ML20236G901

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Insp Repts 50-282/98-08 & 50-306/98-08 on 980512-0618.No Violations Noted.Major Areas Inspected:Operations,Maint, Engineering & Plant Support
ML20236G901
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 06/28/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236G898 List:
References
50-282-98-08, 50-282-98-8, 50-306-98-08, 50-306-98-8, NUDOCS 9807070014
Download: ML20236G901 (20)


See also: IR 05000282/1998008

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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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License Nos:

DPR-42; DPR-60

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Report No:

50-282/98008(DRP); 50-306/98008(DRP)

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Licensee:

Northem States Power Company

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Facility:

Prairie Island Nuclear Generating Plant

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Location:

1717 Wakonade Drive East

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Welch, MN 55089

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Dates:

May 12 through June 18,1998

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Inspectors:

S. Ray, Senior Resident inspector

P. Krohn, Resident Inspector

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S. Thomas, Resident inspector

Approved by:

J. W. McCormick-Barger, Chief

Reactor Projects Branch 7

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9807070014 980628

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ADOCK 05000282

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RdCUTIVE SUMMARY

Prairie Island Nuclear Generating Plant, Unit 1 and Unit 2

NRC Inspection Report 50-282/98008(DRP); 50-306/98008(DRP)

This inspection included aspects of licensee operations, maintenance, engineering, and plant

support. The report covers a 5-week period of resident inspection.

Operations

During the performance of power changes and relatively complex system alignments, the

operators maintained good control of the plant and, when confronted with abnormal

conditions, took prompt and conservative actions to restore the conditions to normal.

(Section 01.1)

The Unit i reactor startup from cold shutdown conditions and subsequent power

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ascension was performed in a deliberate and safe manner with no significant

discrepancies noted. During the approach to criticality, the operators involved focused

solely on the task at hand. (Section 01.3)

Discrepancies in both the Technical Specifications and the Updated Safety Analy::!s

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Report regarding whether the steam line isolation logic used the Low T,y or Lo-Lo T,y

setting were identified. The discrepancies had no affect on plant operations because

surveillance test procedures included the proper setpoints and logic. In addition,

operators were knowledgeable of the proper setpoints and inputs to the isolation logic.

(Section O3.1)

Maintenance

For the seven maintenance and surveillance activities observed, no significant problems

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were noted. Unexpected interference between one surveillance test and a concurrent

maintenance activity in the same area resulted in water entering a dewatered circulating

water bay. However, the interference could not have reasonably been predicted.

(Section M1.1)

Enaineerina

Several additional environmental qualification concerns with steam exclusion dampers

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were identified during corrective action activities for a finding associated with a control

room damper. Licensee engineers completed a comprehensive evaluation which

adequately justified interim operability until the completion of evaluations and corrective

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actions, where necessary. (Section E1.1)

Although calculations eventually demonstrated that there should be sufficient indicated

auxiliary feedwater (AFW) flow under worst case conditions to prevent operators from

unnecessarily tripping reactor coolant pumps during a loss of feedwater accident with

only one AFW pump available, the initial operability assessment of the effect of installing

the AFW flow indication orifice plates backwards was weak because it did not address

that issue. (Section E1.2)

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Report Details

Summary of Plant Status

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Unit 1 operated at or near full power until June 2,1998, when power was reduced to

approximately 15 percent to facilitate maintenance and testing activities. Unit 1 was returned to

full power on June 4. On June 5,1998, Unit 1 tripped from full power when a control rod dropped

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into the core. The unit was placed in cold shutdown during troubleshooting and repairs and was

restarted on June 18. Unit 2 operated at or near full power for the entire inspection period.

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1. Operations

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Conduct of Operations

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01.1

Unit 1 Power Reduction for Coolina Tower 122 Inspection: Turbine Stoo. Governor and

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Intercept Valve Testina: and Condenser Tube Cleanina at Power

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Inspection Scope (Inspection Procedure (IP) 71707)

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On June 2,1998, operators reduced power on Unit i to facilitate the structural inspection

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of the 122 cooling tower. While at the decreased powerlevel of approximately

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200 megawatts (MW) or 40 percent, turbine valve testing and condenser tube cleaning

were performed. Power was subsequently reduced to about 15 percent so that personnel

could safely enter a reactor coolant pump vault. A power increase to 100 percent was

conducted on June 4,1998.- The inspectors observed most of the power changes. The

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documents reviewed by the inspectors to support this inspection were:

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Operating Procedure 1C1.4, " Unit 1 Power Operation," Revision 15;

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Special Operating Procedure D24.2, " Condenser Tube Cleaning At Power,"

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Revision 16;

Surveillance Procedure (SP) 1054, " Turbine Stop, Govemor, and Intercept Valve

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Test," Revision 18; and

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Alarm Response Procedure C47012-0602, "12 RCP (Reactor Coolant Pump]

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Reservoir Hi/Lo Level," Revision 23.

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b.

