IR 05000282/1996016

Insp Repts 50-282/96-16 & 50-306/96-16 on 961120-970107.No Violations Noted.Major Areas Inspected:Aspects of Licensee Operations,Maintenance,Engineering & Plant Support Performed by Resident Inspectors

ML20134H232
Person / Time
Site:	Prairie Island
Issue date:	01/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20134H217	List: IR 05000282/1996016 ML20134H216
References
50-282-96-16, 50-306-96-16, NUDOCS 9702110215
Download: ML20134H232 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION 111 Docket Nos: 50-282. 50-306 License Nos: DPR-42. DPR-60 Report No: 50-282/96016. 50-306/96016

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Licensee: Northern States Power Company Facility: Prairie Island Nuclear Generaliag Plant

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Location: 1717 Wakonade Drive East Welch. MN 55089 Dates: November 20. 1996 - January 7, 1997 Inspectors: S. Ray. Senior Resident inspector J. Lara. Resident Inspector Monticello E. Plettner. Reactor Engineer A. Stone. Senior Resident Inspection. Monticello

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Approved by: J. Jacobson, Chief Reactor Projects Branch 4 i

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9702110215 DR 970128  !

ADOCK 05000282 l PDR

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EXECUTIVE SUMMARY Prairie Island fluclear Generating Plant. Units 1 & 2

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i4RC Inspection Report 50-282/96016. 50-306/96016

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This inspection included aspects of licensee operations. maintenance, engineering, and plant support performed by the resident inspector Doerations

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The inspectors observed that the conduct of routine plant operations was generally acceptable. Operators were attentive and knowledgeable of plant conditions. Shift turnover meetings were thorough but concise. .

Prejob briefings were usually good. (Section 01.1)

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Failure of a system engineer and two licensed operators to adequately self-ched when specifying a return to service valve position resulted in an inadvertent dilution of the reactor coolant syste (Section 01.2)

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Operators were observant of plant conditions and detected the inadvertent dilution in a timely manner (Section 01.2)

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The inspectors found examples of administrative weaknesses iri the control of temporary instruction (Section 03.1) i Maintenance  !

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Inspector observed maintenance and surveillance activities were well ,

conducted with good communications, proper pre-job planning. safe work I practices. and excellent coordination between department (Section M1.1) l

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Failure of an operator to adequately self-check before closing a valve resulted in an unanticipated auto-start of an component cooling water i pum (Section M1.2)

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The inspectors found numerous examples of surveillance procedures which '

did not conform to the licensee's writer's guide. (Section M3.1)

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The inspectors identified that a Licensee Event Report was missing some required information regarding a previous similar event. (Section M8.1)

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Failure to adequately self-check on the part of several licensee personriel resulted in a required surveillance test being misse (Section M8.2)

Engineerina

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The inspectors identified that the licensee's safety evaluation of a problems with the emergency intake line was inadequate in that it didn't review the seismic capability of the sluice gates. (Section El.1)

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The licensee reported that the spent fuel storage racks were outside the design basis due to Boraflex degradation. (Section E8.1)

. Plant Support

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The licensee reported that an individual's security access should have .

been revoked following a determination of questionable fitness for dut (Section S8.1)

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Report Details Summary of Plant Status

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Both units operated at or near full power for the entire inspection period except for brief power reductions for various testing and maintenance activities. On January 7. 1997. Unit 2 reached the "all control rods fully withdrawn" condition and began a gradual power coastdown toward a refueling outag During this inspection period the sixth dry cask was loaded with spent fuel and was being 3repared for transport to the Independent Spent Fuel Storage Installation at t1e end of the inspectio _

I. Operations 01 Conduct of Operations 01.1 General Comments Inspection Scope (71707)

Using Inspection Procedure 71707. the inspectors conducted frequent .

reviews of plant operations. These reviews included observations of control room evolutions, shift turnovers operability decisions, logkeeping, etc. Updated Safety Analysis Report (USAR) Section 13 !

