a good questioning attitude. However, failure to identify the wiring
change during the purchasing process, receipt inspection, or preventative
maintenance prior to its use for moving the spent fuel cask, pointed out
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weaknesses in the licensee's programs which were being addressed by the
corrective actions in the LER. LER 282(306)/97-01 associated with this event will
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remain open pending completion of the remaining corrective actions.
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01.3 Refuelino Operations
a. Insoection Scope (71707) l
The inspectors observed portions of several refueling operations and procedures
during the Unit 2 outage. Performance of the following procedures was observed:
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e 2C1.3 ' Unit 2 Shutdown, Revision 38 l
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o 2C1.6 Shutdown Operations - Unit 2, Revision 7
e 2C12.2 Unit 2 Purification & Chemical Addition, Revision 1
e 2C15 Residual Heat Removal System - Unit 2, Revision 13
e C17 Fuel Handling System, Revision 24
e C19.10 Containment Airlock Door Control at Shutdown, Revision 4
e 2D2 RCS Reduced Inventory Operation, Revision 6
e D5.2 Reactor Refueling Operations, Revision 20
e D61 Containment Penetration Outage Preparation, Revision 13
in addition, the inspectors reviewed Updated Safety Analysis Report,
Section 10.2.1, " Fuel Storage and Fuel Handling Systems."
b. Observations and Findinos
Operations performance during refueling operations was excellent. Significant
improvements were noted, especially in fuel handhng operations, compared to the
previous refueling outage. Communications sad "n Jependent verifications regarding
fuel movements, were excellent. Pre-job briefings and training in fuel handling
procedures for each crew was beneficial. Control of the plant during the crucial
draining of the reactor coolant system for steam generator nozzle dem installation i
was good. There were several examples of operators averting problems by the use
of self-checking and a questioning attitude.
c.- Conclusions
As operations observed by the inspectors associated with the refueling outage were
conducted in an excellent manner with significant improvements noted since the
last refueling outage.
03 Operations Procedures and Documentation
03.1 Licensee Review of Technical Soecifications Interoretations
a. Insoection Scone (9900)
in response to the NRC-identified issue with failure to test the redundant diesel
. generator discussed in inspection Report 282(306)/96014, Section 01.2, as well as
findings at other plants, the licensee conducted a detailed review of their Technical
Specifications (TS) Interpretation book to see if any interpretations were contrary to l
-a literal reading of the TS. The inspectors reviewed the effort. l
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b. Observations and Findinas
The licensee maintained a book of interpretations for use by operators and others to
clarify the meaning of certain TS. Most of the interpretations were intended to be
temporarily in place until TS amendments could be processed. However, little
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effort had been made recently to submit individual amendments to replace the
' interpretations because they were in the process of preparing a significant
amendment to implement improved Standardized Technical Specifications (ISTS).
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At the start of the review, there were 39 interpretations in effect. The ISTS would
eliminate the need for most of them.
The licensee eliminated 13 of the interpretations when they determined that their
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use could not be supported by the current literal wording of the TS. They
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submitted license amendment requests to replace some of the interpretations and
were working on prioritizing other amendment requests. In addition, the licensee
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identified other interpretations to be eliminated but delayed canceling them until
supporting procedures could also be revised to avoid have conflicting operator
guidance in place,
c. Conclusions
While the licensee's efforts to eliminate questionable TS interpretations was a good
idea, it was necessary due to the large number of interpretations in effect. The
inspectors reminded licensee management, in accordance with NRC Inspection
Manual Part 9900, that only TS interpretations in writing from the Office of Nuclear
Reactor Regulation were considered binding on the NRC and the license amendment
process was the normal method of clarifying TS.
06 Operations Organization and Administration
06.1 Manaaement Chanaes
The licensee announced the following management changes effective February 3,
1997:
e Doug Antony, President NSP Generation, retired,
o Ed Watzl was selected as President NSP Generation,
o Mike Wadley was selected as Vice President, Nuclear,
e Joel Sorensen was selected as Prairie Island Plant Manager,
e Pete Valtakis was designated as acting General Superintendent Plant
Operations until a permanent selection could be named.
