ML20080C652

Responds to NRC Re Violations Noted in Insp Repts 50-282/94-15 & 50-306/94-15.Corrective Actions:Preventive Maintenance Procedures Revised to Provide Desired Isolation Provisions to Protect Workers While Maintaining Operability

ML20080C652
Person / Time
Site:	Prairie Island
Issue date:	12/12/1994
From:	Wadley M NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9412190141
Download: ML20080C652 (7)

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'3 Northem States Power Company Prairie Island Nuclear Generothe Plant 1717 Wakonado Dr. East Welch, Minnesota 55089

' December 12, 1994 10 CFR.Part 2 Appendix C U S Nuclear Regulatory Commission Attn:

Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Response to Notice of Violation NRC Inspection Report Nos. 282/94015 and 306/94015(DRP)

Control of Enaineered Safety Features SuDoort Eauioment

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Your letter of November 10, 1994, which t einsmitted Inspection

' Report Nos. 282/94015 and 306/94015(DRP),

equired a response to the Notice of Violation.

Our response tc

he violation is-contained in the attachment to this lette i

In this letter we have made new NRC com:

.ments which are identified as such in the attachment as un statements 'which are in italics.

Please contact Jack Leveille (612-388 '

1, Ext. 4662) if you l

have any questions related to this let

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$ b Gs Michael D Wadley Plant Manager

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Prairie Island Nuclear Generating Plant I

c: Regional Administrator - Region III, NRC j

Senior Resident Inspector, NRC NRR Project Manager, NRC J E Silberg

Attachment:

RESPONSE TO NOTICE OF VIOLATION 9412190141 941212 PDR ADOCK C5000292 O

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'N RESPONSE TO. NOTICE.0F VIOLATION,

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1 Notice of' Violation u

h During "an NRC : inspection - conductedL from September L 13 through 10ctober 24, 1994)-a violation of-NRC requirementsLwas identified.

In accordance with the " General Statement of' Policy.;and Procedures for NRC Enforcement Actions," 10 CFR 2,: Appendix C;

-(1994), the' violation is: listed:below:

Technical Specification 6.5 requires that detailed written procedures covering areas listed in'Section 6.5.A shall--be prepared and followed...One of the areas listed in Section 6.5.A pertains'to integrated and system procedures.for; normal startup,. operation, and shutdown of the reactor and all systems and components involving nuclear safety of.the facility.

Administrative Control Directive SACD 3.15, " Plant L.

Operation," aLprocedure required by Technical Specifications, requires that voluntary ' entry into an LCO:

shall be authorized by plant management..These entries are normally; documented in the Weekly Planning Meeting results.

Any other voluntary LCO entry shall be documented on the work order or; work request.

Operating Procedure C18.1, " Engineered' Safeguards; Equipment Support Systems,"' describes what LCOs;are required.to be entered when supportioquipment is removed'from service.

' Contrary to the..above, plant management' authorization for voluntary entry into an-LCO per_ procedure,5ACD 3.15 was not obtained prior to securing a ventilationisystem, identified in procedure C18.1 as an Engineered'SafeguardsiSupport' as evi'enced by the following examples:

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System, 1.

On October.3, 1994, the D6 safeguards;ventilationi system was removed from service for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 38 minutes, without prior authorization to-enter an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> LCO for safeguards buses:No. 26, 221',

and 222.

2.

On-October 3, 1994, the D6 safeguards ventilation system was removed.from' service for approximately 20' seconds, without-prior authorization to enter an 8 hour:

LCO for safeguards buses No.- 26,'221, and 222.

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

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Attachment:

December 124 1994 P ge 2.of 6 1

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Response to Violation Backaround

.i On August'19, 1993, a violation was cited for allowing.both-trains of ventilation for the:D5/D6 Diesel Generator Building to be out of service for over 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.

The violation resulted from.

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our failure to provide operators'with adequate. guidance to implement the definition of operability relative to essential support equipment.

Our response to that violation included' several corrective actions, including the development of procedural guidance (new procedure C18.1, Engineered Safeguards Equipment Support' Systems) for the definition and treatment of essential support equipment.

On May 6, 1994, a violation was cited for removing a piece of essential support equipment from service without prior authorization.

This violation resulted from our failure to adequately communicate the revised requirements regarding treatment of essential support equipment to plant personnel.