" Plant Operations." was reviewed as part of the inspectio ! Observations and Findings The inspectors noted that control room operators were attentive to their panels and knowledgeable of plant conditions and activities in progres Communications were consistently clear. Shif t turnover briefings were thorough but concise. Prejob briefings for infrequent or complex evolutions were excellen Conclusions The inspectors observed that the conduct of routine plant operations was generally acceptable. A problem with an inadvertent boron dilution of the reactor coolant system is discussed in the next section and a problem with operators performing a surveillance activity is discussed in Section M1.2 of this repor .2 Inadvertent Boron Dilution of the Reactor Coolant System Inspection Scope (92901)

On December 31. 1997, the licensee experienced an inadvertent boron dilution of the reactor coolant system while operating Unit 1 at full powe The inspectors conducted a followup inspection of the even ,

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The inspectors reviewed USAR Sections 10.2.3. " Chemical and Volume Control System." and 14.4.4. " Chemical and Volume Control System Malfunctiva." as part of this inspectio .

b. Observations and findinos . .

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lhe licensee was in the process of restoring the letdown purification system lineup after completing valve work under work order (WO) 961485 The system engineer listed the incorrect restoration position (open) for l

valve VC-11-48. " Letdown Line to 11 & 12 Deboration Demin." The valve i was normally closed except when deborating the reactor coolant syste The lead reactor operator and shift supervisor who approved the restoration failed to notice the incorrectly specified posi. tion.

Before conducting the restoration procedure, a prejob briefing was held

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in the control room. Operators discussed that they would expect to see l l some dilution when the procedure was performed because the mixed bed i demineralizer had cooled down and would be more efficient at removing l boron until it heated up. When the restoration was completed reactor l

power began to increase as expected and the operators added boric acid to compensate. However, after about an hour, it became apparent that -

l more dilution than was expected was occurrin l l

In addition to restoring normal letdown flow through the mixed bed demineralizer, the fact that VC-11-48 was incorrectly opened allowed a l parallel flow path through the deborating demineralizers. After about another hour the operators determined the cause for the dilution and corrected the lineu During the entire time, control room operators closely monitored plant conditions and added boric acid as necessary to compensate for the dilution. Reactor power increased slightly due to the dilution. The inspectors verified that peak thermal power during the shift had not exceeded 100.6% and that the average power for the shift was less than 100% of rated thermal powe The inspectors reviewed licensee Technical Specification Interpretation LIC-1. "100% Full Power Operation."

Revision 1. and determined that thermal power had been maintained within management expectations.

l The licensee issued a employee observation report to document the event and the general superintendent operations ordered an investigation by i the Error Reduction Task Force to determine the cause and recommend corrective actions. This avent is considered an Unresolved Item pending l further NRC review of the cause and safety significance. (282/96016-01) '

c. Conclusions During this event operators were closely monitoring plant conditions and maintaining reactor thermal power within licensee guideline Recognition and correction of the incorrect valve alignment was considered timely. However, a system engineer and two licensed operators failed to notice that the incorrect valve position had been

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specified on the restoration lineup. This is an example of inadequate self-checking similar to others discussed later in this repor . 03 Operations Procedures and Documentation 03.1 Temocrary Instructions a. Inspection Scope (92901)

The inspectors reviewed the licensee's program for the control of temporary operational information. Included in the inspection was a review of all outstanding temporary instructions in the Master .

Operations Noteboo '

b. Observations and Findinas Operations Section Work Instruction SW1 0-19. " Control of Supplemental Information," Revision 23. contained the requirements for maintaining temporary instructions. Section 6.1.3 of SWI 0-19 stated. " Temporary instructions SHALL NOT be used in place of procedural guidance " The

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inspectors identified two temporary instructions, numbers 96-72 and 96-105, that appeared to be of a permanent nature and should have been issued as changes to existing plant procedures or as new procedures rather than temporary instruction Section 6.1.5 of the SW1 0-19 stated. " Temporary instructions SHALL be reviewed by the Shift Manager on a monthly cycle to verify the validit)

and need for each one. Instructions which are obsolete or no longer  :

necessary SHALL be withdrawn from the Master Operations Notebook and  !

placed in a historical file for future reference." The inspectors noted that there was no documentation to verify that the monthly review was being accomplishe The inspectors identified one temporary instruction. number 96-81, that was no longer necessary by plant conditions but was still active in the log.

