05000282/FIN-2014003-04
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Finding | |
|---|---|
| Title | Failure to Meet Alternate Source Term Amendment Implementing Requirement |
| Description | An unresolved item (URI) was documented by the inspectors due to the licensee identification of a failure to meet a license amendment implementing requirement on March 27, 2014. In 2011 the licensee submitted an operating license amendment request to the NRC to adopt a new source term. This amendment was referred to as the AST amendment. The licensee performed and submitted radiological calculations to the NRC for review as part of the amendment process. The calculation results were used to show that adoption of the new source term was safe and did not adversely impact the public. The licensees radiological analysis for the steam generator tube rupture (SGTR) event made assumptions regarding whether or not the steam generators over fill. These assumptions were partially based upon the performance of the steam generator water level narrow range instruments since these instruments are used to determine whether any subsequent radiological release would be contained in steam, a combination of steam and water, or just water. Since the licensee relied upon the steam generator water level narrow range instruments as an indication of steam generator over fill (both pre-AST and post-AST), the NRC required that the instruments comply with Regulatory Guide (RG) 1.97. During the NRCs AST amendment review, an NRC reviewer raised questions regarding the qualification of the steam generator water level narrow range instrumentation. Specifically, the reviewer questioned whether the instruments complied with RG 1.97, Revision 2, requirements. The licensee found that the instruments in question were not included in the current RG 1.97 program. The licensee responded to the NRC reviewers question via a Request for Additional Information (RAI) response dated December 8, 2011. Within the RAI, the licensee identified a new commitment to the NRC which stated the following: The Prairie Island Nuclear Generating Plant will revise the plant design and licensing bases to indicate that the steam generator water level narrow range instrumentation is required to meet Regulatory Guide 1.97, Revision 2, requirements. This commitment will be completed prior to implementation of the AST license amendment. The NRC issued the AST amendment on January 23, 2013. The amendment restated the commitment provided above. However, the NRC listed the commitment as an implementation requirement that needed to be completed prior to implementing the AST amendment. The AST amendment was required to be implemented within 90 days following the fall 2013, Unit 2 refueling outage. The Unit 2 refueling outage ended on approximately January 1, 2014. Although the licensee implemented the AST amendment within 90-days of the end of the outage, the licensee identified on March 27, 2014, that they had not revised the plant design or licensing bases to indicate that the steam generator water level narrow range instruments were compliant with Regulatory Guide 1.97, Revision 2. The licensee also indicated that a modification may be required to achieve compliance. The licensee initiated CAPs 1424460 and 1425033 to document this issue. The licensee revised their Technical Requirements Manual to include pre-AST requirements and ensured that all previous testing requirements were met. The inspectors reviewed the manual revision and the testing data and had no concerns. At the conclusion of the inspection period, the licensee was determining whether they planned to move forward with actions needed to make the steam generator water level narrow range instruments compliant with RG 1.97, Revision 2, or propose new actions to the NRC for review and approval. Since the licensees course of action was unclear, and the NRCs acceptance of the licensees actions was unknown, the inspectors considered this issue to be unresolved pending the NRCs review of the licensees future actions. |
| Site: | Prairie Island  |
|---|---|
| Report | IR 05000282/2014003 Section 4OA5 |
| Date counted | Jun 30, 2014 (2014Q2) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | |
| Inspectors (proximate) | B Cushman K Riemer K Stoedter M Phalen P Laflamme P Zurawski S Shahg Hausmang O'Dwyer J Bozga K Riemer L Haeg M Garza M Jones N Feliz-Adorno P Laflamme P Zurawski R Baker S Bell |
| Violation of: | Pending |
| INPO aspect | |
| ' | |
Finding - Prairie Island - IR 05000282/2014003 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2014Q2
Self-Identified List (Prairie Island)
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