IR 05000282/1997005
| ML20148B144 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/01/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20148B127 | List: |
| References | |
| 50-282-97-05, 50-282-97-5, 50-306-97-05, 50-306-97-5, 72-0010-97-05, 72-10-97-5, NUDOCS 9705120180 | |
| Download: ML20148B144 (35) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket Nos: 50 282, 50-306,72-10 License Nos: DPR-42, DPR-60, SNM-2506 )
i Report No: 50-282/97005, 50-306/97005, 72-10/97005 j Licensee: Northern States Power Company i I
l Facility: Prairie Island Nuclear Generating Plant Location: 1717 Wakonada Drive East Welch, MN 55089 Dates: February 21 - April 4,1997 i
inspectors: S. Ray, Senior Resident inspector R. Bywater, Resident inspector !
G. Pirtle, Plant Protection Analyst I l
Approved by: J. Jacobson, Chief, Projects Branch 4 i Division of Reactor Projects i l
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EXECUTIVE SUMMARY Prairie Island Nuclear Generating Plant, Units 1 & 2 NRC Inspection Report 50-282/97005, 50-306/97005, 72-10/97005 I
This inspection included aspects of licensee operations, maintenance, engineering, and plant support performed by the resident inspectors and a review of a security incident performed by a regional plant protection analys !
Ooerations I l
e The inspectors noted good performance and control of Unit 2 restart activities, )
including reactivity management during this period. (Section 01.3) However, an inadvertent reactivity addition occurred at the start of the next inspection perio This event will be discussed in detcil in the next Resident inspection repor e A violation was identified for filling the Unit 2 accumulators on March 18,1997, using Procedure C18, Section 5.2, when the plant was operating in Mode 4. The procedure allowed filling accumulators per Section 5.2 only in Modes 5 or Control room operators understooc that performing this activity required closing both of the safety injection (SI) to reactor coolant system cold leg isolation valves and that Technical Specifications (TS) required these valves open for operability of the SI system. No allowed outage time was specified in the TS for both valves inoperable. Therefore, the operators assumed it was acceptable to use the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> specified in TS 3.0.C as an allowed outage time for both valves closed, and filled the accumulators. The operators did not understand that this was a condition prohibited by the TS and was reportable per 10 CFR 50.73 until informed by the inspectors. (Section 01.4)
e A quality services audit identified that decommissioning funding calculations were nonconservative and resulted in funding below NRC-required minimum levels. This was considered a Non-cited Violation. (Section 07.1)
i Maintenance e The inspectors conclJded that the licensee's command, control, and coordination of the integrated feakage rate test and integrated safety injection test was very goo (Section M1.1)
e A quality services inspector identified another example of a heavy loads control violation that the inspectors identified in Inspection Report (282)306/97002. The licensee's corrective actions for heavy loads control programmatic deficiencies will be evaluated as part of the inspectors' review of the previous violatio :
(Section M3.1)
e An Inspection Followup Item was identified to review the licensee's interpretation of the Technical Specification allowances for the interval between surveillance tests. (Section M7)
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e The inspectors reviewed licensee activities associated with new plant license
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conditions to iesolve cooling water system post-seismic event performance issue The first of the license conditions were acceptably implemented by the end of this inspection period. (Section E8.2) -
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l e The inspectors observed timely and conservative preparations for potential plant i flooding due to rising river level. (Section P1.1) -
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e A violation was cited because on February 24,1996, a contractor security !
supervisor falsified a record required be NRC regulations in an effort to cover up an
- error the supervisor had made. (Section S.1)
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l l Reoort Details l Summarv of Plant Status j Unit 1 operated at or near full power for the entire inspection period except for brief power i reductions for various testing and maintenance activities. Unit 2 remained in a refueling outage until March 28,1997, when the unit was started up. The generator was placed on l
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the grid on March 30,1997. There were no dry spent fuel storage cask activities during the perio . Operations 01 Conduct of Operations 01.1 General Comments Insoection Scone (71707) i 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 j Report (USAR) Section 13, " Plant Operations," was reviewed as part of the I inspectio l Observations and Findinas The inspectors observed proper control room manning, adequate attention to control panels, good use of communication protocols, good turnovers, and detailed shift briefs in which all members of the crew contribute . Conclusions Plant operations were generally conducted conservatively and in accordance with procedures with the exception of the deliberate entry into a condition prohibited by Technical Specifications discussed in Section 0 .2 Excessive Drainina of Reactor Coolant System (93702)
On March 6 7,1997, during the conduct of activities near the end of the Unit 2 refueling outage, the licensee inadvertently drained more water than desired from the reactor coolant system. This event was the subject of a specialinspection (306/97006) and thus will not be evaluated in this report.
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e, insoection Scone (71707)
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! The inspectors observed portions of the Unit 2 startup on March 27 tnrough 29, i 1997. Procedures reviewed included the following:
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l e 2C1.2, " Unit 2 Startup Procedure," Revision 16 ;
i e D30, " Post Refueling Startup Testing," Revision 27 i
j' Observations and Findinas
i The inspectors observed the pre-evolution briefing conducted prior to the Unit 2 i reactor startup on March 27,1997. An extra reactor operator and senior reactor operator, in addition to the normal crew complement, were assigned to perform the
- startup. Other plant activities were to be kept at a minimum. Nuclear engineering l personnel were also present and personnel roles and responsibilities were j' emphasized with regard to reactivity management.
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j The inspectors observed the withdrawal of shutdown and control rod banks and i dilution to criticality. The reactor was made critical at 2:41 p.m. on March 27.
