IR 05000282/2012009

IR 05000282-12-009; 10/29/2012 - 11/16/2012; Prairie Island Nuclear Generating Plant; Unit 1; Post-Approval Site Inspection for License Renewal

ML12363A155
Person / Time
Site:	Prairie Island
Issue date:	12/28/2012
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Jeffery Lynch Northern States Power Co
Thomas Bilik
References
IR-12-009
Download: ML12363A155 (17)

Text

December 28, 2012

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNIT 1 - NRC POST APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000282/2012009

Dear Mr. Lynch:

On November 16, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Prairie Island Nuclear Generating Plant, Unit 1. The enclosed inspection report documents the inspection results, which were discussed on November 16, 2012 with Mr.

J. Sorensen and other members of your staff.

This inspection was an examination of activities conducted under your renewed license as they relate to the completion of commitments made during the renewed license application process and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The NRC staff did not identify any instances of incomplete commitments with respect to timeliness or adequacy.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-282, and 50-306 License Nos. DPR-42, and DPR-60

Enclosure:

Inspection Report 05000282/2012009 w/Attachment: Supplemental Information

REGION III==

Docket No:

50-282 License No:

DPR-42 Report No:

05000282/2012009 Licensee:

Northern States Power Company, Minnesota Facility:

Prairie Island Nuclear Generating Plant, Unit 1 Location:

Welch, MN Dates:

October 29, 2012 through November 16, 2012 Inspectors:

T. Bilik, Senior Reactor Engineer (Lead)

M. Jones, Reactor Engineer Approved by:

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000282/2012009; 10/29/2012 - 11/16/2012; Prairie Island Nuclear Generating Plant;

Unit 1; Post-Approval Site Inspection for License Renewal The inspection was conducted by two regional based inspectors. No instances were noted of incomplete license renewal commitments with respect to timeliness or adequacy. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006. The NRCs program for overseeing the safe operation of commercial nuclear power reactors as described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

A.

No violations were identified.

NRC-Identified

and Self-Revealed Findings B.

No violations were identified.

REPORT DETAILS

Unit 1 was in a refueling outage during the period of this inspection.

OTHER ACTIVITIES

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.1 Other Activities

a.

Post-Approval Site Inspection for License Renewal (Phase I) - IP 71003

(1) Inspection Scope The inspectors discussed the identification of new SSCs, under the purview of Title 10 of the Code of Federal Regulations (CFR) 54.37(b), with the licensees license renewal staff. The licensee personnel indicated a review for newly identified SSCs is currently being conducted but no new components to date that should have been within the scope of the license renewal program have been identified. Any newly identified SSCs that may subsequently be identified will be reviewed during Phase II of IP 71003.

Review of Newly Identified Structures Systems and Components (SSC)

(2) As part of reviewing the Aging Management Programs (AMPs) associated with the commitments, the inspectors identified that the licensee had performed a number of commitment revisions related to license renewal. These commitment changes and any others that may be generated will be reviewed during the Phase II portion of IP 71003.

Review of Revised Commitments

(3) The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, observed non-destructive examination (NDE) activities of structures and components, including those not accessible during power operation, and observed the activities described below to verity the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors verified the licensee implemented the outage related aging management programs included in NUREG 1960, NRC Safety Evaluation Report Related to the License Renewal of Prairie Island Nuclear Generating Plants Units 1 and 2, in accordance with 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors also verified a selected sample of corrective actions taken as a result of the license renewal inspection.

Review of Commitments

b. Findings and Observations

The inspectors reviewed portions of the commitments below, which are referenced to Appendix A of the Safety Evaluation Report (SER). Activities observed related to these commitments are also listed.

Results of Detailed Reviews

(1) The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD Program is an existing program. The program is implemented in accordance with the requirements of 10 CFR 50.55a, with specified limitations, modifications and NRC-approved alternatives, and utilizes ASME Section XI, Subsections IWB, IWC, and IWD, 1998 Edition including the 1998, 1999 and 2000 Addenda, for the current inspection interval.

It provides for condition monitoring of ASME Class 1, 2 and 3 pressure-retaining components, their welded integral attachments and bolting. Leakage tests are periodically performed on Class 1, 2, and 3 pressure retaining components. The program also provides component repair and replacement requirements in accordance with ASME Section XI. Class 1 dissimilar metal welds in nozzles and Class 1 and 2 welds in piping are inspected in accordance with the Risk Informed Inservice Inspection (RI-ISI) Program as described in the Electric Power Research Institute Topical Report TR-112657, Rev. B-A, "Revised Risk Informed Inservice Inspection Evaluation.

