IR 05000282/1988013

Insp Repts 50-282/88-13 & 50-306/88-13 on 880718-22.No Violations or Deviations Noted.Major Areas Inspected: Licensee Action on Previous Insp Findings Re App R & Fire Brigade Annual Training Program

ML20151Y434
Person / Time
Site:	Prairie Island
Issue date:	08/19/1988
From:	Darrin Butler, Gardner R, Hodor R, Parkinson K, Ulie J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151Y405	List: IR 05000282/1988013 ML20151Y401
References
50-282-88-13, 50-306-88-13, NUDOCS 8808260387
Download: ML20151Y434 (13)

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e U.S. NUCLEAR REGULATORY COMISSION

REGION III

Reports No. 50-282/88013(DRS); 50-306/88013(DRS) >

Docket Nos. 50-282; 50-306 Licenses No, DPR-42; DPR-60 Licensee: Northern States Power Company 414 Nicollett Mall Minneapolis, MN .55401 Facility Name: Prairie Island Nuclear Generating Plants, Units 1 and ?

Inspection At: Red Wing, Minnesota Inspection Conducted: July 18-22, 1988  :

I. 4 % h Inspectors: D. S. Butler fy -l */ - M'

Date s W . l R. S. Hodor 8'I6~ N Date

%- W td2 UK. L. Parkinson

h 8 -13 - 3 0 Date

M- Q J. M. Ulie 6' l6 ' M bb%

Approved By: Ronald N. Gardner, Chief Plant Systems Section 3-li-t h Date Inspection Summary Inspection on July 18-22, 1988 (Reports No. 50-282/88013(DRS);

No. 50-306/88013(DRS)) ,

Areas Inspected: Spe::ial, announced inspection of licen'ee action on previous  !

inspection findings which included Sections III.G, J and t of 10 CFR Part SC, Appendix R. In addition, the witnessing of the fire brigade annual training program was per*ormed. The inspection was performed ir. accordance with NRC Manual Chapter Procedures 30703, 64100, 64704, 92701 and 9270 Results: No violatians or deviations were identified. A strength of the licensee's fire protection program observed during this inspection regarded the practical fire training being provided the fire brigade members during the annual training sessio hgg8gj@@ g2

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DETAILS _;

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Persons Contacted r Northern States Power Company

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• T. Amundson, General Superintendent Training

• T. Bacon, Quality Assurance Engineer

, K. K. Beadell, Superintendent Technical Engineering .-i

'*0. Brown, Senior Production Engineer

• E. T. Burke, Senior Production Engineer

• 0. Carlson, Operations Engineer  ;

• L. Eliason, General Manager Nuclear Plants

*J. Solvmith, General Superintendent Nuclear Technical Services

• A. A.-Hunsted, Staff Engineer

• B. Johnson, Engineer I

• D. H. Koppes, Quality Assurance Specialist

• M. F. Klee, Superintendent Quality Engineer

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0. Krech, Lead Quality A*=urance Engineer

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• D. Mendele, Plant Superintendent Engineering Radiation Protection

• G. Miller, Superintendent Operations Engineering l

• ! Pickens, Senior Nuclear Safety Engineer

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• D. Reynolds, Operations Training Supervisor

, C. Rizzo, Engineer Associate

*J. Ruether, Lead Engineer

*M. Sellman, General Superintendent Plant Operations ,

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• J. Sorensen, Shift Manager *

• E. Watzl, Piant Manager M. Werner, Senior Technical Instructor Gasser Associates

• C. Kreutz, Licensing Engineer 1 ,

Impe11 Corporation j

! G. Poletto, Supervisory Engineer U.S. Nuclear Regulatory Commission

• J. E. Hard, Senior Resident Inspector

• M. Moser, Resident Inspector -

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The inspectors also contacted other licensee personnel during the inspection visi * Denotes persons attending the exit interview of July 22, 1988.

