IR 05000282/2017008

Evaluations of Changes, Test, and Experiments Baseline Inspection Report 05000282/2017008; 05000306/2017008

ML17286B077
Person / Time
Site:	Prairie Island
Issue date:	10/12/2017
From:	Robert Daley Engineering Branch 3
To:	Northard S Northern States Power Company, Minnesota
References
IR 2017008
Download: ML17286B077 (16)

Text

UNITED STATES ber 12, 2017

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 EVALUATIONS OF CHANGES, TESTS, AND EXPERIMENTS BASELINE INSPECTION REPORT 05000282/2017008; 05000306/2017008

Dear Mr. Northard:

On August 11, 2017, the U.S. Nuclear Regulatory Commission (NRC) completed an Evaluations of Changes, Tests, and Experiments inspection at your Prairie Island Nuclear Generating Plant, Units 1 and 2. The enclosed inspection report documents the inspection results which were discussed on September 15, 2017, with Mr. T. Conroy and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The NRC inspectors did not identify any finding or violation of more-than-minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Robert C. Daley, Chief Engineering Branch 3 Division of Reactor Safety Docket Nos. 50-282, 50-306 License Nos. DPR-42, DPR-60 Enclosure:

IR 05000282/2017008; 05000306/2017008 cc: Distribution via LISTSERV

Letter to Scott

SUMMARY

Inspection Report 05000282/2017008, 05000306/2017008; 08/07/2017-08/11/2017;

Prairie Island Nuclear Generating Plant, Units 1 and 2; Evaluations of Changes, Tests, and Experiments.

This report covers a 1-week announced Evaluations of Changes, Tests, and Experiments Baseline Inspection. The inspection was conducted by Region III based engineering inspectors.

The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201

NRC-Identified

and Self Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R17 Evaluations of Changes, Tests, and Experiments

.1 Evaluation of Changes, Tests, and Experiments

a. Inspection Scope

The inspectors reviewed evaluations performed pursuant to Title 10, Code of Federal Regulations (CFR), Part 50, Section 59 to determine if the evaluations were adequate and that prior U.S. Nuclear Regulatory Commission (NRC) approval was obtained as appropriate. The inspectors also reviewed screenings and applicability determinations where licensee personnel had determined that a 10 CFR 50.59 evaluation was not necessary. The inspectors reviewed these documents to determine if:

• the changes, tests, and experiments performed were evaluated in accordance with 10 CFR 50.59 and that sufficient documentation existed to confirm that a license amendment was not required;

• the safety issue requiring the change, tests or experiment was resolved;

• the licensee conclusions for evaluations of changes, tests, and experiments were correct and consistent with 10 CFR 50.59; and

• the design and licensing basis documentation was updated to reflect the change.

The inspectors used, in part, Nuclear Energy Institute 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, to determine acceptability of the completed evaluations, and screenings. The Nuclear Energy Institute document was endorsed by the NRC in Regulatory Guide 1.187, Guidance for Implementation of 10 CFR 50.59, Changes, Tests, and Experiments, dated November 2000. The inspectors also consulted Part 9900 of the NRC Inspection Manual, 10 CFR Guidance for 10 CFR 50.59, Changes, Tests, and Experiments.

This inspection constituted 22 samples of evaluations, screenings, and/or applicability determinations as defined in Inspection Procedure 71111.17-05.

b. Findings

(1) Questions Regarding the Manual Override of the Automatic-Closure Function of Component Cooling System Valves

Introduction:

The inspectors identified an unresolved item regarding manual override of the auto-closure function of Component Cooling System (CCS) valves. Specifically, the inspectors noted that the CCS is not protected from tornado generated missiles during the time when valves CV-39153 & CV-39154 are maintained open to support system alignments.

Description:

The licensee revised Procedure 1C14, Component Cooling System -

Unit 1, to authorize operators to maintain the control switches for the fast-acting valves CV-39153 & CV-39154 in the open position (for up to one minute) when aligning the CCS to provide cooling flow through the 122 Spent Fuel Pool (SFP) Heat Exchanger (HX) and when starting or stopping the standby Unit 1 component cooling pumps.