(B.2.1.3) American Society of Mechanical Engineers (ASME) Code,Section XI Inservice Inspection, Subsections IWB, IWC, and IWD

The inspectors conducted interviews and reviewed documentation. The inspectors also observed a number of NDE examinations as part of the RI-ISI Program. These included risk-informed ultrasonic examination (UT) of four Class 2 safety injection piping and 11 discharge 3 pipe welds (W-2, W-3, W-4, and W-5) performed under work order (WO)408560. The inspectors had no concerns with the observed activities.

(2) The ASME Section Xl, Subsection IWE Program (IWE Program) is an existing program for the condition monitoring of Class MC pressure-retaining components and their related items, including integral attachments, seals, gaskets, moisture barriers, and pressure-retaining bolting. The program monitors for aging effects by performing visual examinations (general, VT-3, VT-I) of the Class MC components and their related items.

Visual (VT-1) or volumetric examinations, as applicable, are performed on components that require augmented examination. The program is implemented in accordance with the requirements of 10 CFR 50.55a and ASME Section Xl. Subsection IWE Leak testing is also periodically performed to detect leakage from the pressure-retaining Class MC components in accordance with the licensees 10 CFR 50, Appendix J Program.

(B.2.1.4) ASME Code Section XI, Subsection IWE

The inspectors reviewed completed WO 466019, which performed VT-3 examinations of the accessible containment surface including bolted connections to verify the integrity of these components. The inspectors had no concerns with the observed activities.

(3) Commitment Item 7 specified the existing compressed air monitoring program was credited for license renewal and the program would be enhanced prior to the period of extended operation. The inspectors reviewed the licensing basis, program basis document, implementing procedures, and instrument air quality guidance provided in ISA S7.0.01-1996 procedures to verify the program is being implemented on Unit 1. The inspectors conducted interviews and reviewed operations procedures to ensure measures were in place to ensure air quality would be maintained after commitments are completed. The inspectors had no concerns with the reviewed activities.

(B.2.1.10) Compressed Air Monitoring Program (Commitment 7)

(4) The Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Program is a new inspection program that conducts a one-time test on a representative sample of electrical cable connections (metallic portions) to confirm the absence of aging effects (loose connections). The specific type of test performed will be determined prior to the initial test, and is to be a proven test for detecting loose connections, such as thermography, contact resistance testing, or other proven test justified in the application. Cable connections terminating within an active or passive device/enclosure assembly from external sources are within the scope of this program. Cable/wiring connections terminating within an active or passive device/enclosure assembly from internal sources are not within the scope of this program.

(B.2.1.11) Electrical Cable Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Commitment No. 8)

This aging management program manages the aging effects of loose connections and electrical failure from the following aging stressors: thermal cycling, ohmic heating, electrical transients, vibration, chemical contamination, corrosion, and oxidation. The representative sample includes connections of various voltage applications (medium and low voltage), circuit loading and location (high temperature, high humidity, vibration, etc.). The technical basis for the sample selections will be documented. If an unacceptable condition is identified, the corrective action program will evaluate additional requirements.

To verify the programs effectiveness, the inspectors reviewed program documents and electrical enclosure examination results for walkdowns of multiple terminal boxes, junction boxes, and enclosures, including thermography and visual examinations, performed in accordance with completed WO 374391. The inspectors had no concerns with the reviewed activities.

(5) The Flow-Accelerated Corrosion (FAC) Program is an existing program based on the Electric Power Research Institute (EPRI) guidelines in the Nuclear Safety Analysis Center (NSAC)-202L-R3 for carbon steel and bronze components containing high-energy single phase or two phase fluids.

(B.2.1.17) Flow Accelerated Corrosion (FAC)

With exceptions, it is consistent with the recommendations of NUREG-1 801, Chapter Xl, Program Xl. M17, Flow-Accelerated Corrosion. The use of NSAC-202L-R3 is an exception to the NUREG-1801 recommendation which references the use of NSAC-202L-R2 (April 1999). NSAC-202L-R3 is the most recent revision of this document and it provides more prescriptive guidance based on the latest industry operating experience.

Use of the current guideline is an acceptable method to maintain the FAC susceptible systems. The program manages loss of material due to flow-accelerated corrosion in piping and components by

(a) conducting an analysis to determine critical locations, (b)performing baseline inspections to determine the extent of thinning at these locations, and

(c) performing follow-up inspections to confirm the predictions of the rate of thinning, or repairing or replacing components as necessary.

The inspectors observed two surveillances credited for the FAC program. These surveillances, conducted under WO 426108, performed an ultrasonic thickness measurement of piping elbows for portions of the condensate and heater drain systems to detect any material loss as a result of FAC. The inspectors had no concerns with the observed activities.