Observations and Findinas

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The inspectors observed the Unit 1 power reduction evolution from the control room. The

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inspectors noted good use of formal communications, attentiveness to control board

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indications, conservative and contro!Ied decision-making with regards to reactivity

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changes, consistently good acknowledgment of all alarm annunciators, and good

supervisory oversight by the shift supervisor. Comments on observations of turbine valve

testing in accordance with SP 1054 are contained in Section M1.1 of this report.

. After the power reduction to about 200 MW, condenser tube cleaning was performed in

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accordance with Procedure D24.2. The evolution consisted of draining the condenser

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inner-pass and outer-pass piping, one at a time, and cleaning of the Amertap screens,

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condenser tube sheets, and condenser water boxes. The inspectors attended the

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pre-evolution briefing, observed por%ns of the activities from both the control room and

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locally, performed checks of the isc.iion cards, and performed a review of the work

order which authorized the maintenance. The inspectors noted good coordination

during the evoluticn between the control room operators and the outplant operators

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draining and refilling the system. The inspectors observed that operators closely

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monitored circulating water and condenser parameters while the system was in an

abnormal line-up due to the maintenance.

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While the operators were retuming the outer-pass piping back to service, they noted a

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leak on the gasket for the lower manway located on the inner-pass outlet piping. Prompt

action was taken to secure the 11 cooling water pump, isolate and drain the inner-pass

piping, replace the manway gasket, and retum the inner-pass piping to service.

While operating at 200 MW, a "12 RCP Oil Reservoir Hl/ Low Level" alarm was received in

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the control room. This was a common alarm serving both the high and low setpoints for

the two oil sumps on the 12 RCP. Upon receiving the alarm, the inspectors observed that

the control room .3perators followed the guidance of the alarm response procedure which

required increased monitoring of RCP oil temperatures and vibrations. After no adverse

trends were observed, instrument and control technicians verified that the alarm was a

valid signal for a low levelin the lower reservoir. Comments on the subsequent

corrective actions for the condition are discussed in Section M1.1 of this report.

In order for personnel to enter the RCP vault while maintaining their radiation dose as low

as is reasonably achievable, operators reduced reactor power from about 40 percent to

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about 15 percent. The power reduction was accomplished in a controlled, deliberate

manner. The concurrent reactivity effects of the power reduction, adding positive

reactivity because of the power defect and adding negative reactivity because of xenon

production, were carefully tracked by the reactor operator. The lead reactor operator

adequately controlled the condenser activities and the transition from main to bypass

feedwater regulating valves, while maintaining an overview of unit status. The inspectors

observed that the lead reactor operator maintained a correct focus on plant operations, by

deferring non-essential activities, while power changes were occurring. Unit 1 was

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subsequently retumed to 100 percent power opera'. ion on June 4,1998, with no

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discrepancies noted by the inspectors.

c.

Conclusions

During the performance of power changes and relatively complex system alignments, the

operators maintained good control of the plant and, when confronted with abnormal

conditions, took prompt and conservative actions to restore the conditions to normal.

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01.2 Unit 1 Reactor Trio from Full Power

On June 5,1998, Unit 1 tripped from full power when Control Rod G7 dropped into the

core because of an electrical short which caused a blown fuse on its stationary gripper

coil. The NRC conducted a specialinspection of the trip and subsequent operator

performance during the recovery actions. The results of that inspection were

documented in inspection Report 50-282/08010(DRS).

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Unit 1 Reactor Sta'rtuo

a.-

Inspection Scope (IP 71707)

On June 17-18,1998, Unit 1 was started up and the generator placed on-line. The

inspectors observed portions of the reactor coolant system heatup, equipment

realignments for power cperation, withdrawal eT the shutdown control rod banks, warming

of the steam system, control rod withdrawal to criticality, and power ascension. Tne

following procedures were reviewed as part of this inspection:

Operating Procedure 1C1.2,? Unit 1 Stariup Procedure," Revision 19;

Operating Procedure C1 A, " Reactivity Calculations," Revision 13; .

Operating Procedurrs C1 B, " Appendix - Reactor Startup," Revision 6; and

Operating Procedure 1C1.4, " Unit 1 Power Operation," Revision 15.

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b.

Observations and Findinas

. All of the operations observed by the inspectors for starting up the plant and placing the

generator on-line were conducted in a careful and deliberate manner. No significant

discrepancies were noted. For the approach to criticality, the inspectors conducted

continuous observations in the control room. .The shift supervisor gave each operator

time to review the reactor startup procedure prior to the startup. Tha pre-evolution

briefing, conducted by the shift manager, was ad:quate and included a complete review

of all of the precautions. Duties of each individual member of the operations team were

clearly designated. A few industry events associated with startup errors were discussed,

although not in detail.

For the reactor startup, two extra reactor operators and one extra shift supervisor were

assigned. This allowed the operators actually performing and supervising the approach

to c.iticality to focus solely on that evolution. Distractions were minimized and control

room access was strictly controlled by the lead reactor operator One of the reactor

operators and a nuclear engineer performed independent inverse count rate calculations

and they compared the predicted critical rod positions frequently. Criticality was achieved

near the predicted point and was properly identified and recorded. Control room

communications were usually formal and all annunciators were properly announced and

assessed.