08 Miscellaneous Operations issues (92700,92901)
08.1 (Closed) Violation 282/96002-01: Four Examples of Operators Failing to Follow
Procedures During a Refueling Outage. These issues were.previously discussed in
inspection Reports 282(306)/96002, Sections 1.1,1.4, and 1.5 the associated
Notice of Violation: 282(306)/96006, Section 01.4; and 282(306)/96010,
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Section M8.2. The errors were associated with inattention to detail and failure to
] adequately self-check. The licensee responded to the violations in a letter to the -
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During the Unit 2 refueling outage discussed in this report, the operators performed l
the same types of evolutions as those resulting in the violation. The inspectors
noted that performance had improved significantly. During this outage the reactor 1
refueling operations were complicated by the fact that extra moves were needed to *
bring the new fuel from the new fuel pit. In the past, the new fuel was placed in
', the spent fuel pool prior to the outage. No errors similar to those cited in the
l - violation occurred during the outage activities. In addition, the invectors noted
{ several examples of problems avoided by the operators due to increased emphasis
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on self-checking and a questioning attitude. Finally, the inspectors noted that the
licensee had implemented a new fuel movement log with significant human-factors
j improvements in its format.
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j 08.2 (Closed) Inspection Followun item 282/96008-01: Technical Specification for Shift
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Manning did not meet 10 CFR 50.54 requirements. This issue was previously
discussed in Inspection Report 282(306)/96008, Section 03.2. It was open
- pending licenses submittal of a Technical Specification amendment request to bring
} the specification in alignment with the regulation.
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On November 25,1996, the licensee submitted a supplement to a previous license
l amendment request dated December 14,1995, containing the necessary changes
to meet the regulation. NRC approval of the request was still pending. .
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j 08.3 (Closed) Insoection Followuo item 282/96008-02: Maintaining Operator Licenses in
i an Active Status. This issue was previously discussed in Inspection Report 1
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282(306)/96008, Section 05.1. It was open pending licensee submittal of a letter !
- clarifying which crew positions would be credited with duiy for the purposes of
- maintaining an active license.
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l On November 13,1996, the licensee submitted a letter to the NRC stating that i
they had discontinued the practice of crediting duty in the work control center as
meeting the criteria for actively performing the functions of an operator or senior'
- operator. The letter also clarified the duties of the shift manager and stated that
j the duties of that position met the requirements for maintaining an active ': cense. !'
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On November 25,1996, the licensee submitted s supplement to a previous license
amendment request dated December 14,1995, which added the requirement for
the shift technical advisor (who is also the shift manager) to hold a senior operator
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license. NRC approval of the request was still pending.
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j 08.4 (Closed) Violation 306/96014-01: Failure to Demonstrate Operability of the
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Redundant Diesel Generator with one Diesel Generator inoperable. This issue was
. previously discussed in inspection. Report 282(306)/96014, Section 01.2, and
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Notice of Violation. The licensee responded to the Notice of Violation in a letter
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, dated January 27,1997,in which they reported their corrective actions. The l
- inspectors determined the corrective actions were completed and acceptable. I
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ll. Maintenanca '
M1 Conduct of Maintenance
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M1.1 General Comments '
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Insoection Scoos (61726,62707)
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The inspectors observed all or portions of the following maintenance and
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surveillance activities. Included in the inspection was a review of the
surveillance procedures (SP) or work orders (WO) listed as well as the
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appropriate Updated Safety Analysis Report (USAR) sections regarding the
activities.
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e SP 1100 12 Motor Driven Auxiliary Feedwater Pump Test i
Monthly, Revision 48 !
- SP 1106B 22 Diesel Cooling Water Pump Test, Revision 50
Revision 8 ,
- SP 1226B
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l Containment Hydrogen Monitor Quarterly Calibration,
Revision 8
- SP 2305 D6 Diesel Generator Slow Start Test, Revision 8
e SP 2318.1 Source Range Channel Calibration, Revision 4
Valves, Revision 5
e WO 960767G Replace Fan Coil isolation Valve MV-32387
e WO 9607678 Replace Fan Coil isolation Valve MV-32389
e WO 9612068 Replace Loop B Main Steam Safety Valves
e WO 9614755 Investigate 12 Auxiliary Feedwater Pump Lube Oil
Pump
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- WO 9700114 Monitor input To Room Ventilation Trouble Alarm
- WO 9614600 Remove 21 CW Pump for Rebuild
b. Observations and Findinas
- For SP 11068, the inspectors noted that step 1.3 of the monthly test
specified that,in January of each year, the diesel cooling water pump be
. started by simulating low cooling water header pressure instead of the
normal manual start pushbutton actuation that was used the other eleven
- months of the year. SP 1106A, "12 Diesel Cooling Water Pump Test,"
j Revision 52, had a similar requirement for the redundant pump.