Corrective actions in response to this violation included better labeling, and.better administrative instructions and training.-

On October 3, 1994, during preventive maintenance on D6. Diesel Generator, we experienced 2 events in which essential support equipment,was' removed from service without prior authorization.

Cause of the first event was verbal miscommunication'between a worker and a. Shift Supervisor.

Cause of the second event was inadequate review of a work package during its preparation.

.The' causes of'these events are different from those that caused the previous violations; it is not likely that corrective actions taken in response to the previous violations would'have prevented the October 3, 1994, events.

Correctivefactions have been formulated to address the October 3, 1994, events..In addition, further corrective actions are proposed that will improve our-definition and treatment of essential support equipment in general.

In response to the October 3, 1994, events, a review team was immediately formed to assess the effectiveness of corrective actions from the previous events, to recommend corrective l actions for this event and to determine what broader corrective, actions were needed.

The root cause analyses previously performed for each of the separate occasions of Engineered Safety Feature (ESP) inoperability due to unavailability of. essential support systems.

were reviewed for correctness of causes' identified and appropriateness of corrective actions to the root causes.

As a result of these reviews several areas for improvement were found which, if implemented, could enhance safe operation of the plant.

In the corrective action sections, we outline those actions we have taken or plan to take regardless of whether or not the concern being addressed was a contributing cause to this

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. Attachment December 12, 1994 Page.3.of 6 r ' violation.

In this way, we believe that we are being responsive to the' concern for a comprehensive approach to the support system issue.

Reasons for Violation In the first instance of the violation, the reason that the limiting condition for operation was entered without authorization was a misunderstanding of verbal communications.

A mindset on the part of the worker and distraction of the Shift Supervisor were contributing factors.

When the worker called the control room to obtain permission to turn off the Diesel Generator Building Supply and Return Fans, the Unit 1 Shift Supervisor took the call in the Unit 2 Shift Supervisor's absence.

The worker expected that permission would be granted since D6 Diesel Generator was already out of service for preventive maintenance.

During the phone conversation, the Unit 1 turbine / generator received a high vibration alarm and the Shift Supervisor terminated the conversation. The Shift Supervisor believed that permission had not been given. The worker believed that permission had been granted, and turned the fans off.

Later, an engineer was touring the building and noticed that the sound level was lower than expected, determined that the fans were off and contacted the control room.

Operators restarted the fans.

The total time the fans were off in this case was approximately one hour and 38 minutes.

During this entire time, a standby fan would have started at a temperature of approximately 100 degrees F and would have prevented any room or equipment overheating under worst case conditions.

The force driving workers to want to shut off these fans on occasion is the high noise level caused by fan operation.

Efforts are being made to determine if the noise level can be reduced by modifying the system, the fans, or by relying on an automatic start feature.

This would reduce the challenges to the barriers erected or being erected to prevent inoperability of engineered safety features via this essential support system.

Cause of the second instance was inadequate review of a work package during its preparation.

Preventive maintenance was still being performed on D6 Diesel Generator.

A step in the procedure called for a DC breaker to be opened to provide worker protection.

The specified breaker supplies control power to several components, including Nos. 22 and 24 Diesel Generator Building Supply and Return Fans.

The fact that the breaker supplies control power to the fans was not recognized by the procedure preparer, and so the workers did not espect the fans to stop.

When the breaker was opened, the fans stopped.

The workers recognized this and re-closed the breaker immediately and the fans restarted.

The total time the fans were off in this instance was approximately 20 seconds.

During worst case conditions, equipment qualification is not challenged by high 4

temperature until about 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> into the loss of ventilation l

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-Actualf..outd6oritemperaturefat(the; time of this eventi W/ e would'havaiextendedJthis? time'.

m; i,.Theiprocedure being'usedishould have'provided, worker' protection'

,,i fin such a?way that;theJfans. remained: energized,,or alternatively,:

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lprovided for authorization'for entry!into the? appropriate.

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rlimitingacondition'forl operation..

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l l Corrective stans taken and results achieved 1

The'D5 and'D6 preventive' maintenance procedures involved lhave.

been' revised to' provide the' desired isolation provisions to,

,H protect-workers while maintaining DieselLGenerator;Buildingi

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Supply and Return Fan' operability.