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Conclusions

The Unit 1 reactor startup and power ascension was performed in a deliberate and safe

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manner with no significant discrepancies noted. During the approach to criticality, the

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' operators involved focused solely on the task at hand.

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Operations Procedures anc' Documentation

O3.1

Editorial Errors in Technical Specifications TS) and Updated Safety Analysis Report

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(USAR) Reaardina Averaae Reactor Coolant System Temperature (T.,) Loaic

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Inspection Scope (IP 92901}

The inspectors identified editorial errors in the TS and USAR and verified that the errors

had no effect on p! ant operations. The inspectors reviewed the following documents as

part of this inspection:

TS Table 3.5-1, " Engineered Safety Features Initiation Instrument Limiting Set

Points," Rev;sion 44;

TS Table 3.5-28," Engineered Safety Feature Actuation System Instrumentation,"

Revision 111;

TS Table 4.1-18," Engineered Safety Feature Actuation System Instrumentation

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Surveillance Requirements," Revision 111;

Basis for Technical Specification 3.5, " Instrumentation System," Revision 111;

USAR Section 7.4.2.2.b, " Steam Line Isolation," Revision 14;

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USAR Table 7.4-1," List of ReactorTrips & Causes of Actuation of Engineered

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Safety Features, Containment and Steam Lli e Isolation & Auxiliary Feedwater,"

Revision 12;

USAR Figure 7.4-15, * Engineered Safety Feature Logic Diagram," Revision 1;

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USAR Section 14.5.5, " Rupture of a Steam Pipe," Revision 14; and

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SP 1002A," Analog Protection System Calibration," Revision 22.

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b.

Observations and Findinas

The T., instruments had both low and lo-lo logic seipoints. A low setpoint of

2554 degrees Fahrenheit ("F) was used in feedwater line isolaeon logic and a 10-10

setpoint of 2540 F was used in steam line isolation logic. The inspectors identified that

item 5 of TS Table 3.5-1 incorrectly stated that the steam line isolation setpoint was "High

Steam Flow in a Steam Line Coincident with Safety injection and Low T.," and the same

table incorrectly staied that the limiting setpoint for Low T , was 2540 F. Also, the TS

Basis for TS 3.5 incorrectly stated in two places that the input for steam line isolation was

Low T.,. Item 5d of Table 3.5-2B and item 5d of Table 4.1-1B, however, correctly stated

that steam line isolation was on high steam flow and Lo-Lo T,, with safety injection.

The inspectors reviewed the USAR and noted a similar error. Whereas,

Section 7.4.2.2.b, Item 21 of Table 7.4-1, and Figure 7.4-15 all correctly stated that the

input was Lo-Lo T.,, Section 14.5.5 incorrectly stated that the input was Low T,,.

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The inspectors verified that the surveillance test procedures for calibration of the

instruments included the proper setpoints, nomenclature, and logic. The inspectors also

interviewed severt! operations personnel and verified that there was no confusion on

their part regarding the setpoint for steam line isolation. Thus, the discrepancies had only

minor safety significance.

The inspectors informed a licensing engineer of the editorial disc epancies so that they

could be addressed in a future TS amendment request and USAR revision. The

inspectors also discussed the findings with the project manager in the NRC Office of

Nuclear Reactor Regulation. Due to the minor nature of the errors, the project manager

stated that correcting the TS could be postponed until the licensee's submittal of

Improved Standardized TS, unless other changes to the same table were submitted

earlier.

Technical Specifications, including proper limiting safety system settings, were required to

be submitted in accordance with 10 CFR 50.36. Although the numerical setting of

2540*F submitted by the licensee for TS Table 3.5-1 was correct, the nomenclature for

the setting was incorrect. This failure constitutes a violation of minor significance and is

not subject to formal enforcement action.

c.

Conclusions

The inspectors identified discrepancies in the TS and USAR regarding whether the steam

line isolation logic used the Low T., or Lo-Lo T,, setting. The discrepancy had no effect

on plant operations because surveillance test procedures included the proper setpoints

and logic. In addition, operators were knowledgeable of the proper setpoints and inputs

to the isolation logic.

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Quality Assurance la Operations

07.1 Manaaement Chanaes Affectina the Quality Assurance Organization (IP 7170.

On June 8,1998, the licensee announced organizational and management changes to be

effective on June 15. Mike Wadley, Vice President, Nuclear Generation, was named to

the newly created position of President, NSP Nuclear Generation. Ed Watzl, President,

NSP Generation, was named to the newly created position of Executive Vice President.

On June 16,1998, Mr. Wadley informed the NRC that the quality services department

would be reporting to him. Previously the department reported to the president, NSP

Generation, a position that was deleted in the organization change. The licensee was in

the process c4 determining whether this change in its Operational Quality Assurance Plan

was a ISduction in commitment.