The inspectors noted that Technical Specification 4.5.B.1.b required that "a
test consisting of a manually-initiated start of each diesel engine, and
1 assumption of load within one minute, shall be conducted monthly." The
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inspectors questioned whether the low pressure actuation met the literal
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interpretation of the Technical Specifications. The operators were required i
to isolate and manually bleed pressure from the low cooling water header '
pressure actuation switch, but actuation of the switch then resulted in an
- automatic start of the diesel-driven pump.
A licensee engineering supervisor informed the inspectors that all monthly
tests were done using the low pressure actuation circuit until about 1991 l
when the test was simplified to use the start pushbutton for eleven of l
twelve monthly tests. Technical Specifications did not specifically require a
test of the low pressure actuation although Updated Safety Analysis Report,
Section 10.4.1.2, stated that the low pressure start of the pumps was part 1
of the design basia response to a loss of offsite power. l
For recent tests, the licensee had performed the tests using manual
pushbutton actuation on December 21 and December 20,1996, for the 12
and 22 pumps respectively, and again on February 14,1997, for both
pumps. However, the tests were done using a low pressure actuation on i
January 17 and January 20,1997, for the 12 and 22 pumps respectively. J
The issue was cons'idered an Unresolved item pending an interpretation from !
the NRC Office of Nuclear Reactor Regulation of the meaning of the term I
" manually-initiated" in the Technical Specification. (282/97002-02)
e While reviewing SP 1106B and Updated Safety Analysis Report (USAR), !
Section 10.4.1, " Cooling Water System," the inspectors noted that all i
routine surveillance tests of the diesel-driven cooling water pumps consisted
of starting and stopping the pumps from the local control stations in the
plant screenhouse. USAR Section 10.4.1.1 stated, "The system is
monitored and operated from the Control Room." The inspectors questioned
whether the ability of the pumps to be started and stopped from the control
room, which was part of the design basis, was ever tested. The system I
engineer could find no such test and stated that he intended to add a start
and stop, using the control room switch, to the annual preventive
maintenance procedure for the pumps. This issue was considered an
Inspection Followup Item pending completion of the licensee's actions and
review by the NRC of whether demonstration of the ability to operate the
system in accordance with that part of the design basis was a requirement.
(282(306)/97002-03) !
- For WO 9607676 and WO 9607678, the inspectors noted that the
construction crews had installed the valve label wires through the T-drain
holes on the drains on the Limitorque operator. The inspectors were
concerned that if the valves were environmentally qualified (EO) for a harsh
environment the T-drains needed to be kept free of obstructions for the
valves to meet their design basis.
The inspectors were informed by the system engineer that those particular
valves were not in the EQ program. He had the valve tags moved to a
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!. proper location on the valve anyway. The EO engineer agreed that is was a
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poor practice to hang tags with wires through T-drains, even on non-EQ
j valves. He wrote a memo to the staff r6 minding them not to do that. The
- EO engineer also stated that he did a walkdown near the end of each
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refueling outage to examine all EG squipment for any deficiencies that might :
affect their qualification.
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The inspectors found no other valve tag wires through T-drains on any EO or
j non-EO valves. The inspectors had no further concerns it' this area.
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- For WO 9612068, the inspectors noted that one of the safety valves that
- the licenses was preparing to install on the relief header was missing its -l
[ release nut. The inspectors contacted the system engineer who agreed that
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the nut should have been present on the valve. The system engineer -
!. determined that the valve in question (a used valve kept as a spare) had
j' been in storage in the warehouse for some time before being sent to a ;
j vendor for refurbishment and testing. Apparently the release nut had been j
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l scavenged while it was in storage. The licensee's quality services
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representative at the vendor during the testing confirmed that the nut was
j not present while the valve was at the vendor.
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- The quality services department checked the receipt inspection records but ;
I the presence of all parts was not one of the attributes checked when the ;
- valve was returned from the vendor. However, the inspectors determined I
i that the system engineer was very aware' of NRC Information Notice 96-61, -l
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" Failure of a Main Steam Safety Valve To Reseat Caused by an improperly i
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! installed Release Nut," which discussed problems with the release nuts and
he undoubtedly would have noticed the missing nut before the valve was put
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j' The system engineer immediately revised WO 9612068 to add a step to
! ensure the nut was installed before the valve was put into the system. He
! also wrote work order 9700810 to accomplish the installation of the nut.
l That work order was completed the same day using a nut salvaged from a
valve being removed. Quality services added a verification step for the nut's
j- installation to the original work order and also wrote an employee
l . observation report to investigate the adequacy of the receipt inspection.