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. Licensee Action on Previous Inspection Findings (Closed) Open Item (282/87004-01; 306/87004-01): Suction for the Auxiliary Feed Water (AFW) pumps may have to be realigned from the Condensate Storage Tanks (CSTs) to the Cooling Wcter Systet prior to depletion of CST volume. The lack of dire:t indication of CST level at either the A Train Hot Shutdown Panel or 10: ally at the tanks, or assurance of procedures to verify CST level was considered to need further licensee evaluatio The Control Room Evacuation (fira) Safe Shutdown Procedure (Appendix B of Section F5 to the Plant Operations Manual, Revision 4)

added a note that directs the operator to switch over to the Cooling Water System from the CST's when the AFW cump suction approacnes four (4) inches Hg vacuum. Attachment 10 to Procedure FS, Appendix 8 is a plot of AFW pump suction pressure versus CST level, therefore, this item is considered close The following was also verified:

• Local flow indicators ar liable in the AFV pump rooms to verify AFW flo AFW fl, _a +he 11 and 12 steam generators

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may also be verified using local flow indicators in the auxiliary building near the component cooling heat exchanger * Local indication of refueling water storage tank level is available at the tanks. The emergency diesel c?nerator fuel oil day tank level indication is provided locally on the engine generator panel along with diesel operating instrumentation and generator voltage and frequency indication, (Closed) Open Item (282/87004-02; 306/87004-02): The F5 Appendix B Procedure does not contain instructions for the operator to close the MSIV's and Pressurizer PORV's from outside the control roo During this inspection, the inspectors learned that Steps 3.C.II.2, and 3.D.II now provide instructions for closing the MSIV's and pressurizer PORV's from outside the control room. This is a satisfactory resolution, therefore, this item is considered closed, (Closed) Open Item (282/87004-03; 306/87004-03): The F5 Appendix B Procedure directed the operator to try all air compressors to fail all tir operated components in the loss of air position. Once air pressure bleeds off, it is assumed that all air operated components have reached their loss of air position. The licensee was requested to revise the procedure to show positive verification that the let-down lines have been secure _

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Subsequutly, the licensee added Step 4.1.2 to Procedure F5,

. Appendix B, in Revision 4 directing the operator to open the air receiver blowdown valves; thereby ensuring let-down isolation valve closure in less than 8 1/2 minutes. Therefore, this item is considered close (Closed)OpenItem(28c/87004-04;306/87004-04):' The licensee's

' methodology for natural circulation cooldown does not rely on pressurizer heaters and PORV's. The licensee was not able to provide an analysis of pressurizer level and pressure versus time for the natural circulation cooldown. The results and infonnation from such an analysis if incorporated into the procedure would orovide guidance to the operator performing a natural circulation cooldown from the Train A Hot Shutdown Pane During this inspection, the licensee provided the inspectors with a satisfactory analysis including Figure 1 which could be used by the operators to guide a natural circulation cooldown and has been incorporated into Procedure F5, Appendix B, Revision Therefore, this item is considered close e. (0 pen) Violation (282/87004-05;306/87004-05): The inspectors reviewed the common bus area of associated circuits. The licensee's

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protection for the conrnon bus area of associated circuits was circuit coordination. The licensee had determined that the following safe shutdown circuits were not coordinated:

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MCC 1A BUS 1 MCC 1AC BUS 1 j MCC 1A BUS 2 MCC 2K BUS 1 MCC 1K BUS 1 MCC 2A BUS 1 i

i The licensee had consnitted to completing modifications that would

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correct breaker coordination deficiencies by May 31, 1987, for Unit I l and February 1988 for Unit Coordination for the above listed circuits was verified to be satisfactory. Therefore, this item is considered closed, i

, In addition, the following safe shutdown circuits were reviewed and i

found to be coordinated:

MCC 2AC BUS 1 MCC 2AC BUS 2 i

MCC 1KA BUS 2 MCC 2KA BUS 2 120 VAC PANEL 1EMA 120 VAC PANEL 1EMB 120 VAC PANEL 2EMA 120 VAC PANEL 2EMB MCC 2A BUS 2 MCC 1AC BUS 2

The coordination of safe shutdown power supplies was found to be satisfactory for the circuits examine !

