ML20203G134
| 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
States Power to USNRC
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Northern States Power Company
Prairie island Nuclear Generating Plant
1717 Wakontie Dr. East
Welch, Minnesota $5089
November 13,1997
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
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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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.
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oel P Sorensen
Plant Manager
Prairie Island Nuclear Generating Plant
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Regional Administrator- Region lil, N' C
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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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November 13,1997
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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
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complete this update.
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We are currently revising the Safe Shutdown Analysis which will require changes to the
' FHA. - The revised FHA will be submitted during the first USAR update submittal of
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1998.
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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 -
submitted to the site Licensing Department for inclusion with the next USAR submittal
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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
of 1998.
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November 13,1997
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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,
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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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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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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:
documents completion of the test by the signature of the performer (along with
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the date and time),
acceptability of the test results, documented by the signature of the fire
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protection administrator,
documents, by signature, the system engineer review of the test for
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completeness
documents necessary corrective maintenance by referring to work orders
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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.
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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.
Surveillance Procedure (SP) 1192," Safeguards Electrical and Mechanical
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Penetrations Surveillance inspection," Revision 7, requires the verification of
penetration seal operability through visual inspection.
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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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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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