ML20148G257

Forwards Response to NRC Re Violations Noted in Insp Repts 50-282/97-05,50-306/97-05 & 72-0010/97-05. Corrective Actions:Plant Was Restored to Compliance W/Ts Requirements Prior to Shift Staff Aware of non-compliance

ML20148G257
Person / Time
Site:	Prairie Island
Issue date:	06/02/1997
From:	Sorensen J NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
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 9706050246
Download: ML20148G257 (9)

Text

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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 June 2,1997 10 CFR Pad 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 l 50-306 DPR-60 72-10 SNM-2506 Reply to Notice of Violation (Inspection Report 97005),

Procedural Adherence issues and Security Log Falsification Your letter of May 1,1997, which transmitted Inspection Report No. 97005, required a

response to a Notice of Violation. Our response to the notice is contained in the attachment to this letter.

In this response we have made one new Nuclear Regulatory Commission commitment, the corrective action for Violation 1.b in italics. Commitments have previously been made, for Violation 1.a, in the Unit 2 Licensee Event Report 97-02, dated April 17,

1997.  !

Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions f, i

related to this letter. //

mw Joel P Sorensen -

Plant Manager  :

Prairie Island Nuclear Generating Plant  ;

c: Regional Administrator - Region 111, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg

Attachment:

RESPONSE TO NOTICE OF VIOLATION 9706050246 970602

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RESPONSE TO NOTICE OF VIOLATION .  !

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VIOLATION 1.a l 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

. Procedure C18, " Engineered Safeguards System," Revision 34, Section 5.2,  !

" Raising Accumulator Level (Cold or Refueling Shutdown)," required that the plant be in the Cold or Refueling Shutdown Mode when the accumulators were filled.

1 Surveillance Procedure SP 1001AA, " Reactor Coolant System Leakage Test,"

Revision 24, did not address manipulation of valve CV-31205.  ;

Contrary to the above:

a. On March 18,1997, the licensee used Procedure C18, Section 5.2 to fill l the Unit 2 accumulators and the plant was not in the Cold or Refueling  :

Shutdown Mode.

b. ...

)

i This is a Severity Level IV Violation (Supplement 1).  ;

, BESPDNSE TOYJOLATION 1a Background Niolation 1.a)

On March 18,1997, Unit 2 was above cold shutdown, with the reactor coolant system (RCS) at approximately 335 degrees F and 360 psig, during startup evolution from a refueling outage. Following an outage, each safeguards accumulator (tank containing borated water pressurized with nitrogen that provides a passive means of injecting into the RCS in the event that the RCS pressure drops below the pressure of the accumulator) needs to be filled. in order to accomplish this, a safety injection pump is normally used to deliver water to an accumulator through the accumulator fill line (see Figure 1); during the filling, the valves to the RCS cold legs, 8801A and 8801B, must be closed to prevent flow to the RCS when RCS pressure is below shutoff head of the safety injection pump. This evolution is normally done prior to heating the RCS above 200 degrees F (and the normal pre-conditions are a gas bubble in the pressurizer and a containment air temperature of greater than 70 degrees F).

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Attachment June 2,1997 a

• Page 2 Prior to exceeding an RCS temperature of 200 degrees F, the procedure requires the accumulators to be filled with borated water and pressurized with nitrogen. However, there is a restriction in another procedure against pressurizing the accumulators when the containment air temperature is less than 70 degrees F. Since the containment air temperature was below 70 degrees F and the accumulators are not required to be in service by Technical Specifications until the RCS pressure is greater than 1000 psig, it was decided to make a temporary change to the procedure to delay filling of the accumulators until later in the startup evolution. There was another reason not to fill at this time: the RCS was filled and solid whereas the Technical Specifications require both SI pumps' control switches to be in pullout with the RCS below 200 degrees F and no bubble in the pressurizer. The accumulators could have physically been filled by gravity supplying borated water from the RWST except that there is an Updated Safety Analysis Report statement that the accumulators are filled by the use of an Si pump and, therefore, there were no procedures supporting a gravity feed fill of the accumulators. It is believed that the Updated Safety Analysis Report statement was not intended to be prescriptive but it was conservatively decided not to fill in this manner without evaluating per 10CFR50.59.