! c. Conclusions SWI 0-19 was not a procedure required to be followed by Technical Specification 6.5. " Plant Operating Procedures." nor were the temporary instructions considered " activities affecting quality" in accordance with 10 CFR 50. Appendix B. Criterion Thus this failure to follow l the section work instruction was not considered a violation of  !

regulatory requirements. However, the inspectors noted administrative '

weaknesses in the control of supplemental information as discussed abov The weaknesses were discussed with licensee management and appropriate corrective actions were initiate l

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II. Maintenance M1 Conduct of Maintenance

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M General Comments . .

a. Inspection Scope (61726. 62707)

The inspectors observed all or portions of the following maintenance and surveillance activities. Included in the ins]ection was a review of the surveillance procedures (SP) or worc orders (WO) listed as well as the appropriate Updated Safety Analysis Report (USAR) sections regarding the activitie .

. SP 1035B Reactor Protection Logic Test at Power - Train Revision 22

. SP 1089 Residual Heat Removal Pumps and Suction Valves from the Refueling Water Storage Tank. Revision 43

. SP 1106C 121 Cooling Water Pump Test Revision 8

• SP 1528 Backflush of Emergency Bay Intake Pipe. Revision 19

. SP 2035 Reactor Protection Logic - Train A. Revision 26

. SP 2093 D5 Diesel Generator Slow Start Test. Revision 63

. SP 2219 Monthly 4KV Bus 26 Undervoltage Relay Tes Psevision 25

. SP 2305 D6 Diesel Generator Slow Start Test. Revision 8

. WO 9406976 Wire Code Changes at Fan Motors

. WO 9611746 Test Imp In Control System 1EH

. WO 9612115 #11 CC Pump Autostart Pressure Switch Calibration

. WO 9612116 #12 CC Pump Autostart Pressure Switch Calibration

. WO 9612834 Intermediate Block Relay Repair c. Conclusions Inspector observed maintenance and surveillance activities were well conducted with good communications, proper pre-job planning. safe work practices, and coordination between departments. The inspectors noted system engineer involvement in all phases of maintenance and surveillance activitie M1.2 Operator Frror Durina Surveillance Test a. Inspection Scope (92902)

On December 5. 1996, while performing post maintenance testing on Unit 2 residual heat removal (RHR) pump #22 an operator error caused an unanticipated start of Unit 2 component cooling (CC) water pump #2 The inspectors reviewed the circumstances of the event. The inspectors also reviewed USAR Section 6.2. " Safety Injection System." as part of the inspectio .- - -_ -- - . - - -

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. Observations and Findings The licensee was performing surveillance procedure (SP) 2089. " Residual

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Heat Removal Pumps and Suction Valves From the Refueling Water Storage Tank." Revision 47. when the operator incorrectly closed the component - !

cooling (CC) heat exchanger cross connect valve. MV-32122. Closing of the valve resulted in an auto start of the #21 CC water pum The instructions contained in step 7.3.21 of SP 2089 were. " Return CC pumps to normal as directed by Shift Supervisor. JF stopping a CC pum THEN record CC Pump No. AND Stop Time." The procedure does NOT contain :

_ instructions to secure the CC heat exchanger inlet valve. MV-32160, after the CC pump has been secured but that is a normal operator actio The operator attempted to close valve MV-32160 but inadvertently closed MV-32122 instead. The control switches for the two valves were in close proximity and had similar name ,

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I The licensee determined the cause of the event was primarily the failure of the operator to adequately self-check to verify that he was operating the correct valve. A contributing cause was that procedure 2089 did not ;

contain detailed steps for securing the CC pump after the test. The {

licensee has completed an Error Reduction Task Force investigation of the event and was addressing those deficiencie ! Conclusions The failure of the operator to adequately self-check the valve l manipulation was another example of similar failures discussed elsewhere is this repor The licensee has initiated corrective actions in response to a recent cited violation in this are The failure to have an adequate procedure was considered a violation of Technical Specification 6.5.A.4 which required that detailed written procedures for surveillance and testing which could affect nuclear safety be prepared and followed. The licensee has implemented a corrective action to review and correct all of the procedures that contain CC pump action statement Although it was an unnecessary challenge to a safety system, the event was not safety significant. All equipment performed as expected. This licensee-identified violation is being treated as a Non-Cited Violation, consistent with Section Vll.B.1 of the NRC Enforcement Polic (306/96016-02)