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Miscellaneous Operations issues (IPs 92700,92901)

08.1 (Closed) Violation (VIO) 50-306/97006-01(DRP): Inadequate Procedure for Filling and

Venting the Reactor Coolant System; and

Closed) VIO 50-282/97011-01(DRP): 50-306/97011-01(DRP): Nine Examples of

Procedures of a Type Not Appropriate to the Circumstances.

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The two violations represented ten cases where operat;ng or maintenance procedures

were inadequate, either because they did not contain necessary information, or because

the information they did contain was inaccurate or misleading. The inspectors reviewed

the licensee's response to the violations contained in letters to the NRC dated

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May 30,1997, and August 25,1997. r:or each specific example, the inspectors verified

that the procedure had been revised to correct the discrepancy. The inspectors also

verified, were applicable, that similar procedures for the opposits train or unit had been

corrected.

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In addition to correcting the specific procedure problems, the licensee instituted a

comprehensive proceduru improvement program. Details of that program have been

discussed in previous inspection reports and public meetings, including the recent

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meeting for the Systematic Assessment of Licensee Performance held on May 19,1998.

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08.2 (Closed) Licensee Event Report (LER) 50-282/97008 (1-97-08): Unit 1 Reactor Trip

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Caused by Electrical Ground in Rod Control System. This event was previously

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discussed in inspection Report 50-282/97011(DRP); 50-306/97011(DRP), Section O3.1.

The cause of the trip was a short to ground in one of the wires to a control rod stationary

gripper coilinside the connector on the cable near the reactor head. The connector was

sent to an independent laboratory for analysis. During this inspection period, another

Unit 1 trip occurred from what appeared to be a similar failure on another control rod

stationary gripper coil. The cable for that rod and two others were sent to another

laboratory for analysis. The licensee will issue LER 1-98-08 describing the cause and

corrective actions for the latest trip. The new LER and its associated corrective actions

will also include the information leamed from the followup associated with the event

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described in LER 1-97-08. Since the corrective actions for the second trip will include any

remaining actions for the first trip, the first LER is closed to avoid duplication.

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II. Maintenance

M1

Conduct of Maintenance

' M1.1 Surveillance Testina and Maintenance Observations

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Inspection Scope (IPs 61726. 62707)

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The inspectors witnessed all or major portions of the following maintenance and

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surveillance testing activities. Included in the inspection was a review of the surveillrace

procedures (SPs) and work orders (WOs) listed below, as well as the appropriate US 3

sections regarding the activities. The inspectors verified that the surveillance tests

reviewed met the requirements of the TS.

WO 9804341, " Rebuild 11 Circulating Water Traveling Scree Y'-

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WO 9805103, " Perform Control Rod Drive Mechanism Timing Tests (Hot)";

SP 1032B, " Safeguards Logb rest At Power- Train B," Revision 5;

SP 1032C, "Safeguads Boric Acid Logic Test," Revision 3;

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SP 1054, " Turbine Stop, Govemor, and Intercept Valve Test," Revision 18;

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SP 1102, "11 Turoine-Driven AFW [ Auxiliary Feedwater] Pump Monthly Test,"

Revision 62; and

SP 1202, " Fire Pump (s) Test Fire Protection System," Revision 11.

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b.

Observations and Findinas

On May 27,1998, the inspectors observed the pre-job briefing for and the

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performance of testing of the automatic actuation and capacity of the three fire

protection pumps in accordance with SP 1202. Coincidently, maintenance

workers were preparing to enter the 11 circulating water intake bay, which had

been isolated with stop logs and dewatered, for rebuilding of the 11 c;rculating

water traveling screen in accordance with WO 9804341. The workers noted that

water was flowing into the bay and the inspectors pointed out that the water was

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coming from the fire protection system test header discharge piping, which

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discharged on the other side of the stop logs. Some of the fire protection water

was discharging over the stop logs into the dewatered bay.

The inspectors interviewed operations, mainte, nance, and work planning

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personnel involved with SP 1202 and WO 9804341 to determine if there was a

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work control problem that allowed two conflicting jobs to be scheduled at the

same time. The inspectors determined that the conflict would have been hard to

predict.

Drawing NF-39261-2,"Screenhouse Fire Protection and Screen Wash Piping,"

Revision J, showed that the fire protection test header discharged at least 10 feet

away from the stop logs. Without a close inspection of the exact configuration of

the piping, it was not obvious that some of the test header water would be

discharged over the stop logs. No one interviewed remembered the fire

protection discharge header ever being used while the 11 circulating water bay

was dewatered, so there was no previous experience to draw from. Thus, the

inspectors concluded that there had not been a significant breakdown in the

maintenance planning process.

The amount of water that was discharge over the step logs was not a significant

personnel hazard, even if the workers had been in the bay, because of the

relatively large bay volume and the dewatering pumps that were installed.

For turbine stop, Govemor, and lntercept valve testing in accordance with

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SP 1054, the inspectors observed portions of both the co'itrol room operations

and local activities. The inspectors noted that the pre-evolution briefing was

adequate and that the evolution was conducted in a safe and controlled manner.