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! During the night of March 27-28, while preparing the reactivity computer for
- performing physics testing per D30, problems were encountered with the output i signal of the 2N44 excore neutron detector. The licensee decided to shutdown the unit and investigate the problem with 2N44. The detector was replaced on l March 28 and the reactor was made critical again at 10
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j On March 29, the inspectors observed the licensee perform rod worth j measurements of control rod banks and shutdown banks using the rod swap j methodology. The test engineer made observations of core reactivity and neutron i flux on the reactivity computer and provided instructions to the reactor operator for
- the desired rod manipulations. The reactor operator provided repeat-backs of the i
instructions in all cases and resolved a couple of instances when the rod movement
- instruction was not clearly articulate
- 1 by the engineer. The reactor operator was i continuously monitoring core response to his rod manipulations under the j supervision of a senior reactor operator. The results of the startup testing were in 4 good agreement with predicted values for rod worth, critical boron concentration,
{ and isothermal temperature coefficient, i
2 Conclusions i
i Control and performance of reactor startup activities was generally good. The
! licensee demonstrated good reactivity controls and a good operations and i engineering personnel interface during the inspection period; however, an
- inadvertent reactivity addition occurred at the start of the next inspection perio !
j This event will be discussed in detail in the next Resident inspection repor ;
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01.4 Entry into Technical Soecifications (TS) 3.0.C to Fili Unit 2 Accumulators Insoection Scooe (919_Q11 On March 18,1997, the General Superintendent of Plant Operations informed the inspectors that Unit 2 control room operators made a deliberate entry into TS 3. during the previous shift to fill the accumulators. The inspectors reviewed the circumstances of the event, drawings, logs, and Procedure C18, " Engineered Safeguards System," Revision 3 Observations and Findinos Procedure C18 required that the containment atmosphere temperature be greater than 70 degrees F, the minimum allowable temperature for accumulator pressurization. Because containment atmosphere temperature was less than 70 degrees F at the time, filling the accumulators was delayed. A decision was made to perform the fill when the RCS was at 335 degrees F and there was a bubble in the pressurizer. At these conditions, TS 3.3.A.1.g(1) required the safety injection (SI) isolation valves to be in the open position with their motor control center breakers locked in the off positio On March 18,1997, Unit 2 was in Mode 4 (Intermediate Shutdown) and the licensee used Procedure C18 to fill the accumulators with a SI pump, in preparation for startup. The control room operators used Section 5.2, " Raising Accumulator Level (Cold or Refueling Shutdown)," which required closing the Si to reactor coolant system (RCS) isolation valves (MV-32171 and MV-32173). TS 3.3.A. allowed one valve inoperable for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, however, the condition of two valves inoperable was not addressed. Although Procedure C18, Section 5.2, required that the unit be in Cold or Refueling Shutdown, control room operators elected to enter the procedure, close both valves, and enter TS 3.0.C. The operators expected that filling the accumulators would take less than one hour and assumed that TS 3. l provided a one hour allowed outage time with both MV-32171 and MV-32173 l closed. Actually, TS 3.0.C was intended only to allow time for a controlled shutdown when the plant was in a condition not allowed by the normal TS limiting conditions for operation. It was not intended to be used as an allowed outage time for those condition Conclusions Title 10 of the Code of Federal Regulations, Part 50, Appendix B Criterion V, l required that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be performed in accordance with these procedures. Procedure C18, Section 5.2 required that the unit be in the Cold or Refueling Shutdown when this section was performed. The Unit 2 was in j neither of these conditions. Therefore, this was considered an example of a failure ;
to follow procedure (50-282(306)/97005-01a). l
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The inspectors also concluded that the licensee did not understand that entry into l TS 3.0.C was a condition prohibited by the TS and reportable to the NR j Operations shift management considered the one hour specified in TS 3.0.C as an allowed outage time, concluded that the evolution planned would take less than one hour, and did not intend to initiate action to place the unit in a condition in which the safety injection system was not required to be operabl The inspectors considered the action to be nonconservative and that it demonstrated a significant lack of appreciation of the TS requirements to maintain operability of the emergency core cooling syste .5 Discoverv of a Misoositioned Valve Insoection Scone (92901)
On April 1,1997, the inspectors were informed that during the night before, operators had discovered that valve CV-31204, " Letdown Divert to Purification," l was in the " Volume Control Tank" (VCT) position on Unit 1. The valve was normally in the " Divert" position. The inspectors reviewed the circumstances of the ;
even l Observations and Findinas Neither the licensee nor inspectors could determine conclusively how or when the valve got into the wrong position. A review of the reactor logs determined that the valve had been in the correct position at 7:58 a.m. on March 30 because a mixed bed ion exchanger had been briefly placed in service to reduce RCS lithium concentration and the evolution had been successfulindicating letdown flow was going through the purification system. The valve was discovered to be in the wrong position at 9:00 p.m. on March 3 The licensee determined that the most 'ikely cause of mispositioning of CV-31204 was a mistake made during the daily ROS leak rate surveillance SP 1001 AA,
"Reactc: Coolant System Leakage Te',t," Revision 24. That surveillance had been performed twice in the time betwem 7:58 a.m. March 30 and 9:00 p.m. March 3 During performance of that test, cperators frequently placed valve CV-31205,
" Letdown Divert to Holdup Tank," in the "VCT" position to prevent invalidation of the test due to diversion of letdown. The two valves were located close together on the control board and had similar names and functions and identical position nomenclature (VCT/ Auto / Divert).
The inspectors observed that SP 1001 AA had a precaution that stated the test would be voided if letdown diverted to the holdup tanks but did not contain instructions to prevent the diversion by placing CV-31205 into the "VCT" positio Interviews with operators revealed that some made it a regular practice to position CV 31205, some did it only when VCT level was near the point of automatic diversion of letdown to the holdup tanks, and some seldom manipulated the valve.