After a bubble had been established in the pressurizer and the containment air temperature had warmed to greater than 70 degrees F, it was intended to fill the accumulators. The RCS was at approximately 335 degrees F and 360 psig. In order to fill the accumulators, the two cold leg injection isolation valves 8801 A and 8801B needed to be closed to prevent flow to the RCS. However, the Technical Specifications require that, when the RCS temperature is greater than 200 degrees F, these valves be

. . . locked in the open position by having the motor control center supply breakers physically locked in the off position." Recognizing this restriction, shift management thought that it would be legitimate to close the valves for a short period of time under  !

direct supervision because the filling could be accomplished in less than an hour and 1 Technical Specification 3.0.C. (commonly referred to as the " motherhood clause")

states:

When a Limiting Condition for Operation is not met, and required action is not specified or cannot be satisfied, within one hour initiate the action necessary to place the affected unit in a condition in which the equipment is not required to be OPERABLE.

Since a required action is not specified for the condition where these two valves are closed above cold shutdown, shift management assumed that they could enter this condition, fill the accumulators and pressurize them, return the valves to their required positions and be within the intent of Technical Specification 3.0.C if they could accomplish the operation within one hour. in addition, it was thought that this would be a more prudent course of action than cycling the RCS through the process of returning to cold shutdown, filling the accumulators, and returning to the heatup process (for IR97005. DOC

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j. Attachment s .

- June 2,1997 Page 3 example, the concern about low temperature overpressurization of the RCS was

- already past).

i

!o The operation was accomplished in 44 minutes and was done with an operator

- stationed at the control switches for the subject valves prepared to open them if j necessary (the breakers were on). The valves were retumed to the Technical

Specification required locked open position when the operation was completed.

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Reason for the Violation Niolation 1.a)

The cause of the event was that shift management assumed that Technical i Specification 3.0.C could be used as a normal Technical Specification required action

when a limiting condition for operation is not met. It was thought that it would be similar

! to removing one safety injection pump from service with a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> return to. service

requirement. The limit in Technical Specification 3.0.C is one hour, which is a very i

short time limit but that seemed appropriate for an action where both paths of injoction

. to the cold legs are isolated. That is, the time limit seemed proportionate to the

[

i condition in which the plant was being placed.

l It was not understood that Technical Specification 3.0.C is intended to provide time to I orderly place the plant in the required mode when a limiting condition for operation is j found not met and no required action is specified in the corresponding specification.

4 Plant management had the proper understanding of Technical Specification 3.0.C but that understanding was not effectively communicated to the operauons shift staff.

Corrective Stens Taken and Results Achieved Niolation 1.a) 5 l The plant was restored to compliance with the Technical Specification requirements L prior to the shift staff becoming aware that the plant had been out of compliance, f

Corrective Steos To Avoid Further Violations Niolation 1.a)

! On March 18,1997, the General Superintendent of Operations sent a message to all

, operations perconnel with a discussion of the significance of entering Technical i Specification 3.0.C.

l The licensee event report for this event has been " required reading" for all operators.

i IR97005. DOC l

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Attachment June 2,1997 j Page 4 '

Training on the intent of Techriical Specification 3.0.C will be made a part of the routine training provided to all operators. l l

An evaluation will be performed to determine if the Updated Safety Analysis Report can  :

be changed te allow gravity filling of the accumulators from the refueling water storage  ;

tank. >

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The Date When Full Comoliance Will be Achieved (Violation 1.a)

Full comp!!ance has been achieved.

VIOLATION 1.b 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Procedure C18, " Engineered Safeguards System," Revision 34, Section 5.2,

. " Raising Accumulator Level (Cold or Refueling Shutdown)," required that the plant be in the Cold or Refueling Shutdown Mode when the accumulators were filled.

Surveillance Procedure SP 1001 AA, " Reactor Coolant S / stem Leakage Test," 1 Revision 24, did not address manipulation of valve CV-31205.

1 Contrary to the above:

4 l

a. ...

b. Operators occasiona':y manipulated valve CV-31205 during the

performance of SP 1001AA to preclude diversion ofletdown to the holdup tanks and subsequent voiding of the surveillance.