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I (Closed) Open Item (282/87004-05; 306/87004-06): The licensee committed to implementing procedures to control fuse replacement e activities primarily for Appendix R purpcses to preclude the '

possibility of improper fuse substitution. A review of the licensee's administrative control procedures determinert that the .

l following controls were implemented for controlling fuse replacement: '

• Administrative Control Directive Number SACD 3.2, Revision 14, j Paragraph 6.1.34, provides the following instructions:

When packages involve the installation or replacement of *

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Electrical Distribution Panel (EDP) fuses or breakers, those installed or replaced shall be identical to that specified on the EDP Listing (available in hard copy.in the Control Room or

thru the "E" run on the Sperry) or an approved EDP Update Form (PINGP 900). If the EDP listing is blank, the fuse or breaker  ;

shall be replaced with the same type removed from the panel,

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and an EDP Update Form shall be comp hted and sent to the i Superintendent Technical Engineering QTE). '

• Administrative Control Directive Number SACD 3.12, Revision 7,

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Paragraph 6.1.15, provides the following instructions:

., EDP fuses or breakers installed / replaced shall be identical to  ;

that specified on the EDP Listing or approved EDP Update Form

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) (a) Any deviation from the type of fuae or breaker identified i

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on the EDP Listing shall be approved by the STE, or ,

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designee, and documented en en EDP Update For .

(b) If the EDP Listing is blank, the fuse or breaker  !

installed / replaced shall be the same type as removed from the panel and an EDP Update Form completed (routed to STE). ,

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1 * /*ninistrative Work Irdtruction Number SAWI 3.10.3, .

Revision 1, Paragraph 6.6.10, provides the following ,

} instructions: '

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' i When removing HOLD or SECURE cards, each specific card to be  !

removed shall be identified in order to minimize the L

possibility of removing a card which has not been released, i NOTE: When removing HOLD or SECllRE cards, the plant operator or '

other authorized per:onnel shall verify that the fuse or  !

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breaker being installed is identical to that specified l on the EDP Listing. Any deviation from the type of  !

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fuse / breaker identified on the EDP Listing shall be approved by the STE or designee, and documented on an EDP Update Form, (PINGP 900).

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Therefore, this item is considered closed.

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g. (Closed) Unresolved Item (282/87004-07; 306/87004-07): A review of the licensee's high impedance fault analysis identified the possibility of the loss of the 100 amp source fuse to DC panel 16-located in Fire Area 18, Auxiliary Building Mezzanine Unit 1, on elevation 715 (Fire Area 59). The analysis determined that the safe shutdown load, DG D2 relay panel, is presently supplied from DC panel 16 located in Fire Area 18 and as a consequence would also be lost. The licensee investigated alternative sources of power for the DG 02 Relay Panel to preclude this possibilit According to the licensee's staff, the high impedance fault concern was a new issue since the licensee's Append 1x R commitment dates were established and weren't learned of until Generic Letter 86-10 (April 1986) was reviewe The licensee has installed Modification No. 87L980, D2 Relay Panel Power Supply, which revised the power supply for 02 Relay Panel due to high impedance fault issues for Appendix R. Specifically, Modification No. 87L980 transferred the source to the 02 Emergency Generator Lockout Relay from Pa.1el 16 to Panel 22 because Panel 16 was determined to be susceptible to high impedance overcurrents after a review of the Prairie Island high impedance fault Analysi This same analysis also demonstrated that Panel 22 will not be affected by high impedance overcurrent Because Panel 22 currently serves as the source for other D2 control circuitry, transferring from Panel 16 to Panel 22 will not affect power train separatio Therefore, this item is considered closed, h. (Closed) Open Item (282/87004-08; 306/87004-08): It was determined that the licensee's analysis requires further clarification to address control of the following interfaces:

Pressurizer PORVs Normal letdown Excess letdown The licensee's present method of control for these interfaces is by procedural actions prior to evacuation of the control room. Unless alte.-native actions from outside the control room are specified in the procedure, the only action normally given credit for prior to control room evacuation is a reactor tri In response to this concern, the licensee initiated a revision to the Control Room Evacuation Safe Shutdown Procedure F5, Appendix B, to secure pressurizer PORVs, and normal and excess letdown lines from outside the control roo p

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The pressurizer PORV interface is made up of two parallel paths, each r.onsisting of two valves in series. Specifically:

