05000282/FIN-2012007-03
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Finding | |
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| Title | Lack of Design Basis Information for Steam Exclusion Damper Leakage |
| Description | An unresolved item was identified by the inspectors due to a lack of steam exclusion (SE) damper leakage design basis information, questions regarding the adequacy of SE damper testing, the functionality of the SE system, and the operability of safety related equipment protected by the dampers following a high energy line break (HELB) event. In 1998 the licensee identified concerns regarding the ability of the SE system dampers to meet the leakage rate described in the USAR and the deterioration of non-metallic gears due to environmental conditions. These issues were documented as Nonconformance Reports 19981361 and 19981104. The licensee initially planned to disposition the conditions as use as is conditions until a revised HELB analysis was completed and the SE dampers were replaced. On October 7, 2009, the licensee initiated AR 1201589 to document that the activities needed to disposition the conditions described above as use as is conditions had not been completed. The licensee reviewed operability recommendations, engineering change records, and 10 CFR 50.59 screenings and evaluations and were unable to find any documents which evaluated the condition of the SE dampers as acceptable. The licensee screened AR 1201589 as a B level corrective action document. No apparent or root cause evaluation was assigned. The screening team concluded that the equipment conditions described in the 1998 Nonconformance Reports should be classified as operable but nonconforming conditions since they had not been corrected. As part of this inspection, the inspectors reviewed the licensees resolution of AR 1201589. The inspectors identified the following: The licensee had not used the operability/functionality process described in Procedure FP-OP-OL-01, Operability/Functionality Program, when classifying the SE damper conditions as operable but nonconforming in 2009; The failure to use the process described in Procedure FP-OP-OL-01 resulted in someone other than the shift manager approving the operable but nonconforming decision; A formal operability recommendation did not exist; and the status of the SE system dampers should have been classified as functional but nonconforming rather than operable but nonconforming. Corrective action document 1201589 also clarified that the SE damper leakage rate described in the USAR was a manufacturing specification rather than design basis information. The inspectors reviewed the most recent SE system health report and found that it also contained information which indicated that design basis information regarding the amount of SE damper leakage that could exist following a HELB did not exist. A large contributor to the lack of this design basis information was due to the fact that the 1998 HELB analysis remained incomplete as of August 10, 2012. Based upon this information, the inspectors were concerned that the licensees monthly SE damper testing may not be adequately verifying the functionality of the SE system. The inspectors were also concerned that assumptions used in currently open operability recommendations regarding the heat up of the battery rooms, the auxiliary feedwater pump rooms, the D1 and D2 emergency diesel generator rooms and several other areas may not be adequate to ensure that the equipment in these rooms would remain capable of performing their specified safety functions following a HELB event. The licensee documented the inspectors concerns in ARs 1345879, 1347752, and 1349909. At the conclusion of the inspection, the shift manager had designated the SE dampers as functional but nonconforming due to the lack of design basis leakage criteria and recent SE damper test results which demonstrated that the dampers had appropriately closed when needed. However, the licensee was continuing to review the adequacy of the SE damper test and the assumptions in the currently open operability recommendations. As a result, this issue will be considered unresolved pending an inspection of the licensees review results |
| Site: | Prairie Island  |
|---|---|
| Report | IR 05000282/2012007 Section 4OA2 |
| Date counted | Sep 30, 2012 (2012Q3) |
| Type: | URI: |
| cornerstone | Other |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71152 |
| Inspectors (proximate) | D Mcneil N Shah K Riemer K Stoedter E Sanchez-Santiagok Riemerd Szwarc B Palagi M Phalen R Baker K Stoedter M Speck K Barclay P Laflamme E Sanchez-Santiago J Beavers M Ziolkowski T Daun |
| INPO aspect | |
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Finding - Prairie Island - IR 05000282/2012007 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2012Q3
Self-Identified List (Prairie Island)
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