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

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i i unoos.coe l

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June 2,1997 i Page 5 RESPONSE TO VIOLATION 1.b -

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1. t i Reason for the Vioistion (Violation 1.b)  !

4

! As discussed in the inspection report, we, too, believe that the valve CV-31205 was  !

mis-positioned during the performance of the daily RCS leak rate surveillance, SP i

, . 1001aa. The test requires stable conditions including constant volume control tank i' level during the two hours data is collected. To avoid any diverting of letdown to the - j CVCS holdup tanks and thus voiding the surveillance, some Operators have placed the j l control switch to the VC TNK position. The action is taken without benefit of procedure l steps to initiate the action or to retum the switch to the AUTO position. On this - i occasion, it appears that the operator positioned the wrong valve, failing to adequately i

, self-check. Sehequently, the operator failed to do an adequate control board l walkdown, not noticing the valve out of its normal position.  ;

j Further investigation via interviews revealed that secondary causes of the mis-

' I positioned valve were:

l l e The modified mirror image conventien used in the control room contributes to  !

! positioning of the wrong divert valve; j

. The dual red light convention (a reo Mrs is illuminated for either position of

, tha valve) contributes to a poor discover / mechanism to find mispositioned j

c'ivert valves.  :

3

. The small tag depicting a lit light bulb over the normal position of the divert valve is not seen by some Operators and contributes little to a discovery

{

j method.

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e Corrective Steos Taken and Results Achieved (Violation 1.b)

Upon review, the mis-positioned valve was returned to its normal position.

Corrective Steos To Avoid Further Violations (Violation 1.b)

There are four procedures to perform the RCS daily RCS leakage rate; these have all been revised to include steps M position the valve when required and to return the valve to its normal position wh?n done.

A solution being considered is to replace the redlenses over the off normalposition with white lenses. It is believed that the white lenses would be thought of as

-" disagreement" as are other white lenses and would draw more attention to the valves if  !

in an off normal position. A decision regarding human factors improvement to the l control board will be made by September 1,1997.

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IR97005. DOC 1

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Attachment 4 June 2,1997 I Page 6 The Date When Full Comoliance Will be Achieved Niolation 1.b) t i

Full compliance has been achieved.

J VIOLATION 2 Section 13 of Amendment 2 of Materials License No. SNM-2506, dated February 1,1996, requires the licensee to comply with all provisions of the Independent Spent Fuel Storage Installation (ISFSI) security plan. Section 6.2 of the ISFSI security plan requires visitors entry to be logged before entering the ISFSI protected area.

10 CFR 50.9 (a) requires information required by the Commission's regulations, orders, or license conditions to be complete and accurate in all material respects.

i

, 10 CFR 50.5 (a) prohibits an individual (s) from engaging in deliberate j misconduct that could cause a licensee to be in violation of any rule, regulation, or order issued by the Commission.

Contrary to the above, 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 j 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.

This is a Severity Level IV violation (Supplement Vil D.2).

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I IR97005. DOC

_ .. _ . . . . _ . _ . m _. _ . _ _ _. _ m _ _ _ .__.._.m Attachment i ,,. . . June 2,1997 i

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Page 7 j RESPONSE TO VIOLATION 2 Reason for the Violation Niolation 2)

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. Removal ,

and falsification of this record by the supervisor constitutes a violation of the ISFSI l security plan. Discussion of the potential reasons that the security supervisor falsified l the record are included in our April 15,1996 letter to the NRC transmitting a copy of our {

l investigative report.

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Corrective Steos Taken and Results Achieved and Corrective Steosjo Avoid Further i Violations Niolation 21 l

A full investigation of the activities surrounding this event was immediately conducted by the security contractor, under the supervision of the licensee. During the investigation, on February 29,1996, the two shift supervisors involved resigned. The  !

licensee considered the resignations as "for cause" and their unescorted access  !

authorization was subsequently denied. ,

- The original visitor log page was returned to the log book and the log book changed to '

a bound book vice the three-ring binder previously used. The security staff changed l

protected and vital area security locks and keys. Discussion of this event with all  !

members of the security team verify that this was an isolated instance involving only l these two supervisors. A " Lessons Learned" document was reviewed with all members of the security team.

-t The Date When Full Comoliance Will be Achieved Niolation 2)

Full compliance has been achieved.

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