The Licensee Event Report for this event is discussed in Section M8.1 of this repor i

. M3 Maintenance Procedures and Documentation M3.1 Review of Surveillance Procedures

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, a. Inspection Scope (92902)

In addition to reviewing the surveillance procedures (SPs) 1isted in Section M1.1 of this report, the inspectors conducted an in-office review of the following SPs:

. SP 1054 Turbine Stop. Governor and Intercept Valve Tes Revision 16 .

. SP 1090 Containment Spray Pump and Spray Additive Valve Tes ~

Revision 46

. SP 2103 22 Turbine-Driven Auxiliary Feedwater Pump Once Every Refueling Shutdown. Revision 27

. SP 2143 Feedwater Isol And FW Pump Trip Verificatio Revision 9

. SP 2250 Test of the Reactor Trip Breakers Using the Main Control Board Switches. Revision 9 b. Observations and Findings The inspectors noted that all of the SP procedures revie<ied had deficiencies when compared to the standards prescribed in the licensee procedures H14. " Procedure Writer's Guide." Revision and H14.4. " Surveillance & Periodic Test Procedure Guideline."

Revision 6. Examples of the deficiencies included the following:

. Notes in procedure steps that should have been in the Prerequisites section

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Notes that contained action requirements that should have been steps in the procedure

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Notes that should have been cautions

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Lack of place keeping aids to help track completed steps Lack of expected parameters to assist personnel an identifying possible degraded conditions l

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Insufficient information to successfully complete the task without assistance from other more experienced personnel

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insufficient space for data entries required by the procedure

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Lack of required information in Personnel and Special Equipment j Requirements section

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Inconsistencies in capitalization, punctuation. bolding, and other format errors The inspectors discussed the procedural weaknesses with licensee management and provided example c. Conclusions l

All of the surveillance procedures that failed to meet licensee's procedure writing guidance had been reviewed by the Operations Committee

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and approved by a member of licensee managemen The large number of weaknesses observed indicated a significant lack of attention to the format of the procedure idthough the 1rocedures could be performed as

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written, the inspectors were concerned tlat surveillance procedures in and incorrect format could lead to operator ecror .

The writer's guide was not a procedure required to be followed by Technical Specification 6.5. " Plant Operating Procedures." Thus the failure to write surveillance procedures in the correct format was not considered a violation of regulatory requirements. However, the inspectors noted weaknesses in the licensee's administrative control and review program as discussed abov M8 Miscellaneous Maintenance Issues (92700, 92902)

M (0 pen) Licensee Event Report (LER) 306/96-03: Auto-start of 21 Component Cooling Water Pump due to Personnel Error. This event was discussed in Section M1.2 of this report and was considered a Non-Cited Violatio While reviewing the LER the inspectors noted that " Previous Similar -

Events" section did not reference LER 282(306)/96-16. " Auto-start of No. 11 Component Cooling Water Pump Due to Personnel Error." which reported a very similar recent event. The inspectors discussed the missing reference with the licensing engineer who stated that it was an oversigh CFR 50.73. Section (b)(5), required that the LER content shall reference any previous similar events at the same plant that are known to the licensee, Failure to include LER 282(306)/96-16 as a previous similar event in LER 306/96-03 was a violation. This failure constitutes a violation of minor significance and is being treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy. (306/96016-03) l

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The LER remains open pending the completion of the corrective actions discussed therei M3.2 (0 pen) Licensee Event Report 306/96-04: Failure to Perform SP-2244, Cycling of Unit 2 Containment Air Sample Valves. This event occurred on April 20, 1996. because operators had inadvertently pulled surveillance procedure SP-2242. " Cycling of Unit 2 Sampling System Valves." from the files to perform instead of the scheduled SP-2244. " Cycling of Unit 2 Containment Air Sample Valves." Thus a quarterly surveillance required !