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. Conclusions Surveillance Procedure SP 1001 AA did not contain instructions for the manipulation of valve CV-31205 although many operators routinely changed its position as part of the surveillance. Title 10 of the Code of Federal Regulations, Part 50, Appendix B Criterion V, required that activities affecting quality be prescribed by documented procedures of a type appropriate to the circumstances and shall be performed in accordance with these procedures. Manipulation of CV-31205 to preclude diversion of letdown to the holdup tanks was not included in SP 1001 AA.
> Therefore, this was considered an example of a failure to follow procedure (50-282(306)/97005-01 b).
06 Operations Organization and Administration
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06.1 Manaaement Chanan On March 7,1997, the licensee announced that Mr. Terry Silverberg had been selected as General Superintendent of Plant Operations. Mr. Silverberg was a Shift Manager with an active Senior Reactor Operator Licens Quality Assurance in Operations 07.1 Mnderfundina of Decommissionino Fundina On December 20,1996, the licensee issued a letter to the NRC stating that a quality services audit had determined that the decommission funding calculations ;
starting in 1993 had been nonconservative, resulting in under funding below the NRC minimum required levels specified in 10 CFR 50.75, " Reporting and Recordkeeping for Decommissioning Planning," Section (b). The letter also l described the licensee's intended corrective actions. The inspectors referred the
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issue to the NRC Office of Nuclear Reactor Regulation staff for a determination of j
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the enforcement aspects of the findin The NRC staff determined that the finding constituted a violation of 10 CFR 50.75(b) but that the violation was licensee-identified, adequate corrective actions had been initiated, and the issue was not safety-significant. Thus this licensee-identified and corrected violation is being treated as a Non-Cited Violation (50-282(306)/97005-02), consistent with Section Vll.B.1 of the NRC Enforcement Polic _ _ -- ._ - - . . - - - - . . . .
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l II. Maintenancg
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M1 Conduct of Maintenance l
M 1.1 General Comments l Insoection Scoce (61726,62707)
The inspectors observed all or portions of the following maintenance and surveillance activities. Included in the inspection was a review of the surveillance procedures (SP) or work orders (WO) listed as well as the appropriate Updated Safety Analysis Report (USAR) sections regarding the activities. The review included a verification that the surveillance activity fulfilled the appropriate Technical Specification requirement and was not contrary to any description in the USA * SP 2102 22 Turbine-Driven Auxiliary Feedwater Pump Test, Revision 50
- SP 2301 22 Turbine-Driven Auxiliary Feedwater Pump Autostart and Functional Testing, Revision 5
- SP 207 Integrated Leakage Rate Test (ILRT) Prerequisites to the Containment Vessel Integrated Leakage Rate Test, Revision 6
- SP 207 Integrated Leakage Rate Test Final Preparations and Test Procedure, Revision 12
- SP 2083 Unit 2 Integrated Safety injection Test with a Simulated Loss of Offsite Power, Revision 21
- SP 2750 Post Outage Containment Closecut inspection
- WO 9611234 12 Diesel-Driven Cooling Water Pump Annual Inspection
- WO 9700571 Auxiliary Feedwater Benchmark Testing i
- WO 9701474 Replace Reactor Head Vent Valve Observations and Findinas All maintenance and surveillance activities observed were performed properl Significant observations on specific activities are discussed belo * For SP 2071.4, the licensee identified an error in the procedure. The error involved the administrative control of the containment boundary and RCS vent path. If undetected, it would have resulted in a violation of requirements for containment boundary control. A procedure deviation was written to correct the condition. The inspectors considered the identification of this issue good. The inspectors wiL review final resolution of RCS vent path and containment boundary considerations for ILRT at a later date (IFl 50-282(306)/97005-03).
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. of activities. This complex test required the coordinated effort of many people, including operations, engineering, and maintenance personnel, to
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establish the test conditions and monitor systems as the test was performe Conclusions i i inspector-observed maintenance and surveillance activities were generally well
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conducted with good communications, proper pre-job planning, safe work practices, J
and coordination between departments.
i M3 Maintenance Procedures and Documentation
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M3.1 Control of Heavy Loads with Mobile Cranes
I Inspection Scoos (62703. 92902)
On February 25,1997, a licensee quality services inspector identified that the
, maintenance workers had used a forklift to remove a concrete trench cover over a pipe chase containing residual heat removal and safety injection system piping. The
, licensee determined that the heavy cover had been removed without implementing i the controls in licensee Procedure D58, " Control of Heavy Loads," Revision 2 The inspectors reviewed the circumstances of the event.
] Observations and Findinas This event was very similar to one which had occurred a few days earlier on
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February 19,1997. That event was discussed in Inspection Report 282(306)/97002, Section M3.1. In both cases, the licensee's procedure, D58, was inadequate in that it did not contain instructions for controlling heavy load lifts with l other than permanently installed lifting devices. For the February 19 event, the i NRC issued a Notice of Violation dated February 25,1997. In addition, during a
- pre-decisional enforcement conference on March 18,1997, regarding another
- heavy load lifting event which occurred on February 3,1997, discussed in Inspection Report 282(306)/97002, Section M1.2, the licensee also discussed the two additional events. Licensee corrective actions discussed in the pre-decisional
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enforcement conference, in the response to the Notice of Violation, and in the associated LER (282(306)/97-01), addressed all three heavy load events and the
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heavy load control program in general.