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The missing nut would have had no safety significance because it did not
j affect the ability of the valve to automatically relieve at its set pressure. The
i missing nut would only have prevented manual actuation of the safety valve
j using the actuation lever. Manual actuation was not required for mitigation
of any accident. However, the finding indicated a potential weakness in the
licensee's control of salvaged parts from equipment in the warehouse,
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- * For WO 9614600, the inspectors observed on February 19,1997, that the
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No. 21 Circulating Water (CW) pump internals were to be lifted from the
- casing thorouph the screenhouse roof using a mobile crane. A similar
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situation was observed for WO 9700434 for the No. 22 CW pump motor.
The inspectors were concemed that the load path of the 15000 lb. pump ;
and 40000 lb. motor was in close proximity to the area of the screenhouse l
roof over safe shutdown equipment. However, the inspectors observed :
these lifts were performed using a safe load path verbally designated by the !
system engineer to the nggers.
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A further discussion of this issue regarding control of heavy loads using i
mobile cranes is discussed in Section M3.1. I
c. Conclusions
inspector-cbserved maintenance and surveillance activities were generally well
conducted with good communications, proper pre-job planning, safe work practices,
and coordination between departments. The inspectors noted good system
engineer involvement in all phases of maintenance and surveillance activities. With
the exception of the control of heavy loads discussed elsewhere in this report,
activities observed were performed acceptably.
M1.2 Failure to Follow Procedure for Movement of Heavy Load Over the Reactor
a. Insoection Scone (62703. 92902,92901)
The licensee identified on February 4,1997, that the Unit 2, No. 22 reactor coolant j
pump (RCP) motor rotor and upper bracket had been lifted over the open reactor !
vessel containing irradiated fuel, in violation of the heavy loads procedure. The j
inspectors reviewed the circumstances of the event and the licensee's corrective i
actions,
b. Observations and Findinas
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On February 3, RCP No. 22 rotor and bracket (approximately 21 tons) was lifted
from its vault with the polar crane, transported over the open flooded reactor cavity
(vessel head removed, core filled with irradiated fuel), and placed on the motor
stand on the refueling floor. Both doors of the containment maintenance and
personnel airlocks were open and the inservice purge system was operating.
The purpose of moving the rotor was to perform RCP preventive maintenance per
Work Order (WO) 9608888. This WO implemented Procedure D15.2, Revision 14,
" Reactor Coolant Pump Motor Cleaning Procedure," which directed maintenance
personnel to " follow the instructions and guidelines in D58 on heavy load
movement." Procedure D58, Revision 25, " Control of Heavy Loads," step 5.3.1,
required that with the reactor head removed, loads greater than 2100 lbs. shall not
be moved within 15 horizontal feet of the irradiated fuel without specific written
procedures. Step 5.8 of D58 required having at least one isolation valve closed in
each line which penetrates the containment and provides a direct path from the
containment atmosphere to the outside when a heavy load is moved over the
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reactor vessel. The above requirements in D58 are also identified in USAR
Section 12.2.12.1.4.
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Procedure D58 was not referred to prior to the lift. The RCP engineer believed it
may have been possible to move the load around the vessel, however, it was not.
Riggers and the RCP engineer questioned if it was acceptable to transport the load
across the cavity. The RCP engineer informed the inspectors that a reactor
engineer was consulted and the shift supervisor was consulted and concurred.
Therefore, the riggers performed the lift under the assumption that the shift
supervisor approved it. The shift supervisor informed the inspectors that he told
the engineer Dgi to go over the vessel. He thought that it was acceptable to lift the
rotor around the vessel (along the edge of the refueling cavity), but he did not refer
to D58 for guidance and was not aware of the 15 foot separation distance
, requirement.