Updated Final Safety Analysis Report (UFSAR) Section 10.4.2.2, Description, states, in part, A portion of the Unit 1 component cooling piping is located outside of a Class 1 structure and is susceptible to tornado generated missiles. The piping at risk includes part of the supply piping and part of the return piping for the 122 SFP HX. To prevent CCS inventory loss during a postulated tornado event, two air-operated valves on the supply to the HX will automatically close either on a loss of component cooling discharge pressure from the 122 SFP HX or on a low level in the 11 Component Cooling Surge Tank, and two check valves on the return from the HX will close on low pressure in the upstream piping. In support of this UFSAR function, the licensee completed calculation PI-48329-M01 Component Cooling System Response Following 122 SFP HX Isolation, and determined these valves must close within 14 seconds of pipe rupture to avoid loss of CCS inventory that would result in loss of CCS functions. Additionally UFSAR Section 10.4.2.3, Performance Analysis, states, in part, Leakage from the CCS can be detected by a falling level in the component cooling surge tanks. Redundant air operated valves on the Unit 1 component cooling supply to the 122 SPF HX will automatically close either on a loss of component cooling discharge pressure from the 122 SFP HX or on low surge tank level.

During alignment of the CCS to the SFP HX or during start/stop of the standby Unit 1 component cooling pump, a system pressure transient occurs that triggers automatic closure of the CV-39153 and CV-39154 valves, which then requires additional operator actions to reopen these valves to restore the CCS functions. Therefore to avoid this condition, on August 31, 2016, and September 28, 2016, the licensee issued Revisions 43 and 44, (respectively) to Procedure 1C14, Component Cooling System-Unit 1, to allow operators to maintain the CV-39153 and CV-39154 valve control switches in the open position for up to 1 minute when aligning the CCS to provide cooling flow through the 122 SFP HX and when starting or stopping the standby Unit 1 component cooling Pump (11 or 12 CC pump).

The inspectors noted that the CCS is not protected from tornado generated missiles during the time when valves CV-39153 & CV-39154 are maintained open to support system alignments as previously described. The inspectors determined that further review is needed to determine if Technical Specifications are met during the period when control valves CV-39153 & CV-39154 are maintained open. This issue is unresolved pending further review by NRC Staff. (URI 05000282/2017008-01, Questions Regarding the Manual Override of the Automatic-Closure Function of Component Cooling System Valves)

4OA2 Problem Identification and Resolution

.1 Routine Review of Condition Reports

a. Inspection Scope

The inspectors reviewed 8 corrective action process documents that identified or were related to 10 CFR 50.59 evaluations. The inspectors reviewed these documents to evaluate the effectiveness of corrective actions related to evaluations of changes, tests, and experiments. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problems into the corrective action system. The specific corrective action documents that were sampled and reviewed by the inspectors are listed in the attachment to this report.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings

.1 Exit Meeting Summary

On September 15, 2017, the inspectors presented the inspection results to T. Conroy, and other members of the licensee staff. The licensee personnel acknowledged the inspection results presented and did not identify any proprietary content. The inspectors confirmed that all proprietary material reviewed during the inspection was returned to the licensee staff.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

S. Northard, Site Vice President

M. Murphy, Regulatory Affairs

M. Emanuelson, Regulatory Affairs Analyst

J. Kivi, Regulatory Affairs Manager

J. Bjorseth, Engineering Director

J. Koenig, System Engineering

J. Conners, Fleet Design Engineering Support

T. Holt, Operations

N. Bibas, Equipment Reliability Manager

A. Ward, Regulatory Affairs

T. Borgen, Operations

E. Blondin, Design Engineering Manager

F. Sienczak, Senior Licensing Engineer

R. Adams, Radiation Protection

T. Dendinger, Design Engineering Supervisor

H. Buttenworth, Director Business Support

D. Shields, Chemistry

R. Waterman, System Engineer

J. Loesch, Senior Reactor Operator

J. Hill, IT Manager

B. Scholberg, Design Engineer

U.S. Nuclear Regulatory Commission

R. Daley, Branch Chief

L. Haeg, Senior Resident Inspector

P. LaFlamme, Resident Inspector

LIST OF ITEMS

Opened

05000282/2017008-01 URI Questions Regarding the Manual Override of the Automatic-Closure Function of Component Cooling System Valves Closed and

Discussed

None