The inspectors observed that the operation of the valves being tested was

smooth, with no evidence of binding or leekage.

The surveillance was completed satisfactorily except for a position indication limit

switch for the 1B reheater stop valve being out-of-alignment. The inspectors

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noted that, when this problem was ericountered during the performance of

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surveillance testing, the evolution was temporarily stopped, the 18 reheater stop

valve posiuon was verified by location indication to be shut, and a work order was

prepared to authorize adjustment of the limit switch.

As discussed in Section 01.1 of inis report, a reactor coolant pump low oil level

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condition was confirmed on the 12 RCP. A power reduction to approximately

15 percent was performed and a work order was prepared with instructions for

entering containment to inspect the RCP and adding oil to the lower oil reservoir.

The inspectors interviewed the system engineer who supervised the corrective

actions and he reported that there was slight leakage from a drain valve fitting,

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which was corrected by tightening the fitting; slight weepage from a sight glass,

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which could not be corrected with the pump running; and that 2% gallons of oil

were added to clear the low level alarm. Additionally, he reported that there was

no large build-up of oil present and that there was approximately 2% quarts of oil

in the flash pan, which was wiped up. The rest of the oil would have drained to a

collection tank.

c.

Conclusions

For the seven maintenance and surveillance activities observed, no significant problems

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were noted. Unexpected interference between one surveillance test and a concurrent

maintenance activity in the same area resulted in water entering a dewatered circulating

water bay. However, the interference could not have reasonably been predicted.

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M8

Miscellaneous Maintenance issues (IPs 92700,92902)

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M8.1 (Closed) LER 50-306/98002 and LER 50-306/98002. Supplement 1 (2-98-02): Defect in

Primary System Pressure Boundary Observed on the Motor Tube Base of Part Length

CRDM [ Control Rod Drive Mechanism) Housing. This event was previously discussed in

inspection Report 50-282/97003(DRP); 50-306/97003(DRP), Sections 01.3 and M1.2.

The licensee supplemented the original LER on May 22,1998, with the results of an

analysis performed by Westinghouse and reported in WCAP-15054, " Metallurgical

Investigation and Root Cause Assessment of Part Length CRDM Housing Motor Tube

Cracking at Prairie Island Nuclear Generating Plant Unit 2." The licensee submitted the

report to the NRC in a separate letter dated May 15,1998.

The conclusion reported in the analysis was that the flaw was a weld fabrication defect

with no evidence of service-induced growth. The flaw was most likely caused by

contamination introduced in the welding process. No other similar defects were identified

in the other part length CRDMs removed from Prairie island Unit 2 nor on any of the

60 part length CRDMs removed from other plants. Therefore, the problem was

considered an isolated case. All of the part length CRDMs were removed from Unit 2 and

the licensee intended to either inspect or remove the Unit 1 part length CRDMs in the

next refueling outage. In the interim, the enhanced leak monitoring measures discussed

in the LER remained in effect for Unit 1. The NRC Office of Nuclear Reactor Regulation

was continuing to review the generic aspects of this issue.

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Ill. Enaineerina

E1

Conduct of Engineering

E1.1

Steam Exclusion Dampers Not Environmentally Qualified (EO)

a.

Inspection Scope (IP 92903)

On June 22,1998, the inspectors were informed that licensee engineers had identif:ed

several steam exclusion dampers or components located in areas that would potentially

be harsh environments following a steam line break accident. Some components in the

dampers and damper actuation equipment were not qualified for those conditions. The

inspectors reviewed the licensee's operability evaluation of the dampers and proposed

corrective actions.

b.

Observations and Findinas

As discussed in Inspection Report 50-282/98007(DRP); 50-306/98007(DRP),

Section E8.1, and LER 50-282/98006; 50-306/98006 (1-98-06), the licensee discovered a

damper in the control room ventilation system that was not EQ and was located in a

potentially harsh environment. This issue was considered a non-cited violation. One of

the corrective actions described in the LER was for the licensee to inspect all other steam

exclusion dampers to assure that the non-EQ equipment was not located in potentially

harsh environments. While performing that inspection, licensee engineers identified and

evaluated several discrepancies.

Dampers CD-34185 and CD-34186, which isolated the Unit 1 Iow level waste gas

storage tank area, were located in a potentially harsh environment. Licensee

engineers determined that steam exclusion in that area was not required and

were in the process of downgrading the dampers.

Dampers CD-34145 and CD-34142, which isolated control room outside air, had

electrical boxes containing fuses and terminal strips located in potentially harsh

environment areas. Dampers CD-34187 and CD-34188, which isolated portions

of the auxiliary building, had most of their components locate.d in potentially harsh

environment areas. Also, eight dampers which isolated the auxiliary feedwater

pumps rooms and safeguards battery rooms had some or most of their

components located in the nonsafeguards bus rooms which nad never been

evaluated for post-accident environmental conditions. For all of those dampers,

licensee engineers performed operability assessments, including some

component testing, which indicated that the dampers would perform satisfactorily

during high energy line break accidents. Operability was based on the followinC:

actuation of the dampers to the post-accideM positions would take place

when temperatures in the area reached 114 'F., which was still considered

a mild environment;

in all cases, the actuation signal would be sealed in by relay; located in a

mild environment;

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all dampers would fail to the desired poat-accident oositions on a loss of

electrical power orinstrument air;

degradation of the mechanical components of the dampers subject to

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thermal damage would not cause the dampers to reopen or leak

excessively; and

complete degradation of all non-metallic components of the solenoid

.

valves which ported instrument air to the dampers would not result in

enough air leakage to actuate the dampers to the open position.