Early during day shift on February 4, maintenance personnel intended to return the
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RCP rotor to its vault following completion of maintenance. The inspectors were on
the refueling floor to observe fuel handling activities. The Senior Reactor Operator
(SRO) in charge of fuel handling was preparing to initiate core alterations and 'was
consulted by the riggers about the plan to return the rotor to the vault and he
directed the lead rigger to contact the shift supervisor. The SRO in charge of fuel
handling later informed the inspectors that he felt uncomfortable with this lift
occurring during fuel handling and informed the shift supervisor. When the shift
supervisor was contacted, he questioned the appropriateness of the activity with
the outage shift manager. The outage shift manager determined that this lift did
not comply with the requirements of D58. Therefore, the riggers were not allowed
to perform the lift. After further evaluation, the licensee determined that a separate
procedure was required to be written to perform the lift which included the
containment closure requirements. An acceptable procedure was written and
approved by the onsite safety review committee on February 5 and the lift was
performed with the D58 requirements implemented.
An error reduction task force investigation was initiated by the licensee to review
the event, and recommend corrective actions. Short term corrective actions
included conducting training on the requirements of D58 for all riggers and
maintenance repairmen and development of a checklist placed at the controls of
plant cranes as a reminder of heavy load restrictions.
The licensee concluded that it did not meet its commitments in implementing
NUREG-0612 for control of heavy loads inside of containment and also concluded
that the event was reportable as a condition outside of the design basis 9 nause
their analysis for dropping of a heavy load on irradiated fuel assumed ' s
containment would be closed.
10 CFR 50, Appendix B,. Criterion V, stated,in part, that activities affecting auality
shall be prescribed by documented instructions, procedures, or drawings, of a type
appropriate to the circumstances and shall be accomplished in accordance with
these instructions, procedures, or drawings. Procedure D58, Revision 25, " Control
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of Heavy Loads," step 5.3.1, required that with the reactor head removed, loads
greater than 2100 lbs. shall not be moved within 15 horizontal feet of the irradiated
fuel without specific written procedures. Step 5.8 of D58 required having at least
one isolation valve closed in each line which penetrates the containment and
provides a direct path from the containment atmosphere to the outside when a
heavy load is moved over the reactor vessel.
On February 3,1997, the No. 22 reactor coolant pump motor rotor and upper
bracket (a heavy load greater than 2100 lbs.) was moved with the Unit 2 polar
crane over the open reactor vessel and irradiated fuel without a written procedure
and without containment closure. This was considered an apparent violation.
(EA 97-073)
c. Conclusions
An apparent violation was identified for failure to follow the requirements of
Procedure D58. Engineering, maintenance, and operations personnel did not know
or understand the requirements of D58 and did not refer to it as instructed or when
a question was identified. Weak communications were evident between workers in
the field and the main control room. The inspectors previously identified a non-
cited violation in Inspection Report 282(306)/95012 for failure to use a written
procedure for movement of a heavy load in the turbine building over the safeguards
bus rooms.
M1.3 Refuelino Outaae Activities
a. Insoection Scooe (61726, 62707. 92902)
The inspectors observed planning and scheduling activities for the Unit 2 refueling
, outage, daily outage update meetings, and portions of numerous outage work
,
activities.
'
b. Observations and Findinos
The inspectors noted that the outage plan was well-developed and comprehensive.
Very few problems were noted with job interferences or scheduling problems. The
licensee used " green, yellow, orange, and red" designations to monitor the status
'
of five significant shutdown safety parameters. Those were decay heat removal,
reactor coolant system inventory control, electrical power availability, reactivity
i control, and containment integrity. The entire outage schedule contained no
planned entries into " orange or red" conditions of redundancy and capability of
maintaining those parameters in a safe condition. As of the end of this inspection
period, there had been no unplanned entries into " orange or red" conditions either.
The inspectors noted generally good execution of outage work. Time estimates for
jobs in the outage plan were fairly accurate but no pressure to hurry jobs was noted
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when they were behind schedule. Outage scope additions were smoothly i
incorporated into the plan. Teamwork was evident and excellent communications
between all groups involved in the executien contributed to the success,
c. Conclusions
Careful planning and safe execution of outages has been a significant strength of
the licenses in the past and continued to be strong in the Unit 2 refueling outage
during this inspection period.
