ML20203G134

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-282/97-12 & 50-306/97-12.Corrective Actions Will Be Examined During Future Insp

ML20203G134
Person / Time
Site:	Prairie Island
Issue date:	12/12/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Wadley M NORTHERN STATES POWER CO.
References
50-282-97-12, 50-306-97-12, NUDOCS 9712180059
Download: ML20203G134 (1)

See also: IR 05000282/1997012

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December 12, 199'/.

Mr.' M. D. Wadley

Vice President, Nuclear Generation

Northem States Power Company

414 Nicollet Mall

Minneapolis, MN ' 55401

SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION

REPORT NO. 50-282/97012(DRS); 50 306/97012(DRS))

Dear Mr. Wadley:

- This will acknowledge receipt of your letter dated Nove.nber 13,1997, in response to

our letter dated October 14,1997, trarismitting a Notice of Violation associatad with inapection

Report No. 50-282/97012(DRS); 50-306/97012(DRS). We have reviewed your corrective

actions and have no further questions at this time. These corrective actions will be examined

during future inspections.

Sincerely, ,

Original Signed by J. Jacobson for

John A. Grobe, Director

Division of Reactor Safety

Docket No. 50-282

Docket No. 50-306

Enclosure: Ltr dtd 11/13/97, J. P. Sorensen, Northern

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Northern States Power Company

Prairie island Nuclear Generating Plant

1717 Wakontie Dr. East

Welch, Minnesota $5089

November 13,1997 10 CFR Part 2

U S Nuciear Regulatory Commission

Attn: Document Control Desk

Washington, DC 20555

PRAIRIE ISLAND NUCLEAR GENERATING PLANT

Docket Nos. 50-282 License Nos. DPR-42

50-306 DPR-60

Reply to Notice o' Violation (Inspection Report 97012),

Deficiencier in the Fire Protection Program _

Your letter of October 14,1997, which transmitted Inspection Report No. 97012,

required a response to a Notice of Violation. Our response to the notice is contained in

the attachment to this letter,

in addition, you requested responses to two Unresolved items. These responses

immediately follow.

URI 07012-01 Hot Shorts with Valve Damage:

As indicatedin the inspection report, we willperform additionalreviews of the hot

short problems following the completion of the safe shutdown analysis currently

being revised. After completion of the analysis a revised list of MOVs that are

susceptible to hot shorts will be developed and further reviews will be made for

these MOVs. Information Notice 92-18 willbe used for guidance in these

additionalreviews.

URI 97012-08 Fire Brigade Drill Requirements:

We am in the process of reviewing all of the commitments made relating to the

Fim Protection Program. After this review is completed the commitments will be

assessed against practices allowed by our administrative procedures and any

discmpancies between our fire brigade drill commitments and pmcedures will be

corrected.

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USNRC' NORTHERN STATES POWER COMPANY

November 13,1997

Page 2

In this letter and attached response we have made new Nuclear Regulatory

Commission commitments, these are indicated by italics,

Ples se contact Jack Leveille (612-388-1121, Ext. 4662) if you hate any questions

relateJ to this letter.

/

oel P Sorensen

Plant Manager

Prairie Island Nuclear Generating Plant

c: Regional Administrator- Region lil, N'RC

Senior Resident inspector, NRC

NRR Project Manager, NRC

J E Silberg

Attachment: RESPONSE TO NOTICE OF VIOLATION

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1R97372. DOC

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RESPONSE TO NOTICE OF VIOLATION

VIOLATION 1

10 CFR 50.71(e) required that revised portions of the Fina; bafety Analysis Report

(FSAR) be submitted to the NRC.

Contrary to the above, on July 1,1994, substantial revisions were mad. to the Fire

Hazards Antlysis (FHA)(referenced as a portion of the FSAR) that were not submitted

to the NRC.

This is a Severity Level IV violation (Supplement 1).

Response to Violation 1

Reason for the ViolatiRD

Control & maintenance of the Fire Hazard Analysis (FHA)is outlined in several PINGP

site documents. The Prairie Island FHA is currently located in Operations manual

section F5 Appendix F. The USAR outlining the Fire Protection Program is located in

USAR section 10.3.1. Current practice for control and maintenance of the FHA and

USAR documents are outlined in SAWI 3.13.0," Fire Prevc..tative Practices," 5AW1

3.13.1 " Fire Protection Review of Plant Modifications," and SAWI 4.9.0 " Safety

Analysis Reports" as well as other site procedures which use processes to evalcate

and make required changes. The documents identified above use the FHA and USAR

in sepnte text and use separate processes for making changes to each.

Prict to this URC inspection, Prairie Island viewed the FHA as a separate document

than the USAR section.