Since the February 25 event occurred before the licensee had adequate time to implement corrective actions for the February 19 ovent, the inspectors consider the
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event a second example of the same violation cited in the Notice of Violation dated
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- Conclusions
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Because the three heavy load events indicated problems both in procedure adequacy and implementation, the licensee implemented numerous corrective actions as discussed above. Effectiveness of the corrective actions will be reviewed when the violation is closed ou M7 Quality Assurance in Maintenance Activities Insoection Scooe (92902)
On April 3,1997, the inspectors were informed that licensee quality services personnel and scheduling personnel had a disagreement regarding the interpretation of the Technical Specification (TS) allowances for the interval between surveillances. The inspectors reviewed the issu Observations and Findinas Technical Specification 4. SURVEILLANCE REQUIREMENTS. stated: l Aoolicability l Each Surveillance Requirement shall be performed within the specified time interval with the following exceptions: Specified time intervals between tests may be adjusted !
plus or minus 25% to accommodate normal test i schedules, j l The intervals between tests scheduled for refueling 1 shutdowns shall not exceed two year ,
I Hcwever, the Surveillance Requirements did not actually specify a " time interval between tests" such as 31 days from which to calculate the plus or minus 25%.
They merely specified a frequency such as " monthly" with no definition of what
" monthly" means. In addition, the TS did not have a Basis section for In practice the licensee used a " fixed" surveillance program which scheduled each test on a particular repeating day such as "the third Wednesday of each month."
The licensee defined the start of a surveillance month as the first Sunday of that calendar month. Thus for monthly surveillances, the program was such that they were scheduled either exactly 28 or 35 days (4 or 5 weeks) apart depending on the number of weeks in the month. The licensee also conservatively used 7 days (one week) as the 25% allowance for monthly tests. However, they applied the 25% to an interval of as long as 35 days to start wit !
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l l It was licensee scheduling personnel's belief that TS 4.0 allowed them to adjust the schedule for one monthly test by minus 7 days and the next monthly test by plus 7 days. That could result in as much as 49 days (7 weeks) between the actual performance of monthly tests. A licensee quality services inspector found cases where as much as 43 days had elapsed between monthly test The inspectors had two concerns; was it acceptable for surveillance schedules be adjusted minus 25% for one performance and plus 25% for the next performance, and what was the base interval from which the schedule can be adjusted. For example, was it acceptable to add 25% to a monthly surveillance that was already scheduled 35 days from the last scheduled performanc Conclusions In order to resolve the questions in interpretation, the inspectors initiated a request for technical assistance to the NRC Office of Nuclear Reactor Regulation and consider the issue an inspection Followup Item (50-282(306)/97005-03) pending a response to that reques M8 Miscellaneous Maintenance issues (92700,92902)
i M8.1 (Closed) Licensee Event Reoort (LER) 282(306)/97-01: Transporting a Heavy Load j over Irradiated Fuel or Safe Shutdown Equipment without Establishing the Required Conditions. This LER discussed three events, one discussed in Inspection Report ,
282(306)/97002, Section M1.2, one discussed in Section M3.1 of the same report, I and one discussed in Section M3.1 of this report. A violation (306/97002-04) was !
issued for the inadequate procedure which lead to two of the events and the other l event was the subject of an apparent violation (EA 97-073). Thus the LER will be closed to avoid duplication of tracking and licensee's corrective actions will be reviewed when the violation and apparent violation are close M8.2 (Closed) Licensee Event Reoort (LER) 282(306)/97-02: Failure to Submit Relief Requests for Limited inservice Inspection Examinations. This issue was previously discussed in inspection Report 282(306)/97003, Section M4.1. A Notice of Violation was issued in that report for the issue (282(306)/970~)3-01(a)&(b)). The licensee's corrective actions will be reviewed when the violation is close Therefore the LER is closed to avoid duplicatio M8.3 (Closed) Insoection Followun item 282(3061/97002-03: Verification of Ability to Operate the Cooling Water System from the Control Room. This issue was previously discussed in Inspection Report 282(306)/97002, Section M1.1. The inspectors were concerned that there was no routine tast to demonstrate the ability of the cooling water pumps to be started and stopped from the control room. This was part of the system design basis described in Section 10.4.1.1 of the Updated Safety Analysis Repor During this inspection period the system en0i neer completed revision 15 to Preventive Maintenance Procedure PM 3002-2-12,"12 Diesel Cooling Water Pump 12 -
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Annual Inspection," and Revision 16 to PM 3002-2-22, "22 Diesel Cooling Water Pump Annual Inspection," to add steps to test the ability of the pumps to be
started and stopped from the control room. in addition, the inspectors observed
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water pump during the performance of the PM.
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The actions discussed above were sufficient to resolus the concern.
111. Enaineerina j E2 Engineering Support of Facilities and Equipment E2.1 Review of Uodated Safety Analysis Reoort (USAR) Commitments (37551)
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j 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 l
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the USAR as an engineering / technical support basis document. The inspectors l l compared plant practices, procedures, and/or parameters to the USAR descriptions I
as discussed in each section. The inspectors verified that the USAR wording was
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not consistent, the licensee had completed safety evaluations in accordance with I 10 CFR 50.5 !
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E6 Engineering Organization and Administration i
- E6.1 Manaaement Chanaes I
On March 19,1997, the licensee announced some changes in the system engineering organization. Mr. Ted Amundson was named to a temporary position as a second General Superintendent of Engineering, managing the mechanical disciplines. Mr. Ken Albrecht, continues as a General Superintendent of Engineering, managing the electrical and instrumentation and control discipline Other changes in supervisory positions were also announce !