The last point was verified by testing solenoid valves with all non-metallic components

removed and verifying that outlet port leakage was not of a quantity or pressure high

enough to inadvertently open the dampers.

Licensee Non-Conformance Report (NCR) 19981105 documented the licensee's findings,

operability evaluation, testing, and planned corrective actions for these issues. The

inspectors reviewed the NCR and found that it was comprehensive and contained

adequate information to justify interim operability until corrective actions were completed.

A total of 15 out of a population of 26 steam exclusion dampers had at least some EQ

concems. The licensee was still evaluating whether the discrepancies placed the

components outside of the design basis. The status of these issues will be reviewed

again during the inspectors' next review of LER 1-98-06.

c.

Conclusions

The licensee identified several additional EQ concems with steam exclusion dampers

during corrective action activities for a finding associated with a control room damper.

Licensee engineers completed a comprehensive evaluation which adequately justified

interim operability until the completion of evaluations and corrective actions, where

necessary.

i

E1.2

Evaluation of the Effect of Improperly Installed AFW Flow Instrument Orifice Plates on the

Use of Emeroency Operatina Procedures (EOPs)

a.

Inspection Scope (IP 92903)

The inspectors reviewed engineering calculations to determine if there was a concern

that operators could be led to take unnecessary actions, while following EOPs, due to the

Unit 2 AFW flow instrument orifice plates being installed backwards. The following

documents were reviewed during this inspection:

Calculation ENG ME-366," Minimum Expected AFW Flow Indication to Unit 2

a

Steam Generators at 1077 psig [ pounds per square inch-gauge]," dated May 28,

1998;

Calculation ENG ME-367," Determination of Expected AFW Flow Rates for

+

Operating Procedures," dated May 22,1998;

12

I

ib

NCR 19980890, " Unit 2 Degraded AFW Flow Indication as a Result of Orifices

-

Being installed Backwards"; and

Functional Restoration Guideline 2FR-H.1," Response to Loss of Secondary Heat

+

Sink," Revision 9.

b.

Observations and Findinas

This issue was previously discussed in inspection Report 50-282/98007(DRP);

50-306/98007(DRP), Section M3.3. Because AFW flow detector orifice plates were

installed backwards, indicated flow would be expected to be less than actual flow. The

inspectors raised the concern that, if AFW flow indicated less than 200 gallons per minute

(gpm) when it was actually greater than 200 gpm, an unnecessary entry into 2FR-H.1

during certain EOP scenarios could result. The guideline contained instructions to stop

the RCPs to limit the heat input to the steam generators. The accident of most concern

was a loss of feedwater with a concurrent loss of one of the two AFW pumps. Decay

heat removal via natural circulation without RCPs was within the design basis of the

{

plant, but it would coraplicate the operators' response.

During this inspection period engineering calculations ENG-ME-366 and 367 were

]

performed, reviewed, and approved by licensee engineering personnel. The engineers

concluded that worst case expected AFW flow indication with the flow orifices installed

backwards was 202 gpm. Thus, unnecessary entry into 2FR-H.1 would not occur. The

,

inspectors reviewed the calculations and identified no concems with the licensee's

j

conclusions.

l

The licensee's initial operability assessment of the effects of the AFW flow orifices being

installed backwards was contained in NCR 19980890. That assessment included a

review of the effects of operators setting indicated AFW flow to values specified in the

EOPs, resulting in higher than specified actual flows. No adverse effects during ECP

activities were identified. However, the NCR did not address the possibility that specified

indicated flow might not be obtainable because of the orifice errors. The operability

)

assessment was weak in that it failed to consider that a potential entry into 2FR-H.1 might

)

result. However, the latter calculations, performed because of the inspectors' concerns,

indicated that there would still be a small margin of indicated flow above the 2FR-H.1

entry condition.

c.

Conclusions

Although calculations eventually demonstrated that there should be sufficient indicated

AFW flow under worst case conditions to prevent operators from unnecessarily tripping

reactor coolant pumps during a loss of feedwater accident with only one AFW pump

available, the initial operability assessment of the effect of installing the AFW flow

indication orifice plates backwards was weak because it did not address that issue.

13

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

_ _ .

.

E2

Engineering Support of Facilities and Equipment

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1

E2.1

Review of UCAR Commitments (IPs 37551. 92903)

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 descript!ons as discussed in each

section. The inspectors verified that the USAR wording was consistent with the observed

plant practices, procedures, and parameters. One minor editorial discrepancy was

identified in USAR Section 14.5.5 as discussed in Section O3.1 of this report.

