ML20199C425

Responds to NRC Re Violations Noted in Insp Repts 50-282/97-12 & 50-306/97-12.Corrective Actions:Facility Developed Administrative Work instruction,5AWI 3.13.1, Fire Protection Review of Plant Mods

ML20199C425
Person / Time
Site:	Prairie Island
Issue date:	11/13/1997
From:	Sorensen J NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-282-97-12, 50-306-97-12, NUDOCS 9711200012
Download: ML20199C425 (9)

Text

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i MI Northern States Power Company 1

,, Pralrle Island Nuclear Generating Plant 1717 Wakonado Dr. East Welch. Minnesota $5089 November 13,1997 10 CFR Part 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50 282 License Nos. DPR-42 50-306 DPR-60 Reply to Notice of Victation (Inspection Report 97012),

Deficiencies 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.

l in addition, you requested responses to twc Unresolved items. These responses i immediately follow.

URI 97012-01 Hot Shorts with Valve Damage:

1 As indicated in the inspection mport, we willperform additional reviews 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 <

those MOVs. Information Notice 92-18 will be used for guidance in these additionalreviews. i URI 97012-08 Fire Brigade Drill Requirements:

We are in the process of reviewing all of the commitments made relating to tho l Fire Protection Program. After this review is completed the commitments will be '

assessed against practices allowed by our administrative procedures and any discrepancies between our fire brigade drill commitments and procedures will be t corrected. .

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9711200012 971113 PDR ADOCK 05000282

,(r O pon g

USNRC NORTHERN STATES POWER COMPANY November 13,1C97.

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In this letter and attached response we have made new Nuclear Regulatory Commission commitments, these are indicated by italics.

Please contact Jack Levellie (612-388-1121, Ext. 4662) if you have any questions related to this letter.

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oel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region lil, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg

Attachment:

RESPONSE TO NOTICE OF VIOLATION IR97012. DOC

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.. RESPONSE TO NOTICE OF VIOLATION l VIOLATION 1 10 CFR 50.71(e) required that revised portions of the Final Safety Analysis Report (FSAR) be submitted to the NRC.

Contrary to the above, on July 1,- 1994, substantial revisions were made to the Fire Hazards Analysis (FHA) (referenced as a portion of the FSAR) that were not submitted to the NRC.

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

Resoonse to Violation 1

- Reason for the Violation 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 Append!x 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 Preventative Practices," 5AWI 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 evaluate and make required changes. The documents identified above use the FHA and USAR in separate text and use separate processes for making changes to each.

Prior to this NRC 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 Piotection Review of Plant Modifications," that implemented .

requirements for reviews of modifications that may impact the Fire 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 88-10 requires all changes to the approved program be reported

- annually to NRR along with FSAR revisions. A major revision to the FHA could be

Attaennc.

Ngygmber 13,1997 Page 2 considered a program change; however, all that was done was to update the fire

' loading portion of the FHA and to identify the more conservative methodology used to complete this update.

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 1998.

Action to Be Taken to Prevent Recurrerice A procedure change request was submitted for SAWI 4.1.0, Plant 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

, to the NRC.

. Date When Full Comoliance Will Be Achieved The Praide Island Fire Hazards Analysis will be submitted with the first USAR submittal of 1998.

d IR97012. DOC

Attachment November 13.1997 Page 3 VIOLATION 2.a Prairie Island Technical Specification 6.5.A.7 required that detailed written implementing procedures be prepared and followed for the fire protection program.

a. Administrative Work Instruction 5AW13.13.0, " Fire Preventive Practices,"

Paragraph 6.9.6, stated: " Individual Fire Brigade members SHALL actively participate in at least one drill 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."

i Corrective Actions Taken l i-ollowing the identification of this issue by the inspector we removed from Fire Brigade l duty those individuals that had not participated as a member of the fire brigade at the l

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 drill scene. Following this participation these individuals were returned to active Fire Bngade status, it should be noted that these individuals had all participated in hands-on fire brigade training, during l the preceding 12 months, which includes full suit-up and full participation in fire fighting I scenarios. l Corrective Actions to Prevent Recurrence j 1

We will change our administrative requirements to identify that A.CTIVE participation in 1 a Fire Drill willrequire fire brigade members to respond to the location of the simulated fire in fullprotective equipment and willinvolve participation in fire brigade activities to extinguish er'd prevent the spread of fires simulated for the drill. We will develop a

\ program to track this ddllparticipation and fire brigade qualifications willrequire this active participation in drills. The program will be in place by March 1,1998.

Date When Full Comoliance Will Be Achieved Full compliance has been achieved. '

l 1R97012. DOC

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I Attachment l November 13.1997  ;

Page 4 l 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 SAWI 3.4.0, *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 Leve! IV violation (Supplement 1).

Resoonse to Violation 2.b Reason for the Violation The inspection repost states:

The inspector identified that detector surveillance data documented during SP 1189, " Safety Related Fire Detector Check," Revision 16, was not available 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 Administrativo Work Instruction, 5AWI 1.5.0, 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 SAWii.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, initialed steps and no data, dates or signatures.

The discarded pages of SP-1189 contained only routine, initialed steps and did not contain dates or signatures. We have questioned whether these routine, initialed steps constitute " data" or provide " significant value in demonstrating capabi!ity for safe operation of a safety related or fire protection related item." We have discovered that we have an internal 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 IR91012. DOC

• Attachment November 13,1997 Page5 acknowledge the violation but have not determined that it extends beyond this particular

' procedure.

Corrective Actions Taken 6 The discarded surveillance pages have not caused us to doubt the operability of the fire detectors. The cover sheet, which is maintained:

e documents completion of the test by the signature of the performer (along with the date and time),

e acceptability of the test results, documented by the signature of the fire protection administrator, e documents, by signature, the system engineer review of the test for completeness e documents necessary corrective maintenance by referring to work orders generated in addition,-any pages with deviations are maintained with the coversheet. Because revisions of surveillance procedures are maintained, it is possible to recover the specifics that were addressed by past surveillances of the fire detectors.

The information is available from the preserved documentation to make appropriate safety, operability, or reportability determinations. We, therefore, believe that no repeated surveillance is deemed necessary.

Corrective Actions Regarding Fire Protection Data Retention We will revise SP-1189 to require the retention of allpages that contain any documentation ofperformance (priorto 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-revise the retention practice for SP-1189 as a result of that determination.

Corrective Actions to Preclude Recurrence 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.

IR97013.COC

. Attachment November 13,1997 Page 6

VIOLATION 2, c Prairie Island Technical Specification 6.5.A.7 required that detailed written implementing procedures be prepared and followed for the fire protection program.

c. Surveillance Procedure (SP) 1192, " Safeguards Electrical and Mechanical Penetrations Surveillance Inspection," Revision 7, requires the verification of penetration seal operability through visual inspection.

Contrary to the above, on April 4,1997, SP 1192 was not followed in that 8 penetrations were not verified to be operable.

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

Resoonse 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. lt directs the inspector to plact checkmarks by the individual penetrations on the sketches; this is to keep track of thein 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 checkmarks 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.

Actionig Preclude Recurrence Ths surveillance procedure has been submitted to the Enor Reduction Task Force (ERTF) for a Human Factors review and will be modified following this review based on IR970kJ. DOC-

, Attachment November 13,1997 Page 7 the tecorninendatiuhs 6f thd ERTF, Through improvementa in the human perfo_rmance

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

_ properly determine if all penetrations were inspected will be enh6nced.

Date When Full Comoliance Will Be Achieved Full compliance has been ach!eved.

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