E8 Miscellaneous Engineering issues (92700, 92903) l
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E8.1 (Onen) Licensee Event Reoort (LER) 282(306)/96-10: Determination that the Auxiliary Feedwater Pumps are not Protected Against Runout for all Accident Conditions. This issue was previously discussed in Inspection Reports 282(306)/96006, Section 01.3; 282(306)/96007, Section E1.1; and 282(306)/96010, Section E During this inspection period the licensee intended to resolve the design questions on Unit 2 by installing flow restricting orifices as discussed in the " Corrective Action" section of the LER. However,it was subsequently determined that orifices would reduce auxiliary feedwater (AFW) flow below design minimums for some events and therefore was not an acceptable solutio l
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The licensee evaluated several other options and eventually decided to set the AFW pump low discharge trips to 800 psig on Unit 2 and adjust the time delays to prevent spurious trips during pump startup. However, during the evaluation of the issue, the licensee discovered that the Updated Safety Analysis Report (USAR)
analysis for the loss of feedwater anticipated transient without reactor scram (ATWS) accident analysis (USAR Section 14.8.3.2) apparently assumed that AFW )
flow would be delivereri continuously throughout the event. USAR Figure 14.8-19, l Revision 0, indicated that steam generator pressure would drop below 800 psig at i about 10 minutes into the event which would result in a loss of the AFW pumps due to the low pressure trip. The licensee reported this issue to the NRC via the Emergency Notification System on March 25,199 l A modification was subscquently implemented which defeated the low pressure trip l on the turbine-driven AFW pump during an ATWS event on Unit 2. It was i determined that the pump would still be protected from runout conditions because, as the discharge pressure dropped below 800 psig, the driving steam supply pressure would also drop correspondingly and the pump would slow down. The licensee then requested vendor calculations to verify that the margin of safety in the loss of feedwater ATWS event would not be reduced due to the changes in the AFW system. A letter was issued to the NRC dated March 22,1997,in which the completed and planned actions to resolve the issues related to the AFW pumps j were discusse At the end of the inspection period, the licensee had limited Unit 2 to below 40% l power (the power below which the automatic ATWS mitigation system is not l credited). Unit 1 continued to operate at full power under an operability evaluation which depended on operator intervention to maintain sufficient backpressure on the AFW pumps to prevent runout conditions or tripping. This evaluation was j performed in accordance with the guidance of NRC Generic Letter 91-1 i l
This issue will be one of the subjects of an upcoming System Operational Performance Team inspection which will be documented in inspection Report 282(306)/9700 E8.2 (Onen) Enforcement Action 96-402: Failure to identify that an Unreviewed Safety Question Existed in a Safety Evaluation of the Emergency Cooling Water Intake Line. This issue has been extensively discussed in Inspection Reports 282(306)/95014, Section 3.13; 282(306)/96007, Section E2.1; 282(306)/96015 (entire report); 282(306)/96016, Section E1.1; and 282(306)/97002, Section E I It was also the subject of a pre-decisional enforcement conference on November i 22,1996, and the resulting Notice of Violation and Proposed imposition of Civil Penalty $50,000, dated January 23,1997. The licensee paid the penalty on February 17,1997, and responded to the violation in a letter dated February 24,
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199 A license amendment request dated January 29,1997 was submitted to resolve the issue. After several telephone conversations, meetings, requests for additional information, a letter to the NRC dated March 3,1997, containing statements of 14 -
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intent for heatup of Unit 2, NRC Confirmatory Action Letter (CAL No. NRR-97-001)
dated March 6,1997, and seven supplements to the original request, the NRC approved an amendment on March 25,1997, which authorized continued operations of both units on an interim basis provided three additional conditions listed in Appendix B of the amendment were me The inspectors verified that the first of the license conditions was implemented when a dedicated licensed operator was posted in the control room for the purpose of identifying the occurrence of an earthquak This violation will remain open pending additional NRC review of the effectiveness of the corrective actions discussed in the violation response letter of February 24, 1997.
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IV. Plant Suocort 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 7175 No discrepancies were note P1 Conduct of Emergency Preparedness Activities (71750)
During normal resident inspection activities, routine observations were conducted in the area of emergency preparedness using Inspection Procedure 71750. No discrepancies were note P Prenaration for Floodino Insoection Scoce (71750)
During the inspection period, Spring flooding of the Mississippi River near the plant was predicted to be at levels which might be higher than previous years. The inspectors monitored plant preparations for potential flooding.
' Observations and Findinos The plant established a task force to review flood procedures and other preparations issues. Near the end of the inspection period the predicted crest was about 685 feet at the plant location. Normal river level was 674.5 feet. That crest would be about 1.5 feet higher than the 1993 flood which was discussed in inspection Report 282(306)/93010, Section 1.c. It would also be about 1.5 feet higher than lowest portion of the plant access road (Sturgeon Lake Road).
However, a road improvement project was already well underway to widen and heighten that road, and the new higher portion was expected to be able to be put into service if neede .
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The task force did a detailed review of Abnormal Procedure AB-4, " Flood," and 1 made several enhancements based on experience with the 1993 flood. The task !