(6) Commitment Item 15 specified that the existing fuel oil chemistry program was credited for license renewal and that the program would be enhanced prior to the period of extended operation. The Fuel Oil Chemistry Program includes:

(1) periodic sampling and testing of stored fuel oil and testing of new fuel oil in accordance with plant Technical Specifications and selected industry standards to confirm water, sediment and contaminants remain below limits of concern for corrosion to occur;

(2) periodic testing of fuel oil storage tanks for the presence of water;

(3) periodic integrity testing of underground storage tanks and external visual inspections of aboveground storage tanks to confirm leakage is not occurring; and,

(4) one-time inspections of selected tank bottom and piping locations, using ultrasonic testing, to be performed prior to the period of extended operation.

(B.2.1.19) Fuel Oil Chemistry Program (Commitment 15)

The inspectors reviewed the licensing and program basis documents, scheduled and completed work orders, and implementing procedures to verify that the program is being implemented for Unit 1. The inspectors reviewed program documents to ensure the licensee plans to adequately address the material condition and bottom thickness of the 11 fuel oil storage tanks at an acceptable periodicity in accordance with NUREG-1960, Safety Evaluation Report. The inspectors had no concerns with the reviewed activities.

(7) The One-Time Inspection AMP is a new program which the licensee committed to implement prior to the period of extended operation. The AMP provides assurance through sampling inspections using NDE techniques that aging effects such as cracking, loss of material, and heat transfer degradation are not occurring in areas protected by chemistry controlled environments or is progressing so slowly as to have negligible effect on the intended function of the structure or component, and in areas not required to be managed by an aging management program. If aging effects are identified that could adversely impact an intended function prior to the end of the period of extended operation, additional actions will be taken to correct the condition, perform additional inspections, and/or perform periodic inspections as needed.

(B.2.1.29) One-Time Inspection Program (Commitment No. 23)

To verify the programs effectiveness the inspectors interviewed the program owner and accompanied the licensee to observe VT-1 examinations of valve body HV-1-1, HV-1-9, HV-1-17, feedwater heater shell to 1A Condenser vent valves, per WO 462514, WO 462516, and WO 462517 respectively. The inspectors also viewed the VT-1 examination of the internal surfaces of the main steam sample line valve bodies SS-2-2 and SS-2-3, and related tubing in accordance with WO 462552 and WO 462553 respectively.

In addition, the inspectors reviewed completed WO 345095, which credits the One-Time Inspection Program to perform a one-time enhanced visual examination (VT-1) of the chemical volume and control system (CVCS) side of the letdown heat exchanger tubes, tube sheet and channel head for evidence of cracking of stainless steel (SS). Lastly, the inspectors reviewed completed WO 403189, which credits the One-Time Inspection Program to perform a one-time visual examination (VT-3) of the tubes (internal and external) of the 12 auxiliary feedwater pump lubricating oil cooler for evidence of crevice corrosion, pitting, and fowling of a SS component in lubricating oil and treated water environments. The inspectors had no concerns with either the observed or reviewed activities.

(8) The One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program is a new program that provides additional assurance that either aging of Class 1 small-bore piping is not occurring or the aging is insignificant, such that an aging management program is not warranted. This program addresses pipe, fittings, and branch connections in accordance with the NUREG-1801, Chapter XI, Program XI.M35, One-Time Inspection of ASME Code Class 1 Small-Bore Piping.

(B.2.1.30) One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program (Commitment No. 24)

In Commitment No. 24, the licensee stated:

A. One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program will be completed prior to the period of extended operation except as noted in Part B of this commitment with program features described in the license renewal application Section B.2.1.30. The commitment also stated the following examinations of ASME Code Class 1 small-bore piping socket welds will be performed prior to the period of extended operation:

-

Volumetric examinations of two socket welds on Unit 1 and three socket welds on Unit 2, or

-

Destructive examination of two socket welds per Unit.

B. Socket weld examinations required by the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program, not performed prior to the period of extended operation, will be performed within three years of each Unit entering the period of extended operation.

Note the examination sample requirements of A and B have already been satisfied by completed UT exams.

The Class 1 Small-Bore Piping Program monitors for aging effects by performing one-time volumetric examinations on a sample of butt welds in Class 1 piping (pipe, fittings, and branch connections) less than 4 inch nominal pipe size (NPS 4) and greater than or equal to 1 inch nominal pipe size (NPS 1). In addition, the program will perform one-time volumetric examination of socket welds using a qualified inspection methodology, if available (Newly qualified volumetric socket weld inspection methodology is currently available to facilitate the examination of the socket welds). The one-time inspections are performed to detect cracking due to thermal and mechanical loading or intergranular stress corrosion at locations that are determined to be the most susceptible to cracking using the site specific NRC approved risk informed ISI Program. All inspections necessitated by this program will be completed prior to entering the period of extended operation.