E8

Miscellaneous Engineering issues (IPs 92700,92903)

E8.1

(Closed) LER 50-282/97001: 50-306/97001 (1-97-01): Auxiliary Building Crane Protective

Features Defeated by Wiring Errors. This issue was previously discussed in inspection

Report 50-282/97002(DRP); 50-306/97002(DRP), Section 01.2. The finding was treated

as a Non-Cited Violation in that report. The inspectors reviewed spent fuel cask handling

procedures to ensure that notes were added to describe the new labeling and key

functions on the crane control transmitter box and that the procedures were revised to

require the crane operator to check the fuel pool enclosure roof slot limit switch function

prior to critical lifts. Other corrective actions, as specified in the LER, were verified by

discussions with the cognizant members of the licensee engineering staff.

E8.2

(C!osed) LER 50-282/97010 (1-97-10): Failure to Evaluate the Condition of a Residual

Heat Removal Pump When the Vibration Level During a Surveillance Test Was Recorded

at the Alert Level. This issue was previously discussed in Inspection

Report 50-282/97015(DRP); 50-306/97015(DRP), Sections M7.1 and M8.7. The finding

was treated as a Non-Cited Violation in that report. The inspectors verified by review of

licensee documents that the corrective actions discussed in the LER had been

i

completed. A memorandum was sent on August 24,1997, to all engineering personnel

emphasizing the need to follow the administrative work instructions for system turnovers

between system engineers. Training on American Society of Mechanical Engineers

inservice testing requirements was given to mechanical system engineers on October 3

ar,d October 8,1997.

E8.3

(Closed) LER 50-282/97018: 50-306/97018 (1-97-18): Failure to Test the Auto-Start

Feature of the Control Room Ventilation System Air Handlers Due to Procedure

Deficiency. This issue was previously discussed in inspection

Report 50-282/97023(DRP); 50-306/97023(DRP), Section E3.1. The finding was treated

as a Non-Cited Violation in that report. The inspectors verified by review of licensee

documents that SP 1083, " Unit 1 Integrated SI (Safety injection] Test with a Simulated

Loss of Offsite Power," Revision 24, and SP 2083, " Unit 2 Integrated SI Test with a

Simulated Loss of Offsite Power" Revision 21, contained changes to verify the automatic

start of the control room air handler fans on an SI during the refueling outage surveillance

tests.

14

_ _ _ _ _ _ _ _ _ -_-_-

l

E8.4

(Open) LER 50-282/98006: 50-306/98006 (1-98-06): Control Room Vent Outside Air

Equipment Qualification. Additionallicensee findings discovered during corrective actions

i

for this LER were discussed in Section E1.1 of this report. Resolution of the additional

I

concerns will be included in the closing of this LER in a future inspection.

E8.5

(Closed) Unresolved item (URl) 50-28?/98007-07(DRP): 50-306/98007-07(DRP):

Possible Failure to Perform an Evaluation in Accordance with 10 CFR 50.59. This issue

I

was previously discussed in Inspection Report 50-282/98007(DRP); 50-306/98007(DRP),

Section E3.1. The inspectors reviewed Addendum 1 to Safety Evaluation 95T047,

' Backup Compressed Air Supply for Cooling Water Strainer Backwash Valve Actuator,"

which contained an evaluation of all failure modes of the backup air bottle regulator. The

licensee's conclusion, documented in Addendum 1, was that the temporary modification

did not involve an unreviewed safety question. The inspectors had no further concerns

with the safety evaluation.

IV. Plant Support

I

!

P2

Status of Emergency Preparedness Facilities, Equipment, and Resources

!

)

P2.1

Temporary Inoperability of Public Alert Sirens (IP 92904)

On June 1,1998, the licensee reported in accordance with 10 CFR 50.72 that about 39

percent of the public alert sirens surrounding the plant had been lost due to

weather-related power interruptions on or about 11:05 p.m. on May 30,1998. Most of the

i

sirens were restored by 12:18 a.m. on May 31. The licensee did not become aware of

{

the extent of the losses until June 1. Routine siren testing conducted on June 3,1998,

'

indicated that only four sirens were inoperable at that time and all were returned to

service by June 4. The licensee was in the process of determining which electrical power

lines fed which sirens in order to be able to better predict which sirens would be lost

during electrical outages. This issue will be reviewed in the next NRC emergency

preparedness inspection.

'

F2

Status of Fire Protection Facilities and Equipment

{

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F2.1

PotentialInadeouate Separation Between Fire Areas (IP 92904)

I

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On May 26,1998, the licensee reported, in accordance with 10 CFR 50.72, that it had

]

identified some areas in which separation between fire areas may not have met

!

10 CFR Part 50, Appendix R requirements. The issues were identified during licensee

'

self-assessments in preparation for a planned NRC Fire Protection Functional Inspection.

The licensee intended to conduct additional evaluations of the findings and issue

LER 2-98-03 to report its findings. The LER will be assigned to the NRC Fire Protection

Functional Inspection Team for followup.