M3 Maintenance Procedures and Documentation
M3.1 Control of Heavv Loads with Mobile Cranes
a. Insoection Scone (62703. 92902)
As discussed in Section M1.1, the inspectors had a concern with the control of
heavy loads using a mobile crane and potential impact on safe shutdown ;
equipment. The inspectors reviewed the following work orders (WOs) and !
procedures: 1
e WO 9700434 Remove 22 CW Motor for Cleaning and Inspection i
e WO 9614599 Remove 21 CW Motor for Cleaning and Inspection
- WO 9614600 Remove 21 CW Pump for Rebuild
- D58 Control of Heavy Loads, Revision 26 l
1
b. Observations and Findinos '
The WOs addressed the use of a mobile crane to lift the loads from the Unit 2
circulating water (CW) pump area through an opening in the screenhouse roof. The
WOs identified the weight of the loads, however, they did not identify a safe load ;
path around the area of the roof that covered safe shutdown equipment in ;
screenhouse. Also, a safe load path area was not marked on the roof of the
screenhouse. Support equipment was located on the roof of the screenhouse and
damage to these components could have impacted operability of safe shutdown
equipment.
The inspectors reviewed Procedure D58 and determined that it did not address the
use of mobile cranes for handling loads in proximity to safe shutdown equipment.
As discussed in NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants,"
safe load paths should be defined for movement of heavy loads to minimize the
potential for heavy loads, if dropped, to impact safe shutdown equipment.
Additionally, procedures should be developed to cover load handling operations for
heavy loads that are or could be handled over or in proximity to safe shutdown
equipment.
10 CFR 50, Appendix B, Criterion V, states,in part, that activities affecting quality
shall be prescribed by documented instructions, procedures, or drawings, of a type
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appropriate to the circumstances and shall be accomplished in accordance with
these instructions, procedures, or drawings. Procedure D58, " Control of Heavy
Loads," Revision 26, was inadequate for the circumstances in that it did not
contain administrative controls for handling heavy loads over or in proximity to safe l
shutdown equipment located in the screenhouse nor instructions for the evaluation
l
of the use of mobile cranes from reactor safety standpoint in general. This was i
considered a violation. (306/97002-04)
c. Conclusions
The actuallifts that the inspectors observed were performed with a load path that
avoided safe shutdown equipment in the screenhouse so this particular evolution
had only minor safety significance. The system engineer who planned the work
reviewed D58, but because it contained no instructions pertaining to the job he was
i
planning, he concluded that the administrative controlt;it contained did not apply. i
The inspectors concluded that D58 was too narrowly focused in that it only l
addressed permanently installed cranes. Failure to properly control the load paths I
of heavy loads using mobile or other temporary cranes could result in a serious i
event.
!
M8 Miscellaneous Maintenance issues (92700, 92902)
M8.1 (Closed) Licensee Even Reoort (LER) 282(3061/96-06: Cooling Water Surveillance
Tests Missed as a Result of a Rescheduling Error. This event was previously
discussed in Inspection Report 282(306)/96002, Section 2.7. The inspectors i
verified that corrective actions discussed in the LER had been completed. No l
additional events of the same type have occurred since LER 96-06. I
M8.2 (Closed) Violation 282/96008-04 and (Closed) Violation 282/96008-05: Failure to
Promptly identify and Correct an Adverse Condition. These issues were discussed
in inspection Reports 282(306)/96008, Sections M1.2, M3.1, and M8.1; the ;
associated Notice of Violation; and 282(306)/96010, Section M8.4. The licensee l
replied to the violations in a letter to the NRC dated November 6,1996. The '
inspectors verified that corrective actions discussed in the reply had been
completed.
M8.4 (Closed) Violation 282/96008-08: Failure to Make a Timely Report of an Operation
Prohibited by Technical Specifications. This issue was previously discussed in
inspection Report 282(306)/96008, Section M8.1, and the associated Notice of '
Violation. The licensee replied to the violation in a letter to the NRC dated
November 6,1996. The inspectors verified that corrective actions discussed in the
reply had been completed. Administrative Work Instruction 5AWI 3.6,0,
" Reporting," Revision 6, was issued on December 31,1996. It directed that the
site licensing department be properly informed by the shift manager of events that
will require a Licensee Event Report in accordance with 10 CFR 50.73 but not an
Emergency Notification System callin accordance with 10 CFR 50.72.
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M8.5 (Closed) Violation 282/96010-03: Failure to Adequately Perform Check Valve
Tests. This issue was previously discussed in inspection Reports 282(306)/96010,
Section M3.2: the associated Notice of Violation; and 282(306)/96014,
Section M8.1. The licensee replied to the violation in a letter to the NRC dated
December 5,1996. The inspectors verified that the appropriate changes had been
made to surveillance procedures SP 1355, " Checking Chemical Feed and Auxiliary
Feedwater Check Valves - Unit 1," Revisior; 7, and SP 2355, " Checking Chemical
Feed and Auxiliary Feedwater Check Valves - Unit 2," Revision 3, to prevent
recurrence of the violation. One corrective action in the licenree's reply to the
violation, to conduct procedure walkthroughs, was not yet completed because it
was longer term in nature. However, the inspectors determined that it was
progressing satisfactorily.