Unit-I interfaces are:

PORV, CV-31231, and associated block valve, MOV-32195, and i

PORV, CV-31232, and associated block valve, M0V-3219 Unit-II interfaces are:

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PORV, CV-31233, and associated block valve, M0V-32197, and PORV, CV-31234, and associated block valve, MOV-3219 Control Room Evacuation Safe Shutdown Procedure, F5, Appendix B, Revision 4, Step 3.D.ii, directs the operators to remove / pull the fuses for the pressurizer. Pulling fusas has been considered to be a hot shutdown repair and consequently has required review on a plant specific basi The licensee's plant specific configuration for pulling the pressurizer PORV fuses was examined and found as follows: '

• The fuse panels (4) are readily accessibl * The fuses are clearly identified in the panels,

• The fuse panels have sufficient space to permit ready / easy

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access for pulling the fuses, a

• Emergency lights have been installed to support pulling the fuse '

• Fuse pullers are installed in each panel, and

- * The operators are trained and experienced in removing / pulling j fuse . Based upon the above conditions, discussions with NRR 1 representativqs, and the previous acceptance of removing / pulling fuses to achieve and maintain hot shutdown at other nuclear pov.'er i plants, the licensee's control of the pressurizer PORV interface was found to be satisfactor Therefore, the pressurizer PORV section of this open item is ,

considered close '

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t The normal and excess letdown interface paths include the following valves:

UNIT NORMAL LETDOWN VALVES EXCESS LET00WN VALVES I CV-31325 CV-31330 l CV-31326 CV-31210 CV-31327 CV-31399 II CV-31347 CV-31422 CV-31348 CV-31222

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CV-31349 CV-31430 These valves are air operated globe valves that fail to the close position in the event of a loss of ai The interfaces are controlled by removing air from the valves to fail the valves close Procedure FS, Appendix B, Control Room Evacuation (Fire) Safe Shutdown Procedure, Revision 4, Paragraph 4.1.1 and 4.1.2 provide instructions for deenergizing the instrument air compressors and opening the air receiver drain valves to fail instrument ai The remaining normal and excess letdown interface sections of this open item are also considered close Therefore, this item is considered closed, f 1. (Closed) Unresolved Item (282/87004-09; 306/87004-09): Current '

Transformer Open Circuit Secondaries. It was determined that the licensee had not prepared an analysis of this concern, however, the ,

licensee's staff contended that no specific transmittals between the "

NRC and the licensee identifying current transformer open circuit secondary details had occurred. The inspectors acknowledged the licensee's contentio During May 1988, discussions were conducted with NRR representatives to determine if current transformer open secondary circuits :

presented an Appendix R associated circuit spurious signal concer The NRR Power Systems Branch determined that current transformer open secondary circuits were not an Appendix R spurious signal concer Therefore, this item is considered close j. (Closed) Violation (282/87004-10; 306/87004-10): During a review of

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the remote transfer switch isolation circuitry for the 01 DG and Hot i Shutdown Panels A and B, it was identified that the isolation !

switches, presently installed at Prairie Island, do not provide

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i redundant fusing of 125 VDC control powe This lack of redundant fusing may result in a loss of 125 VOC control power at the panels in the event of a control room fir Such an occurrence would ;

require troubleshooting and needed repairs in the form of '

fuse replacement to achieve hot shutdow During this inspection, a review of Modification No. 86L927, redundant fusing for Appendix R required equipment, showed that the licensee installed redundant fusing and associated wiring to protect the operability of hot shutdown system component This '

modification ensures that there is redundant fusing or appropriate ;

wiring so that if the "main" fuses should blow before the operators can reach the hot shutdown panel, the components will be operable when their switches are placed in "local." Once the hot shutdown panel switches are placed in "local", the components are electrically isolated from any further damage due to a control room fire. The modification included circuitry for the D1 DG and Hot Shutdown Panels A and Therefore, this item is considered closed, k. (Closed) Open Item (282/87004-11; 306/87004-11): The handheld radio system is the designated means of communication during alternate ;