Corrective Actions Taken:

During an unannounced fire protection inspection in March of 1994 the inspector

identified a violation relating to timely updates to the facilities FHA. Following the

issuance of this violation we completed a revision to the FHA that included

incorporation of all modifications completed since the previous revision where the FHA

was impacted. In addition, the facility developed an Administrative Work Instruction,

5AWI 3.13.1, " Fire Protection Review of Plant IV.odifications," that implemented

requirements for reviews of modifications that may impact the Fice Protection Program

for the facility. This Administrative Work Instruction has been in effect since the

inspection of 1994. Changes were made to the FHA as indicated in our response to

Violation 282/306/94004-1b dated May 2,1994. In this response we did not indicate

that we would or understood we were required to submit the updated FHA to the NRC

for review. NRC GL 86-10 requires all changes to the approved program be reported

annually to NRR along i.vith FSAR revisions. A major revision to the FHA could be

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i- considered u program change; however, all that was done was to updete the fire _ _

loading portion of the FHA and to_ identify the more conservative methodology used to .

complete this update.

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We are currently revising the Safe Shutdown Analysis which will require changes to the

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' FHA. - The revised FHA will be submitted during the first USAR update submittal of

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1998. .

Action to Be Taken to Prevent Recurrence '

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A procedure change request was submitted for 5AWI 4.1.0, P! ant Operations and Site

Engineering Manuals to require that any changes made to the Fire Hazards Analysis be -

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submitted to the site Licensing Department for inclusion with the next USAR submittal

to the NRC.

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'. Date When Full Comollance Will Be Achieved

The Prairie Island Fire Hazards Analysis will be submitted with the first USAR submittal

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November 13,1997 l

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VIOLAT!ON 2.a

Prairie !sland hchnical Specification 6.5.A.7 required tilat detailed written

implementing prcadures be prepared and followed for the fire protection program,

a. Administrative Work !nstruction SAWI 3.13.0, " Fire Preventive Practices,"

Paragraph 6.9.6, stateo. " Individual Fire Brigade members SHALL actively

participate in at least one drii; per year."

Contrary to the above, during 1996, SAW13.13.0 was not followed in that 7

members of the fire brigade did not actively participate in fire brigade drills.

This is a Severity Level IV violation (Supplement 1).

Resoonse to Violation 2.a

Reason for the Violation

The reason for the violation was that we interpreted " active participation" to include

participation from the control room functions during a fire scenario. We are unaware of

the existence of clear NRC guidance on the meaning of" active participation."

Corrective Actions Taken

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Following the identification of this issue by the inspector we removed from Fire Brigade

duty those individuals that had not participated as a member of the fire brigade at the

scene of a drillin the past 12 months. In the following days, additional fire drills were

conducted and the individuals who had not previously participated in a fire drill at the

drill scene did participate as brigade members at the dr;ll scene. Following this

participation these individuals were rebrned to active Fire Brigade status, it should be

noted that these individuals had all participated in hands-on fire brigade training, during

the preceding 12 months, which includes full suit-up and full participation in fire fighting

scenarios.

Corrective Actions tq. Prevent Recurrence

We will change our administrative requirements to identify that ACTIVE participation in

a Fire Drill will require fire brigade members to respond to the location of the simulated

fire in fullprotective equipment and willinvolve participation in fire bdgade activities to

extinguish and prevent the spread of fires simulated for the drill. We will develop a

program to track this drillparticipation and fire brigade qualifications will require this

active participation in drills. The program willbe in place by March 1,1998.

Date When Full Comoliance Will Be Achieved

Full compliance has been achieved.

IR97012, DOC

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Nov:mber 13,1997

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VIOLATION 2.b

Prairie Island Technical Specification 6.5.A.7 required that detailed written

implementing procedures be prepared and followed for the fire protection program.

b. Prairie Island Administrative Work Instruction SAW13.4.0,"QA Records Control,"

Revision 4, stated in paragraph 6.2.3: " Records that meet one or more of the

following criteria SHALL be classified as lifetime records: a. Would be of

significant value in demonstrating capability for safe operation of a safety related

or fire protection related item."

Contrary to the above, the December 12,1996, detector surveillance data

documented during fire protection surveillance SP 1189," Safety Related Fire

Detector Check," was not available for inspector review because it had been

discarded.

This is a Severity Level IV violation (Supplement 1).

Resoonse to Violation 2.b

Reason for the Violation

The inspection report states:

The inspector identified that detector surveillance data documented during SP

1189, " Safety Related Fire Detector Check," Revision 16, was not ava>able for

inspector review because it had been discarded. Only the cover sheets of

surveillances were saved. The licensee stated this was allowed by the licensee's

Administrative Work Instruction, SAW11.5.0, Revision 2, in Paragraph q.3.d.