The remaining:related procedures-have been' reviewed and changes l submitted as H

a appropriate.

1 All ' stock isolation 8 ' tables in the safety tag databaae'for these l

procedures have been reviewed te.r..wi. operability of the' j

support systems is ma'intainer..

q During evaluation of the event, it was notedi hat.the t

' nomenclature of some computer alarms associated'with'the D5:and 1

D6' Diesel' Generators and.their support'equipmentLneeded more precise wording. These descriptions have.been revised:to correct:

deficiencies.

C18.1, Engineered Safeguards Equipment Support Systems,ihas;been revised to include the use of actual equipment l descriptions.as l

given on. equipment labels.

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.The alarm. response procedures relating to-D5/D6 andztheir supportl systems have'been enhanced.

A letter.was issued'by the Plant ManagerLemphasizing'that' permission must be'obtained from the-control ~ room before non-1 operations personnel'can manipulate any equipmentcor? controls,.

4 except as specified in a procedure that has:been' authorized'for'

.I A. separate letter.from the Plant: Manager'emphasizednthe j

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requirements for accurate' communications.-

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A lesson plan pertaining to D5/D6. ventilation and'C18.1,

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Engineered Safeguards Equipment Support Systems,.was developed.

o Training of plant work. groups was conducted;

The.importance of performing thorough and' complete reviews usihg '

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all applicable electrical schematics, drawings, flow di. grams,1

.etc., has been emphasized with engineering personnel-wh.i write or review procedures and work packages'.

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Personnel involved with the violations cited'have been counseled.

INPO has been consulted for information concerning best practices for communicating new operating requirements to plant personnel.

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A[ project has been-developed;to produce a matrix.'of'all: support j

CsystemsJthat are' essential.for operability and=their related ESF * '

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Iequipuent'. As thia matrix is: developed, C18.1, Engineered

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Safeguards' Equipment Support Systems, willibe; revised and 1

1 l training provided to appropriate personnel. Caution orJ.

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information labels.will be placed-on or near switches that' control, essential; support system equipment. JIn the; interim,'the m,

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Shift Manager;reviev.of pre-planned; entries:into limiting 1

' conditions for operations is being supplemented by reviews by thel g

x. Work Request 'Authorisation Coordinators : (WRACs).. The WRAce,are:

.i highly experienced engineering superintendents andLwill' provide.

additionalJaxpertise: relating to emerging issues;thatIrelateito, l

essential support systems and ESF operability'

'r SWI-O-24, Operations Section Communications' providesLguidance on

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communications within the operations group.This SWI will be.

revised to require compliance by other groups when communicating a

with the control room.

l Simulator instructors and shift management will stress' proper' t

phone communication with operations personnel when simulator' scenarios require phone communications with outplant; operators or other departments.

This emphasis will be incorporated into training cycle 94-09.

Operations will evaluate the

• chain of command

• to be used when.

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one of the units

• Shift Supervisor is not in the control. room.;

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Variations in nomenclature on drawings associated'with DS/D6 and O

associated equipment' will be corrected.

l We will consider establishing an operating' philosophy for Dieseli j

Generator' Building ventilation based on a heatup'~ analysis.

j The capability of the ERCS alarm functions associated with'DS/D6 and related equipment will-be evaluated'to)see it; changes can;be

'1 made to give added importance to alarms that would more

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appropriately relate support' system' alarms with the ESF they.

support.

In addition to the training already conducted, each department (Operations, Maintenance, Engineering, Radiation Protection,'and Nuclear Generation Services) will evaluate'their needs for.

training and submit appropriate requests for training in the.

following areas:

DS & D6 Ventilation systems and operability requirements Procedure C18.1, Engineered Safeguards Equipment Support Systems l

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'IAttachment December 12,.19M

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' consideration.is'being given to requiring'use'of' safety tags'to

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. remove. normally operating equipaent from service during the -~

1 iT interin' period of-matrix development'and implementation.

L Date when full como11ance will be achievedL u

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/Fullicompliance'was ach'ieved4 at 2032 hours0.0235 days <br />0.564 hours <br />0.00336 weeks <br />7.73176e-4 months <br /> on October 3,-1994

-when power.was restored'to the~ control' circuitry for Nos.'22.and

- 24 Diesel Generator Building' Supply'and Return Fans'and the fans a

' restarted.

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