force also reviewed the emergency plan implementing procedures for floods. A l Notice of Unusual Event was not expected to be needed but would be required if river level reached 686 fee The licensee entered AB-4, " Flood," Revision 10 on March 30,1997, when water level reached greater than 678 fee Conclusions i The inspectors observed timely and conservative preparations for potential floodin At the end of the inspection period the river level at the plant was 679.2 feet and risin S1 Conduct of Security and Safeguards Activities (71750,81001)
During normal resident inspection activities, routine observations were conducted in the areas of security and safeguards activities using Inspection Procedure 71750. No i discrepancies were noted. Additional inspection was performed by a Region 111 plant i protection analyst as discussed below using Inspection Procedure 8100 S Falsification of Loos
- Insnection Scooqj81001)
The inspector reviewed licensee documents pertaining to an investigation of alleged alteration and falsification of a visitor sign in log for the Independent Spent Fuel j Storage Installation (ISFSI) by a contractor security supervisor on February 24, '
1996. This issue was previously discussed in NRC Inspection Report 282(306)/96006 and considered for escalated enforcement (EA 97-088). Observation and Findinas On February 23,1996, during the day shift, a group of five visitors toured the ISFSt. Section 5.1.b of ISFSI procedure SAP 1.7, "lSFSI Personnel, Vehicle, and Material Control," required pre-authorization for visitors to enter the ISFSI which is documented on a form that includes, among other things, the visitor's signatur Section 6.2 of the ISFSI security plan requires visitors to the ISFSI to be logged on a visitor log shee Approximately 4:00 a.m. on February 24,1996, the oncoming night shift supervisor noticed that the visitor pre-authorization forms had not been signed by the visitors. The night shift supervisors advised the day shift supervisors that the forms needed the required signatures. On February 24,1996, the junior day shift supervisor removed the visitor sign in log sheet (required by Section 6.2 of the ISFSI security plan) that correctly showed that visitors had entered the ISFSI, and replaced it with an altered visitor log sheet that incorrectly showed that no visitors i
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had entered the ISFSt. When the night shift supervisors returned to work later on the 24th, the day shift supervisors advised them that there had not been a tour of the ISFSI so it did not matter if the pre-authorization forms were signed (Note:
Visitors had toured the ISFSI on February 23,1996, and this fact was known by both day shift supervisors).
On February 25,1996, the night shift supervisors suspected that the records had been altered, verified that the ISFSI had a visitor tour on February 23,1996,and notified contractor security managers of their concern. An investigation was initiated on February 25,1996, by the licensee's security contractor. The junior day shift supervisor retained the original visitor sign in log sheet until it was returned by him on February 26,1996, during an investigation of tt'e inciden On February 29,1996, the two day shift security supervisors resigned. The licensee considered the resignations as "for cause" because it appeared that the supervisor caused the record to be falsified. The security staff changed the l protected and vital area security locks and keys. The two security supervisors unescorted access authorization was subsequently denie ;
When the security staff became aware of the issue, the incident was logged as a security event and the NRC was advised of the pending investigatio Conclusions On February 24,1996, the junior day shift security shift supervisor removed a visitor sign in log sheet (required by Section 6.2 of the Independent Spent Fuel Storage Installation (ISFSI) security plan) that correctly showed that visitors had entered the ISFSI on February 23,1996, and replaced it with an altered visitor log sheet that incorrectly showed that no visitors had entered the ISFSI on February 23,1996. The actions taken by the security supervisor caused the licensee to be in violation of Section 6.2 of the ISFSI security plan. The record (ISFSI visitor log) was material to the NRC in that such records are routinely reviewed to confirm compliance with requirements of the ISFSI security plan. The supervisor's actions constitute a violation (72-10/97005-04) of Section 6.2 of the l lSFSI security plan,10 CFR 50.5(a) and 10 CFR 50.9(a).
F1 Control of Fire Protection Activities (71750)
I During normal resident inspection ar;tivities, routine observations were conducted in the
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area of fire protection activities usi'ig inspection Procedure 71750. The inspectors identified abandoned fire suppression sprinkler piping located in a cable tray in the relay and cable spreading room. The inspectors identified this to the fire marshall who had the piping removed. The sprinkler system had been abandoned in place several years ago when a carbon dioxide system was installed. The fire marshall suspected that the piping may have been an interferencu during other modification activities and was not appropriately removed. The ;nspectors considered this an example of a housekeeping weaknes l l
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V. Manaaement Meetinas X1 Exit Meeting Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on April 4,1997. Additional information was provided to the licensee on April 29,1997. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie X2 Pre Decisional Enforcement Conference Summary i
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On March 18,1997, a Pre-Decisional Enforcement Conference was conducted in the NRC Region ill Office in Lisle, illinois. A list of attendees is included at the end of this report and a copy of the licensee's presentation materials is included as an attachment. The purpose of the conference was to discuss NRC Enforcement Action EA 97-073, involving I an apparent violation of NRC requirements for the control of heavy loads at the Prairie 1 Island Plan l Three events involving control of heavy loads were discussed at the conference. Two of i the sub,iect events were previouslyd iscussed in Inspection Report 282(306)97002. A !
third event is discussed in Section M3.1 of this report and all of the events were discussed in detail in LER 282(306)/97-01. The apparent violation involved the movement on February 3,1997, of a 21 ton reactor coolant pump motor rotor over the open reactor vessel, which was loaded with irradiated fuel. Both doors of the containment building maintenance and personnel airlocks were open and the inservice purge ventilation system was operating, contrary to procedural requirement ,
The licensee discussed short and long term corrective action plans to resolve deficiencies
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in the heavy loads program. These actions were summarized in the licensee's presentation l materials and in LER 282(306)97-0 l l
The NRC informed the licensee that the information provided would be used to determine what enforcement action, if any, would be taken in response to the apparent violation and that the enforcement decision would be transmitted under separate correspondenc ._ __ _ __ _ .._ _ . _ _ _ __ _ _ ._ _.._ _ . _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ .
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PARTIAL LIST OF PERSONS CONTACTED
- Licensee J. Sorensen, Plant Manager K. Albrecht, General Superintendent Engineering j J. Goldsmith, General Superintendent Design Engineering
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R. Held, Outage Planner i
J. Hill, Manager Quality Services G. Lenertz, General Superintendent Plant Maintenance J. Maki, Outage Manager l
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D. Schuelke, General Superintendent Radiation Protection and Chemistry
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T. Silverberg, General Superintendent Plant Operations
M. Sleigh, Superintendent Security P. Valtakis, General Superintendent Plant Operations (Acting)
ATTENDEES AT PRE-DECISIONAL ENFORCEMENT CONFERENCE MARCH 18,1997 Licensee ;
E. Watzl, President, NSP Generation J. Gonyeau, Sr. Consultant l
J. Sorensen, Plant Manager M. Wadley, Vice President, Nuclear Generation j N ~j A. Beach, Regional Administrator B. Berson, Regional Counsel R. Bywater, Resident inspector ;
H. Clayton, Director, Enforcement and Investigations Coordination Staff J. Grobe, Deputy Director, Division of Reactor Projects J. Hannon, Project Director, Projects Directorate ill 1, NRR (via telecon)
J. Jacobson, Chief, Reactor Projects Branch 4 M. Leach, Deputy Director, Division of Reactor Safety (Acting)
S. Ray, Senior Resident inspector E. Schweibinz, Project Engineer B. Wetzel, Project Manager, NRR (via telecon)
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INSPECTION PROCEDURES USED IP 61726: Surveillance Observations IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant Support Activities IP 81001: Independent Spent Fuel Storage Installation IP 92700: Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities IP 92901: Followup - Operations IP 92902: Followup - Maintenance IP 92903: Followup - Engineering IP 93702: Prompt Onsite Followup of Events ITEMS OPENED, CLOSED, AND DISCUSSED Opened 282(306)/97005-01a VIO Failure to Follow Procedure for Filling Accumulators 282(306)/97005-01b VIO Failure to Follow Surveillance Procedure 282(306)/97005-02 NCV Underfunding of Decommissioning Fund 282(306)/97005-03 IFl RCS Vent and Containment Boundary Control During ILRT 282(306)/97005-04 IFl Technical Specification Surveillance Interval Requirements 72-10/97005-05 VIO Security Supervisor Falsified ISFSI Visitor Log Sheet Closed 282(306)/97-01 LER Transporting a Heavy Load over Irradiated Fuel or Safe l
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Shutdown Equipment without Establishing the Required Conditions 282(306)/97-02 LER Failure to Submit Relief Requests for Limited Inservice Inspection Examinations 282(306)/97002-03 IFl Verification of Ability to Operate the Cooling Water System from the Control Room Discussed 282(306)/96-10 LER Determination that the Auxiliary Feedwater Pumps are not Protected Against Runout for all Accident Conditions EA 96-402 VIO Failure to Identify and Unreviewed Safety Question Existed in a Safety Evaluation of the Emergency Cooling Water Intake Line EA 97-073 eel Transporting a Heavy Load over Irradiated Fuel or Safe Shutdown Equipment without Establishing the Required Conditions l
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, LIST OF ACRONYMS USED
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l l AFW Auxiliary Feedwater ATWS Anticipated Transient Without Scram
- CAL Confirmatory Action Letter ;
i CFR Code of Federal Regulations
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C ! Circulating Water l i EA Enforcement Action !
l eel Escalated Enforcement issue l EQ Environmentally Qualified IFl inspection Followup item
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ILRT Integrated Leakage Rate Test IP inspection Procedure ISFSI Independent Spent Fuel Storage Installation ISI Inservice inspection ISTS Improved Standardized Technical Specifications ;
LCO Limiting Conditions for Operation LER Licensee Event Report LOCA Loss of Coolant Accident NRC Nuclear Regulatory Commission
- NSP Northern States Power Company POR Public Document Room RCP Reactor Coolant Pump RCS Reactor Coolant System i SI Safety injection SP Surveillance Procedure '
l SRO Senior Reactor Operator USAR Updated Safety Analysis Report TS Technical Specifications URI Unresolved item VC Volume Control Tank VIO Violation WO Work Order i
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ENCIOSURE 3 AGENDA NRC- NSP Pre-Decisional Enforcement Conference March 18,1997
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- Heavy Load Event of Feb. 3,1997
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g& Causes
_] > S.. sty Significance M?k Heavy Load Event of Feb. 19,1997
> Causes
- sb t Safety Significance hlh a Heavy Load Event of Feb. 25,1997
'a e Causes t Safety Significance h
y a Corrective Actions t Completed Short Term y & Planned Long Tenn d
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Heavy LoadEvent ofFeb. 3,1997
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22 RCP Motor Rotorlifted using polar i crane (See Figute 1.)
me ARin Reactor Vesselheadoff pb l n Refueling Cavityflooded
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il and Personnel Airlocks open n Inservice Purge Ventilation System i,
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Causes ofFebruary 3rd Event
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Procedure D58, Control of Heavy Loads, not adequately applied before making the lif pgEn Job planning by system engineer and maintenance l
f8tb personnel did not identify the need for special requirements to make thislif .Q n Personneldid not have an adequate understanding
% of D58, Control of Heavy Loads, procedur a Communication between maintenance, engineedng f and operations personnel not adequate due to limited knowledge of DSB requirement Safety Sigmficance ofFeb. 3rdEvent .
Rigging met all safety factorrequirement *
AII rigging and lifting fixtures were properly inspected prior
_- to the lif l Load was in vicinity of core forapproximately
' 2 minute '
a Inservice Purge Forced Ventilation uses PAC filter '*%
k a Inservice Purge Forced Ventilation would have automatically isolated by Hi Rad on 2R11/12 and 2R1 .
i h a Calculated thyroid dose from the release of gas from l
@j 1 fuel element is 3.9 rem at site boundar ,
m 1 Q n Load was safely moved again on Feb. 5th after OC y reviewedprocedure wasputin plac Idi
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l Heavy Load Event ofFeb. 19,1997 v.. -
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m r - a . .m 21 Circ Water Pump intemals and l
i 7 h mobile crane (See Figure 2).RQ,
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- di equipment.
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l 9 m Work Orderprocedures did not identify a safe load path.