shutdown. During the walk down of the licensee's Control Room Evacuation Procedure, communication difficulties were observed including crosstalk and interference, gerator confusion in selection of channels, and the radios did not appear capable of transmission between plant locations as require The licensee's corrective action included reducing the number of ,

channels used, moving the plant repeater into the Auxiliary Building, '

testing the communication adequacy in all required locations for alternate shutdown, and providing operator training in the use of ,

the handheld radios under emergency conditions. Therefore, this item is considered closed, i. (0 pen) Violation (282/87004-12; 306/87004-12): Eight hour emergency lighting was not provided for access and egress routes to the OG Room No I and inside the Turbine Building operator shac The inspectors were provided Work Request Log No. M4675-FP showing [

that the safe shutdown emergency light verification Surveillance Procedure No. SP 1755. Revision 0, was conda:ted to verify that sufficient emergency lighting units were available to perform appropriate shutdown procedures. This procedure covered the routes to the DG Room No. I and inside the Turbine Building operator shack. As part of the performance of this surveillance procedure,

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AC lighting in selected plant areas were also shutoff to determine the adequacy of the installed eight hour emergency lightin l

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Three plant locations; (1) the Auxiliary Building, 735' elevation, !

2MS-27-1, 27. Loop A MSIV Accumulator Vent Valve, (2) the screenhouse basement at the diesel fire pump, and (3) the fire pump strainer room in the screenhouse were identified by the licensee as '

being in need of additional lighting. Until this additional  !

lighting is installed, the licensee has placed handheld lights in the th ee locations to be used by operators to improve the lighting illumination levels. A walkdown of this procedure was conducted on

. July 19, 1988, by members of the licensee's staff and by an NRC inspector. This inspector confirmed that additional emergency lighting units have been provided in access and egress routes to the DG Room No. 1 and in the Turbine Building operators shack. Yet, this item will remain open until the additional lighting units are permanently installed and /or relocated as appropriate. The licensee has scheduled this work to be completed by October 1, 1988.

r i m. (Closed) Unresolved Item (282/87004-13; 306/87004-13): Emergency lighting appeared tc be inadequate for the Unit 1 Plant Equipment and Reactor Operator to perform the procedural steps safely and efficiently in the Unit 1 DG Room, Fire Area 25, elevation 695'. '

By licensee letter dated May 5, 1987, additional emergency lighting units would be installed in this room by July 1, 1987. On July 19, 1988, an inspector accompanied by licensee staff verified that additional lighting units have been installed in this room. As discussed in the previous item, this type of emergency lighting deficiency was previously categorized as a violation for lacking '

adequate lighting units. Since the licensee has taken adequate ;

corrective action, this item is considered close ,

In addition, the licensee provided the inspector with the Emergency Lighting Eighteen Month Surveillance Procedure No. 1708, Revision 2, i

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dated October 16, 1987. The purpose of this procedure is to ft.actionally test the operation of the emergency lighting for ei0ht hours availability, and to clean and verify direction of the lamp An inspector determined this procedure to be satisfactory and no other discrepancies were identifie *

l n. (0 pen) Open Item (282/87004-14; 306/8700d-14): Examples were identified where the as-built plant configuration was not accurately described in Section F5 af the Operations Manua '

During this inspection, the inspectors confirmed that those specific discrepancies have been corrected. However, during this inspection examples were found showing that the Fire Hazards Analysis (FHA),

Table 6-2, conflicted with the detailed FHA description and to the cross reference Fire Area to Appendix R requirement letter dated June 30, 1988. Specifically, eight fire areas were shown in Table 6-2 to have shutdown equipment / cabling located in those areas '

while the other documents showed no shutdown equipment / cabling existed in those areas.