To verify the programs effectiveness, the inspectors reviewed program documents and UT examination results for multiple small bore piping exams performed in accordance with completed WO 372283 and WO 311486. The inspectors had no concerns with either the observed or reviewed activities.

(9) The inspectors reviewed and observed licensee activities to implement the existing Protective Coating Monitoring and Maintenance Program:

(1) visual inspection of Service Level I coatings near sumps or screens associated with the emergency core cooling system;

(2) pre-inspection review of previous reports to identify trends for the program; and

(3) analysis of coating failures to determine reasons for failures.

(B.2.1.32) Protective Coating Monitoring and Maintenance Program (Commitment No.

25)

The Protective Coating Monitoring and Maintenance Program provide for aging management of Service Level I coatings inside primary containment. Service Level I coatings are used in areas where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown. In addition, this program also provides guidance on the procurement and maintenance of Service Level I coatings. The program is consistent with the ten elements of Aging Management Program XI.S8, "Protective Coating Monitoring and Maintenance Program," specified in NUREG-1801, without exceptions or enhancements.

The inspectors reviewed program documents and observed containment coating examinations per direction of procedure SP 1834, Unit 1 Containment Coating Inspection. The inspection consisted of areas painted within the containment vessel that included flooring, tanks along with associated supports, piping, and walls as directed by procedures. The inspectors had no concerns with the reviewed activities.

(10) Commitment No. 29 specifies the licensee will develop and implement the program prior to the beginning of the period of extended operation. The Selective Leaching of Materials Program is a new program to perform one-time visual inspection and hardness test, or other suitable detection technique, on selected components that may be susceptible to selective leaching. The program is consistent with the ten elements of aging program XI.M33, "Selective Leaching of Materials," specified in NUREG-1801 with one exception. NUREG-1801 indicates the Selective Leaching of Materials AMP includes a one-time hardness measurement of a selected set of components. The licensees program specifies alternative detection techniques may be used instead of, or in addition to, visual inspection and hardness testing for the detection of selective leaching.

(B.2.1.36) Selective Leaching of Materials (Commitment No. 29)

Selective leaching is a corrosion process resulting in the selective removal of one constituent of an alloy. The most common forms of selective leaching are graphitization in gray cast iron and dezincification in brasses and certain bronze alloys. The one-time examinations will determine whether loss of material due to selective leaching is occurring, and whether the process will affect the ability of the components to perform their intended function(s) for the period of extended operation. If the examinations reveal selective leaching could affect the license renewal intended function of a system or component prior to the completion of the period of extended operation, further visual inspections and hardness testing, or other detection techniques, will be conducted to assess the extent, if any, of degradation on other system components. Any corrective actions will be implemented through the Corrective Action Program.

To verify the programs effectiveness, the inspectors observed a selective leaching examination performed in accordance with WO 434046-01 on the body of a condenser inlet valve, MD-3-5. In addition, the inspectors reviewed program documents and VT-1 examination results performed in accordance with completed WO 422735, VT-1 of the brass valve body of valve 2FP-88-1, WO 393025, VT-1 of a diesel generator air coolant heat exchanger tube and tube sheets (035-052 tubes). The inspectors had no concerns with either the observed or reviewed activities.

(11) Commitment Item 30 specified the existing structures monitoring program was credited for license renewal and would be enhanced prior to the period of extended operation.

The structures monitoring program was an existing program that provided for aging management of structures, supports and structural components, including bolting, within the scope of License Renewal. The inspectors reviewed the program basis documents, and inspection records to verify that the program is being implemented for Unit 1.

(B.2.1.38) Structures Monitoring Program (Commitment 30)

The inspectors reviewed inspection results from recent shield building inspections and conducted a walkdowns of the shield building annulus region with the program owner.

Inspectors reviewed the operating experience component of the aging management program and determined additional follow up will be necessary during the Phase 2 License Renewal inspection to ensure operating experience is being incorporated and assessed at an appropriate threshold, in accordance with the licensees corrective actions program.

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.1 Management Meetings

On November 16, 2012, the inspectors presented the inspection results to Mr. J. Jensen and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed that none of the potential report input discussed was considered proprietary.

Exit Meeting Summary

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

J. Jensen, Acting Site Vice-President

Licensee

K. Vincent, Engineering Supervisor

T. Downing, ISI/Engineering

LIST OF ITEMS

OPENED, CLOSED AND DISCUSSED

None

Opened

None