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l Causes ofFebruary 19th Event
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. D58, Control of Heavy Loads, did not j contain guidance formoving heavy
&] loads with the use of mobile crane ;g a The initialinterpretation of
,ll NUREG-0612, " Control of Heavy 1' i Loads," and other original documents
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~ ' Mobiie craneins'pection sticker postedinside cab
! ; was checked before lift to ensure annualinspection ! I requirements were me Work Order didinclude component weight m Work Order did require crane to be grounded and l . nearby 345 KV line to be isolated and grounde ga
$ a Rigging met all safety factor requirement a All rigging was properly inspected prior to the lif m Pre-job brief discussed safe load path (but not : proceduralized).
n 21 Circ Water Pump motor was safely moved after
?!it the OC reviewed procedure was put in plac e i
Heavy Load Lift Event ofFeb. 25,1997
- ) Concrete trench coverlifted using . :) forklift (See Figure 3).
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\ Load lifted over Train A RHR discharge i piping to SIpump suction and RWST to
> charging pump pipin m Discovered by NSP QC Inspector after El lift was completed.
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, I l Causes ofFebruary 25th Event .
- D58, Control of Heavy Loads, did not
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_' aA loads with the use of forklift I m Initialinterpretation of NUREG-0612, ' y " Control of Heavy Loads,"and other ' f original documents was not applied to
:: forklift ,
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l 1I f Safety Sigmficance ofFeb. 25th Event
. . , _ . . _ . . . . . - . . . - . . ~ , . ; RCS Inventory was at top of hotleg n Train B RHR was operating; Train A was available.
, ; mi Three other make-up paths available to the RCS:
'Zj * RWSTto RHR I * RWSTto SI
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A * Normalmake-up to CVCS
'l l n Rigging of this load followed standard rigging lf' requirement n Loadlifted to 1 inch above floor, then moved to side f.
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and set dow l'}i n Load was safely moved back after oC reviewed j ;] procedure was putin plac '
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Corrective Actions Completed \
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Date Corrective Actions Comoleted Comoleted Movement of 22 RCP motor rotorplaced on hd /4/97
, Specific procedure written for moving 22 RCP motor 2/5T7 %y rotor and reviewed by O "Y Training performed for PI and traveling maintenance 2/W97 5 nggers and repairmen on requirements of DS E Engineering, maintenance and operations personnel 2/W97
- ' informed of event to increase awareness of DSB and management's expectation to follow the procedwe.
i j E Checklist developed and posted at permanent crane 2/12/97 l controls to determine if DSB requirements should be , applie ' n
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Corrective Actions Completed (cont.)
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. . Corrective Actions Completed Comoleted 'S Procedwe written and reviewed by OC forlifting 21 Circ 2/21/97 ) WaterPumpmoto i E AII outstanding odage Work Orders reviewed to identify 2/2&97 i fa any heavy loadlifts requiring preparation ofprocedure l E Mairtenance Standards implementing Procedure 2/27N7 ., . MSIP-6003 written to screen alllifts using permanent or
, portable lifting devices.
, :' ff}l E Procedwe written and reviewed by DC forreplacing RHR trench cove /28/97 g 1 E Maintenance personnel trained on MSIP-600 /28/97 E Construction personnel trained on MSIP-600 '3/97 '
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E Management received draft investigative report from 3f5'97 f ERTF and evaluated short term andlong term corrective q action $b
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! Date l Corrective Actions Comoleted Completed
,.,,:S Intenm revision to DS8 issued to require any load 3997 l s:; , >1799 lbs. transported over safe shutdown equipment or
. ?M irradiated fuel to have a wntten procedure reviewed by i O I i
, ,; n Perforrn heavy load familiarization trainingincluding the 3'17/97 3 MSIP-6003 screening procedure for engineering. QC l
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h B Planned Long Term Corrective Actions
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n Perform comprehensive review of all source l g documents and related correspondence to l l determine scope of heavy loads program,
? including mobile cranes, and then incorporate ;
n, into human factored procedure ,
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Mt wg n Assign single heavy loads program owne i n Conduct ajob task analysis of the heavy i fy loads program.
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Maintenance, Operations and Engineering ' Training PACS will review D Sections in order
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{! to identify any tasks not included in the initial and continuing training program n Outage Planning Team to develop methods .
.] that willidentify heavy loads in future outage planning and schedulin .
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. . . FIGURE 2 Plant Screenhouse
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Screenhouse ,
[ , Diesel Clg Wtr Pmps % Mobile Crane ( ".". . - ,. .
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2M 2R Unit 1 Transformers I 2GT L___J
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. . . FIGURE 3 Unit 2 Aux Bldg Trench
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,, , s _,~ewk w Joseph Gonyeau PE
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SeniorNuclear Consultant
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PrairieIslandNGP
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-Comprehensive Review-Evaluate Program Adequacy-Revise Program and Procedures as appropriate
- Several stages including otitage consideration
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- -NUREG-0612 / ANSI B30.2-1976
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i - Bulletin 96-02 i .
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! -NSP-NRC Correspondence
- - D58 and D sections involving heavy lifts
! , - Design Basis Topical Reports
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/ reliminary Observations T
j _.............;;........;.==mm..._....-.....,_..........._....._
. - Spent fuel / Fuel in core / Safe SD SSCs l , -Operation vs. shutdown conditions - Redundancy - Overhead and gantry cranes - Use of drawings - Typical loads
-Opportunity for error .
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/' - Procedural - human engineering considerations and address potential experience level shifts - D58 and related D sections to address typical
- lifts with drawings to reduce opportunity for l
, error l
; - Mobile and other lifting considerations l - Design basis - consolidate further j , < ~ WO Process review - Heavy Loads TBD . .
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/' mm_______ -Preliminary Revievi l , -Detailed Review-Documents-Calculations-Correspondence-Unit 1 outage procedures # - Design Basis Documents
- General procedures - Process !
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