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In addition, while reviewing isolation ar.d protection for spurious signals, the licensee's listing of safe shutdown equipment,

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Table 4-1, was found to be missing valves which are believed

by the inspectors to be required for post-fire safe shutdown. This equipment in:luded the Volume Control Tank (VCT) Outlet Valve N /2-LCV-1128, and the Safety Injection Suctio') Valves Nos. MV-32163 r and MV-3219 Therefore, this item will remain open pending a complete re-review

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of the fire protection /!,afe shutdown documents including a review of-

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the shutdown equipment list to ensure the minimum shutdown equipment '

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o. (Closed) Open Item (282/87004-15a; 306/87004-15a): During the .

witnessing of fire detector calibration testing for Fire Detection Zone (FDZ) 83, it was observed that all six fire detectors were out of calibration to the non-conservative sensitivity range. Further it was learned that certain A-Train diesel cooling water oil transfer pump cabling is routed through F0Z 83 which is required for safe shutdow Based'on the importance of the area to safe shutdown

, and the results of the fire detector _ calibration test, the inspectors requested the licensee to consider increasing the frequency of the I&C Periodic Maintenance Test until the results of the test demonstrate calibration of the zone detectors within an i q acceptable rang l During this inspection, the inspectors were provided Surveillance Procedure 1189, Revision 5, dated September 29, 1987, which now  !

l provides for a semi-annual test of one half of the fire detectors i

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located in F0Z 8 In addition, the inspectors were provided a copy of the Master

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Instrument List dated June 7, 1988, which incorporated FDZ 83 (U1 Ground Floor 480V Switchgear Room). This list showed the

frequency of inspection for the fire detectors located in this zone to be on a triennial basis. According to the licensee, this

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frequency has been increased from the previous five year frequenc Based on the above, this item is considered closed, p. (0 pen) Open Item (282/87004-15b; 306/87004-15b): F0Z 83 was not l listed in the Technical Specification (TS) Fire Detection  :

Instrumentation Section while the A-Train Diesel Cooling Water Oil l

, Transfer Pump cabling which is required for safe shutdown is routed through this zone.

In addition, during this inspection it appeared that two additional  !

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FDZ's (No. 4 and No. 37) need to also be incorporated into TS since ,

shutdown cabling is also routed through thera zone '

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This item will remain open pending licensee submittal of a TS change !

I for these three locations. According to licensee management, this submittal is scheduled to be submitted by September 30, 198 ,

' Common Enclosure The common enclosure associated circuit concern is found when redundant circuits are routed together in a raceway or enclosure or non-safety related cables are routed together in a raceway or enclosure with redundant safe shutdown cables and the non-safety related cables are not electrically protecte ,

During the inspection cable routing for the following redundant safe shutdown components were reviewed for common enclosure routing: }

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CV-31231 CV-31232 CV-31233 CV-31234 MV-32195 MV-32196 MV-32197 MV-32198 MV-32080 MV-32163 MV-32183 MV-32191

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The licensee's protection for the common enclosure as:ociated circuit

] concern was found to be satisfactory for the above component . Fire Brigade Trainina l

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On July 21, 1988, an inspector witnessed a portion of the licensee's annual fire brigade training session held offsite. The inspector witnessed two live firegroi3d training firefighting evolutions involving i an internal structural firs (smokehouse) and a transformer fir l These training evolutions denieted the types of fires which eculd be l expected to potentially occw at the plant. The inspector concluded that this type of training met NRC requirements committed to by the licensee I

and emphasized the importance of critique discussions following each training activit In addition, the inspector encouraged the use of all '

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i firefighting equipment during the quarterly fire brigade training including self-contained breathing apparatus for maintaining the fire .

brigade's readiness to use this equipment when neede ! HousekeepinJ  !

On July 19-21, 1980, during walkthroughs of certain plant areas within I the Screennouse, Turbine and Auxiliary Buildings, the inspectors !

determined that these plant areas were being maintained in a satisfactory j conditio ,

, Open Item  !

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Open items are matters which have been discussed with the licensee, which :

1 will be reviewed further by the inspector, or which involve some action j j on the part of the NRC or licensee or bot Open items disclosed during

the previous Appendix R inspection and which remain open are discussed in )

j Paragraph 2 of tnis repor L

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Exit Interview 1 ^l n

The in:pectors met with licensee representatives (denoted in Paragraph 1) l at the conclusion of the inspection on July 22, 1988, and summarized the i scope and findings of the-inspection. The inspectors also discussed the likely informational content of the inspection report with regard to  :

documents reviewed by the it.spectors during the inspectio The licensee  !

did not identify any of the documents as proprietary, j

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