M8.6 (Closed) Licensee Event Reoort 282(306)/96-15: Auto-start of No. 22 Diesel
Cooling Water Pump on Low Header Pressure During Surveillance. This event was
previously discussed in inspection Reports 282(306)/96008, Section M3.2, and
282(306)/96010, Section M8.5. The inspectors reviewed Surveillance Procedures
SP 1106A, "12 Diesel Cooling Water Pump Test," Revision 51, SP 1106B, "22
Diesel Cooling Water Pump Test," Revision 49, and SP 1106C, "121 Cooling Water i
Pump Test," Revision 8, and noted that they were significantly improved over '
previous revision from a human factors standpoint.
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lil. Enoineerina j
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E1 Conduct of Engineering (92903)
During this inspection period a detailed inspection of the licensee's inservice inspection !
program was conducted by a regional inservice inspection (ISI) specialist and was i
documented in inspection Report 282(306)/97003.
In addition, conference calls, meetings, and correspondence occurred between the NRC
and licensee on the topics of proposed license amendments for F' tube rolling in steam
generators and resolving the unreviewed safety question regarding the emergency cooling
water intake line discussed in inspection Report 282(306)/96015.
E2 Engineering Support of Facilities and Equipment
E2.1 Review of Uodated Safety Analysis Reoort (USAR) Commitments (37551)
While performing the inspections discussed in this report, the inspectors reviewed
the applicable portions of the USAR that related to the areas inspected and used
the USAR as an engineering / technical support basis document. The inspectors
compared plant practices, procedures, and/or parameters to the USAR descriptions
as discussed in each section. One Inspection Followup Item was identified because
there were no tests to demonstrate that the cooling water pumps could be operated
from the control room as described in the USAR (Section M1.1.b).
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E2.2 ' System Enoineer Suonort of Outaae Activates (37551)
i While observing refueling outage operations and maintenance activates described
elsewhere in this report, the inspectors noted strong system engineer involvement
in the work. System engineers were frequently observed at the job sites or
monitoring operations from the control room. Operations and maintenance i
department personnel often consulted system engineers and were consistently
provided with prompt support. The inspectors concluded that system engineering )
support of the outage was excellent. 'l
E8 Miscellaneous Engineering issues (92700, 92903)
i
E8.1 (Closed) Violation 282/96007-04: Exceeding Technical Specifications Limiting ;
Conditions for inoperability of Post Accident Containment Hydrogen Monitors.
This issue was previously discussed in inspection Reports 282(306)/96007,
Section E8.1; the associated Notice of Violation; and 282(306)/96006,
Section M2.2. The licensee replied to the violation in a letter to the NRC dated i
October 13,1996. The inspectors verified that the appropriate changes had been
i
made to maintenance procedure D87, " Containment Hydrogen Monitor Calibration j
Gas Fill," and system technical manual. Training was conducted for technicians i
and engineers on the event, including discussions of the contributing cause;
,
procedural adherence problems in the work control, post-maintenance testing, and j
technical manual revision process areas. One corrective action to the violation, to j
consider upgrade of the calibration assemblies, was not yet completed because it l
was longer term in nature. However, the inspectors determined that it was
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progressing satisfactorily. !
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IV. Plant Suncort t
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R1 Radiological Protection and Chemistry Controls (71750)
h
During normal resident inspection activities, routine observaticns were conducted in the
- areas of radiological protection and chemistry controls using Inspection Procedure 71750. .
No discrepancies were noted. During this inspection period an additional inspection was I
conducted by a regional radiation protection specialist and was documented in inspection !
Report 282(306)/97004. I
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P1 Conduct of Emergency Preparedness Activities (71750) !
During normal resident inspection activities, routine observations were conducted in the !
- area of emergency preparedness using inspection Procedure 71750. No discrepancies '
were noted. The inspectors became aware of the start of major construction work to
upgrade Sturgeon Lake Road. All traffic to and from the plant had to travel on a portion of
the road being worked on. The improvements were to include raising the level of the i'
roadway and widening it to two lanes in each direction. The inspectors were informed
that the intent of the project managers was to maintain two-way traffic throughout the ,
project so that emergency evacuation from the area and emergency response to the plant j
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would not be significantly affected. The inspectors concluded that licensee emergency
preparedness personnel were adequ';tely monitoring the project.