F8

Miscellaneous Fire Protection issues (IP 92904)

F8.1

(Closed) VIO 50-282/97011-05(DRP): Failure to Provide Safe Shutdown Emergency

l

Lighting for Access and Egress Routes to the Safeguards Bus No.15 Room. This issue

'

was previously discussed in Inspection Report 50-282/97011(DRP); 50-306/97011(DRP),

i

15

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_ _ - - - - - - - _ _ - - -

_-

)

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

Section M3.3. The inspectors reviewed the licensee's corrective actions, including the

revision of surveillance test procedures and the installation of a new emergency light

illuminating the access and egress routes to the Safeguards Bus No.15 room. The

corrective actions were found to be complete and the inspectors had no additional

concems. The inspectors also noted that the I?:ensee installed 13 additional emergency

lights in various location throughout the plant as a result of findings during recent fire

protection self-assessment efforts. In addition, the licensee was considering performing

darkened condition tests to verify the adequacy of emergency lighting.

V. Manacement Meetings

X1

Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on June 18,1998. The licensee acknowledged the findings

presented. The inspectors asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was identified.

(

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16

__________ __ ____ _

1

.

.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

i

J. Sorensen, Plant Manager

K. Albrecht, General Superintendent Engineering, Electrical / Instrumentation & Controls

T. Amundson, General Superintendent Engineering, Mechanical

J. Goldsmith, General Superintendent Engineering, Generation Services

'

J. Hill, Manager Quality Services

G. Lenertz, General Superintendent Plant Maintenance

R. Lindsey, General Superintendent Safety Ascessment

D. Schuelke, General Superintendent Radiation Protection and Chemistry

.

T. Silverberg, General Superintendent Plant Operations

1

M. Sleigh, Superintendent Security

17

f

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-

-

-


- -

-

-

--

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.

.

INSPECTION PROCEDURES USED

IP 37551:

Engineering

IP 61726:

Surveillance Observations

IP 62707:

Maintenance Observations

IP 71707:

Plant Operations

IP 71750

Plant Support Activities

l

IP 92700:

Onsite Follow-up of Written Reports of Non-routine Events at Power Reactor

Facilities

IP 92901:

Follow up - Operations

IP 92902:

Follow up - Maintenance

IP 92903:

Follow up - Engineering

IP 92904:

Follow up - Plant Support

1

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I

ITEMS OPENED, CLOSED, AND DISCUSSED

'

Opened

i

None.

Closed

50-282/97001 (1-97-01)

LER

Auxiliary Building Crane Protective Features Defeated by

l

50-306/97001

Wiring Errors

j

50-306/97006-01(DRP)

VIO

Inadequate Procedure for Filling and Venting the Reactor

!

Coolant System

50-282/97007-07(DRP)

URI

Possible Failure to Perform an Evaluation in Accordance

50-306/97007-07(DRF)

with 10 CFR 50.59

50-282/97008 (1-97-08)

LER

Unit 1 Reactor Trip Caused by Electrical Ground in Rod

Control System

50-282/97010 (1-97-10)

LER

Failure to Evaluate the Condition of a Residual Heat

Removal Pump When the Vibration Level During a

,

Surveillance Test Was Recorded at the Alert Level

j

l

50-282/97011-01(DRP)

VIO

Nine Examples of Procedures of a Type Not Appropriate to

'

50-306/97011-01(DRP)

the Circumstances

50-282/97011-05(DRP)

VIO

Failure to Provide Safe Shutdown Emergency Lighting for

Access and Egress Routes to the Safeguards Bus No.15

Room

l

50-282/97018 (1-97-18)

LER

Failure to Test the Auto-Start Feature of the Control Room

50-306/97018

Ventilation System Air Handlers Due to Procedure

'

Deficiency

50-306/98002 (2-98-02)

LER

Defect in Primary System Pressure Boundary Observed on

Supplement 1

the Motor Tube Base of Part Length CRDM Housing

18

i

_ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _ _ .

.

Discussed

I

50-282/98006 (1-98-06)

LER

Control Room Vent Outside Air Equipment Qualification

50-306/98006

1

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- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ,

LIST OF ACRONYMS USED

AFW

Auxiliary Feedwater

CFR

Code of Federal Regulations

CRDM

Control Rod Drive Mechanism

DRP

Division of Reactor Projects

DRS

Division of Reactor Safety

EOP

Emergency Operating Procedure

EQ

Environmentally Qualified

F

Degrees Fahrenheit

gpm

Gallons Per Minute

IP

inspection Procedure

LER

Licensee Event Report

MW

Megawatts

NCR

Non-Conformance Report

NRC

Nuclear Regulatory Commission

NSP

Northern States Power Company

psig

Pounds Per Square Inch-Gauge

RCP

Reactor Coolant Pump

SI

Safety injection

i

SP

Surveillance Procedure

T.,

Average Reactor Coolant System Temperature

TS

Technical Specifications

URI

Unresolved item

USAR

Updated Safety Analysis Report

VIO

Violation

WO

Work Order

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20

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.