by Technical Specification 4.2.A and ASME Section XI was not performed l for one quarte The licensee discovered the error during a system engineer review of the completed surveillance on December 5, 1996. By that time. SP-2244 had been performed successfully twice in the next two quarters after April 1996. so it was probable that it would have been successful had it been performed on April 20. Thus the event was not considered safety

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. significan In addition. the licensee has not had a reportable event '

involving inadvertently performing the wrong surveillance since 1989 so the event was considered an isolated cas The licensee completed an e

Error Reduction Task Force investigation of this event and has initiated corrective actions for this and other similar events. This licensee-identified violation is being treated as a Non-Cited Violatio consistent with Section VII.B.1 of the NRC Enforcement Polic (306/96016-04)

However. licensed operators failed to notice that the wrong surveillance procedure was being performed both when the procedure was pulled from the files and while it was reviewed upon completion. This is another example of inadecuate self-checking similar to the events discussed in Sections-01.2 anc M1.2 of this report and other recent events referred to in the cover letter for this report. In addition, over seven months elapsed between completion of the surveillance test and the system engineer's review which identified the error. The inspectors discussed this issue with engineering management personnel who stated that the expectation was that successful curveillance tests would be reviewed within one month. That ex)ectation was reinforced with the system engineers as a result of tais even The LER remains open pending completion of the corrective actions discussed therei III. Engineerina El Conduct of Engineering E1.1 Emergency Intake Line Declared Inonerable Inspection Scope (92903)

On November 22 1996, the inspectors attended an Enforcement Conference between the licensee and NRC associated with Inspection Report 282(306)/96015. The purpose of the conference was to discuss an apparent unreviewed safety question regarding the cooling water emergency intake lin Observations and Findinas During the conference, the inspectors questioned the seismic adequacy of the sluice gates between the circulating water bay and the cooling water ba Because of the inability of the emergency intake line to the cooling water bay to pass design flow, the. licensee had completed Safety Evaluation (SE) 427. Revision 1. which took credit for cooling water suction through the sluice gates for a period of time until the cooling water demand could be reduced to within the capacity of the emergency

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intake line.

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The emergency intake line wr: designed to remain operable after a seismic event, but it was r clear that the sluice gates were. As a result of the NRC question, the licensee determined that there was no

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evidence that the sluice gates had been designed to be seismically quali fied. The ]icensee. declared the emergency intake line to be inoperable until seismic calculations could be complete On November 26, 1996. the calculations were completed and the sluice gates were determined to be able to remain open after a seismic event.

j The emergency intake line was then declared operabl c. Conclusions Licensee engineering personnel failed to consider the seismic adequacy ~

] of the sluice gates when they completed the SE which took credit for

water flow through the gates after a seismic event. This issue will be

evaluated as ) art of the assessment of the information provided by the licensee in tle Enforcement Conferenc E2 Engineering Support of Facilities and Equipment

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E2.1 Review of Undated Safety Analysis Report (USAR) Commitments (37551)

While performing the inspections discussed in this report. the inspectors reviewed the applicable portions of the USAR that related to l

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the areas inspected and used the USAR as an engineering / technical

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support basis document. The inspectors compared plant practice procedures, and/or parameters to the USAR descriptions as discussed in each section. No new discrepancies were identified.

, E8 Miscellaneous Engineering Issues (92700)

E (0 pen) Licensee Event Report (LER) 282(306)/96-19: Spent Fuel Storage Racks Outside Design Basis due to Boraflex Degradation. The licensee

' reported this event to the NRC via the Emergency Notification System on November 27. 1996, and issued the LER as a followup report on December 20. 199 The NRC has been evaluating Boraflex degradation for some time as discussed in Generic Letter 96-04. "Boraflex Degradation in Spent Fuel

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Storage Racks." The licensee submitted a license amendment request on July 28, 1995. as the lead )lant for a proposed Westinghouse methodology

to take credit for soluble acron in the spent fuel pool rather than Boraflex. In the interim administrative controls on the spent fuel

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pool boron concentration were implemented as discussed in the LE The LER will remain open pending further NRC review of the licensee amendment request and responses to Generic Letter 96-0 .