S1 Conduct of Security and Safeguards Activities (71750)
During normal resident inspection activities, routine observations were conducted in the
areas of security and safeguards activities using Inspection Procedure 71750. No
discrepancies were noted.
F1 Control of Fire Protection Activities (71750)
During normal resident inspection activities, routine observations were conducted in the !
area of fire protection activities using Inspection Procedure 71750. No discrepancies were
noted.
I
V. Manaaement Meetinas
!
X1 Exit Meeting Summary
The inspectors presented the inspection results to members of the licensee management at
the conclusian of the inspection on February 20,1997. The licensee acknowledged the
findings prosented.
The insractors asked the licensee whether any materials examined during the inspection i
should be considered propthtary. No proprietary information was identified.
19
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PARTIAL LIST.0F PERSONS CONTACTED !
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Licensee
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- J. Sorensen, Plant Manager l
K. Albrecht, General Superintendent Engineering !
J. Goldsmith, General Superintendent Design Engineering
R. Held, Outage Planner
J. Hill, Manager Quality Services
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G. Lenertz, General Superintendent Plant Maintenance I
J. Maki, Outage Manager
D. Schuelke, General Superintendent Radiation Protection and Chemistry
M. Sleigh, Superintendent Security
P. Valtakis, General Superintendent Plant Operations (Acting)
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 61726: Surveillance Observations
IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 71750: Plant Support Activities
IP 92700: Onsite Follow-up of Written Reports of Nontoutine Events at Power Reactor
Facilities
IP 92901: Followup - Operations
IP 92902: Followup - Maintenance
IP 92903: Followup - Engineering
Part 9900: Technical Guidance - Licensee Technical Specifications interpretations
ITEMS OPENED, CLOSED, AND DISCUSSED
Onened
-282/97002-01 NCV Failure to identify a Change to the Design of Purchased
Equipment
282/97002-02 URI Question Regarding Whether Surveillance Testing of the
Cooling Water Pumps Fulfills a Technical Specification
Requirement
282/97002-03 IFl No Test to Demonstrate that the Cooling Water Pumps can be
Operated From the Control Room as Described in the Design
Basis
306/97002-04 VIO _ Inadequate Procedure for the Control Of Heavy Loads
282(306)/97-01 LER Auxiliary Building Crane Protective Features Defeated by
Wiring Errors
20
a
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Closed
282/96002-01 VIO Four Examples of Operators Failing to Follow Procedures
During a Refueling Outage
282(306)/96-06 LER Cooling Water Surveillance Tests Missed as a Revilt of
Rescheduling Error
282/96007-04 VIO Containment Hydrogen Monitors inoperable
282/96008-01 IFl Technical Specification for Shift Manning did not Meet
10 CFR 50.54 Requirements
282/96008-02 IFl Maintaining Operator Licenses in an Active Status
282/96008-04 VIO Failure to Promptly identify an Adverse Condition
282/96008-05 VIO Failure to Promptly Correct an Adverse Condition
282/96008-08 VIO Failure to Make a Timely Report of an Operation Prohibited by
i
Technical Specifications
,
282/96010-03 VIO Failure to Adequately Perform Check Valve Surveillance Tests !
306/96014-01 VIO Failure to Demonstrate Operability of the Redundant Diesel '
Generator with one Diesel Generator inoperable
282(306)/96-15
.
LER Auto-start of No. 22 Diesel Cooling Water Pump on Low i
Header Pressure During Surveillance
!
Discussed
None
i
LIST OF ACRONYMS USED
i
CFR Code of Federal Regulations
CW Circulating Water
EQ Environmentally Qualified
IFl Inspection Followup item
IP inspection Procedure
ISFSI Independent Spent Fuel Storage Installation
ISI Inservice Inspection
ISTS Improved Standardized Technical Specifications
LER Licensee Event Report
LOCA Loss of Coolant Accident
NRC Nuclear Regulatory Commission
NSP Northern States Power Company
I
Public Document Room i
RCP Reactor Coolant Pump
SP Surveillance Procedure
SRO Senior Reactor Operator
USAR Updated Safety Analysis Report
TS Technical Specifications
URI Unrcsolved item
VIO Violation
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