It is true that we stated that the discarding of pages from the completed surveillance

procedure was allowed by Administrative Work Instruction 5AW11.5.0, which states that

pages of standing procedures may be discarded if several requirements are met,

including:

The discarded pages SHALL contain only routine, initiated steps and no data,

dates or signatures.

The discarded pages of SP-1189 contained only routine, initiated steps and did not

contain dates or signatures. We have questioned whether these routine, initiated steps

constitute " data" or provide " significant value in demonstrating capability for safe

operation of a safety related or fire protection related item." We have discovered that

we have an intemal disagreement regarding this question in general. However, in the

case of SP-1189, the procedure itself refers to the information in the table (the initials)

as test results. Test results must be maintained as quality records. Therefore, we

IR97012. DOC

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November 13.1997

P:ge 5

acknowledge the violation but have not determir.ed that it extends beyond this particular

procedure.

Corrective Actions Taken

The discarded surveillance pages have not caused us to doubt the operability of the fire

detectors. The cover sheet, which is maintained:

e documents completion of the test by the signature of the performer (along with

the date and time),

e acceptability of the test results, documented by the signature of the fire

protection administrator,

e documents, by signature, the system engineer review of the test for

completeness

e documents necessary corrective maintenance by referring to work orders

generated

in addition, any pages with deviaticns are maintained with the coversheet. Because

revisions of surveillance procedures are maintained, it is possible to recover the

specifics that were addressed by past surveillances of the fire detectors.

The information is available from the preserved documentation to make appropriate

safety, operability, or reportability determinations. We, therefore, believe that no

repeated surveillance is deemed necessary.

! Corrective Actions Recarding Fire Protection Data Retention

We will revise SP-1189 to require the retention of allpages that contain any

documentation ofperformance (prior to the next performance of the test). As

discussed in the reason for the violation, the violation resulted from the procedure

calling out the information in the table as " test results;" we are not considering this to be

a global concern and are not currently changing our retention practice for other than fire

detector surveillance procedures. Further action is dependent on the conclusion to be

determined as discussed in the following section. We may elect to subsequently re-

retase the retention practice for SP-1189 as a result of that determination.

Corrective Actions to Preclude Recurreaca

We will determine the acceptable definition of data (in particular, as it relates to test

results) and revise the administrative workinstruction(s) as necessary. If a revised

concept of data is incorporated into the administrative work instruction (s), we will

perform an appropriate review of other surveillance procedures for conformance.

Date When Full Comoliance Will Be Achieved

Full compliance has been achieved, we are currently maintaining completed fire

detector surveillance procedures in their entirety.

IR97012.DCC

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VIOLATION 2. c

Prairie Island Technical Specification 6.5.A 7 required that detailed written

implementing procedures be prepared and followed for the fire protection program.

c. Surveillance Procedure (SP) 1192," Safeguards Electrical and Mechanical

Penetrations Surveillance inspection," Revision 7, requires the verification of

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penetration seal operability through visual inspection.

Contrary to the above, on April 4,1997, SP 1192 was not followed in that 8

penetrations were not verified to be operable.

This is a Severity Level IV violation (supplement 1).

Response to violation 2.c

Reason for the Violation

There are approximately 100 sketches attached to surveillance procedure SP-1192.

The surveillance procedure outlines several steps for completing the work, it directs the

inspector to place checkmarks by the individual penetrations on the sketches; this is to

keep track of them because there are several on each drawing. The procedure also

directs the inspector to initial and date each sketch when it has been completed. A field

or working copy of the inspection procedure is used while performing the penetration

inspections. The field information is then transferred to an office copy which is used as

the master work order. The craft inspector assured us the penetrations had been

inspected although he had not properly transferred the checkmarks onto the master

copy of the work order. causing the violation.

Note that the engineering review after all the work has been done verifies by each page

signoff that all the penetrations were checked, not by looking for individual checkma-ks

on each sketch.

Corrective Actions Taken

When the question arose whether or not the inspections had been performed for the

subject penetrations, a roving fire watch was established for the penetrations noted as

being possibly inoperable and a work order issued to inspect those penetrations that

were not indicated as being inspected on the sketches. These penetrations were

inspected and found to be intact and acceptable.

Action to Preclude Recurrence

The surveillance procedure has been submitted to the Error Reduction Task Force

(ERTF) for a Human Factors review and will be modified following this mview based on

IR97012.CCC

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November 13,1997

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the recommendations of the ERTF. Through improvements in the human performance

aspects of the surveillance and its logging of completion of inspections the ability to

properly determine if all penetrations were inspected will be enhanced.

Date When Full Comoliance Will Be Achieved

Full compliance has been achieved.

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IR97012. DOC

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