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IV. Plant Support

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R1 Radiological Protection and Chemistry Controls (71750) -

During normal resident inspection activities, routine observations were conducted in the areas of radiological protection and chemistry controls using Inspection Procedure 71750, No discrepancies were note Conduct of Emergency Preparedness Activities (71750)

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During normal resident inspection activities, routine observations were

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conducted in the area of emergency preparedness using Inspection Procedure 71750. No discrepancies were note S1 Conduct of Security and Safeguards Activities (71750)

During normal resident inspection activities, routine observations were conducted in the areas of security and safeguards activities using Inspection Procedure 7175 No discrepancies were note S8 Miscellaneous Security and Safeguards Issues (92700)

5 (Ocen) 1.icensee Event Report (IER) 282(306)/96-20: An Individual's Security Access Should Have Been Revoked Following Determination of Questionable Fitness. This LER was issued on January 8. 1997, for the i licensee's discovery on December 9. 1996, that an employee not assigned to the plant, but who occasionally performed work at the plant, should have had their access suspended in August 1996 when the employee's fitness for duty was questione The error was a result of the issue being handled through the company's employee assistance program but not through the fitness for duty progra This LER remains open pending a review by an NRC regional security specialis F1 Control of Fire Protection Activities (71750)

During normal resident inspection activities, routine observations were conducted in the area of fire protection activities using Inspection Procedure 7175 No discrepancies were note ,

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V. Management Meetinos l X1 Exit Meeting Summary l . .The inspectors presented the inspection results to members of the licensee

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management at the conclusion of the inspection on January 9.1997 The i licensee acknowledged the findings presented.

l The inspectors asked the licensee whether any materials examined during the I inspection should be considered proprietary. No proprietary information was l identified.

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. PARTIAL LlST OF PERSONS CONTACTED 1.icensee e

M. Wadley. Plant Manager - .

K. Albrecht. General Superintendent Engineering J. Anderson. Shift Manager J. Goldsmith. General Superintendent Design Engineering J. Hill. Manager Quality Services G Lenertz. General Superintendent Plant Maintenance J. Leveille. Licensing Engineer D. Schuelke. General Superintendent Radiation Protection and Chemistry M. Sleigh. Superintendent Security J. Sorensen General Superintendent Plant Operations INSPECTION PROCEDURES USED IP 37551: Onsite Engineering  ;

IP 61726: Surveillance Observations l IP 62707: Maintenance Observations IP 71707: Plant Operations -

IP 71750: Plant Support Activities IP 92700: Onsite Follow-up of Written Reports of Nounroutine Events at Power Reactor Facilities IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering ITEMS OPENED. CLOSED, AND DISCUSSED Opened 282/96016-01 URI Inadvertent Boron Dilution of the Reactor Coolant System 306/96016-02 NCV Operator Error During Surveillance Test 306/96-03 LER Auto-start of 21 Component Cooling Water Pump due to Personnel Error 306/96016-03 NCV Failure to Include Previous Similar Event in Licensee Event Report 306/96-04 LER Failure to Perform SP-2244. Cycling of Unit 2 Containment Air Sample Valves 306/96016-04 NCV Fallure to Perform SP-2244. Cycling of Unit 2 Containment Air Sample Valves 282(306)/96-19 LER Spent Fuel Storage Racks Outside Design Basis due to Boraflex Degradation 282(306)/96-20 LER An Individual's Security Asses Should Have Been Revoked Following Determination of Questionable Fitness Discussed 282(306)/96-16 LER Auto-start of No. 11 Component Cooling Water Pump due to Personnel Error

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LIST OF ACRONYMS USED

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. ASME American Society of Mechanical Engineers CC Component Cooling

- CFR Code of Federal Regulations i FW Feedwater

IP Inspection Procedure LER Licensee Event Report  !

NCV Non-Cited Violation NRC Nuclear Regulatory Commission PDR Public Document Room RHR Residual Heat Remo' val SE Safety Evaluation SP Surveillance Procedure URI Unresolved Item USAR Updated Safety Analysis Report WO Work Order

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