L-PI-16-058, Special Report: Timely Restoration of Operability of Explosive Gas Monitoring Instrumentation

Special Report: Timely Restoration of Operability of Explosive Gas Monitoring Instrumentation

ML16208A065
Person / Time
Site:	Prairie Island
Issue date:	07/22/2016
From:	Northard S Northern States Power Company, Minnesota, Xcel Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-PI-16-058
Download: ML16208A065 (5)

Text

1717 Wakonade Drive Welch, MN 55089 Xcel Energy@

RESPON IBLE BY NATUR 800.895.4999 xcelenergy.com L-PI-16-058 JUL 2 2 2016 ODCM 3.8 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Operating License Nos. DPR-42 and DPR-60 Special Report: Timely Restoration of Operability of Explosive Gas Monitoring Instrumentation Pursuant to Section 3.8., Action b, of the Prairie Island Nuclear Generating Plant (PINGP)

Offsite Dose Calculation Manual (ODCM), Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter "NSPM"), submits the enclosed Special Report.

From 9/25/2014 to 10/26/2014, 7/12/2015 to 8/18/2015, and 1/24/2016 to 4/14/2016, less than the minimum required Explosive Gas Monitoring Instrumentation was operable as specified by ODCM Section 3.8. The enclosed Special Report explains why the minimum required explosive gas monitoring instrumentation was not restored to operable status in a timely manner.

lfthere is any question, please contact Dr. Glenn A. Carlson, P.E., at (651) 267-1755.

Summary of Commitments This letter contains no new commitment and no revision to an existing commitment.

Scott Northard Acting Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure (1)

Document Control Desk Page 2 cc: Regional Administrator, USNRC, Region Ill Project Manager, Prairie Island Nuclear Generating Plant, USNRC, NRR NRC Resident Inspector- Prairie Island Nuclear Generating Plant Department of Health, State of Minnesota PI Dakota Community Environmental Coordinator

Enclosure 1 ODCM 3.8b Special Report:

Timely Restoration of Operability of Explosive Gas Monitoring Instrumentation (2 pages follow)

Enclosure 1 to L-PI-16-058 ODCM 3.8b Special Report

Background

The Prairie Island Nuclear Generating Plant (PINGP) Offsite Dose Calculation Manual (ODCM), Section 3.8, specifies that a minimum of two channels of Waste Gas Holdup System Explosive Gas (Oxygen) Monitors shall be operable during system operation.

ODCM Section 3.8, Action b, specifies:

With less than the minimum required explosive gas monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.2. Restore the inoperable instrumentation to OPERABLE status within 30 days and, if unsuccessful, in lieu of a License Event Report, prepare and submit a Special Report to the Commission to explain why this inoperability was not corrected in a timely manner.

The corresponding "ACTION shown in Table 3.2" is ACTION 2 that states:

With the number of channels Operable less than required by the Minimum Channels Operable requirement, operating of this system may continue for up to 14 days. With two channels inoperable, manually isolate the oxygen addition line.

On 5/11/2016, PINGP discovered potential instances exceeding 30 days when less than the minimum required explosive gas monitoring instrumentation channels was operable and for which PINGP submitted no Special Report to the Commission. The issue was entered into the PINGP Corrective Action Program (CAP).

An apparent cause evaluation found that, during the periods 9/25/2014 to 10/26/2014 (31 days, hereafter "Period 1"), 7/12/2015 to 8/18/2015 (37 days, hereafter "Period 2"),

and 1/24/2016 to 4/14/2016 (81 days, hereafter "Period 3"), less than the minimum required explosive gas monitoring instrumentation channels was operable and that PINGP had submitted no Special Report to the Commission for the periods.

Actions Taken to Restore Operability Period 1:

9/25/2014 High readings on 10AT-1119, 121 CTLTC H2 RCMBNR OUTL 02 ANZR, entered into CAP. Work request initiated. Less than minimum required channels operable.

10/26/2014 1OAT-1119 cell replaced and tested satisfactory during surveillance procedure SP 1231, 121 CATALYTIC HYDROGEN RECOMBINER GAS ANALZER FUNCTIONAL AND CALIBRATION TEST. Oxygen restored to 121 Recombiner.

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Enclosure 1 to L-PI-16-058 ODCM 3.8b Special Report Period 2:

7/12/2015 Oxygen monitor 10AT-1112 and 10AT-1119 are removed from service.

Less than minimum required channels operable.

8/18/2015 1OAT-1119 cell is replaced and test satisfactory according to surveillance procedure. 121 Recombiner placed in MANUAL 121 Recombiner placed in AUTO on 8/19/15.

Period 3:

1/24/2016 Flow through 121 Recombiner stopped according to operating procedure C21.3.2, LOW LEVEL WASTE GAS LOOP, unable to restore flow because CV-31922, 121 CTLYTC RCMBNR FEED GAS PCV, not controlling. Work request written on 1/25/16 to replace rupture disc. Less than minimum required channels operable.

2/12/2016 SP 1231 performed unsatisfactory due to bad rupture disc causing no flow through the recombiner.

3/17/2016 Rupture disc replaced on 121 Rcombiner.

3/22/2016 Post maintenance test completed satisfactory.

4/14/2016 SP 1231 completed satisfactory after 10AT-1119 replaced second time.

Why Actions Taken to Restore Operability were not Taken in a Timely Manner An apparent cause evaluation found the apparent cause was site ownership of the ODCM equipment out of service has been weak to ensure the proper tracking method was developed to meet the ODCM Program.

The apparent cause evaluation identified the following contributing causes:

e Standard for system operation and required actions are not clear in the ODCM.

• Administrative work instruction 5AWI 3.6.3, 10CFR and Technical Specification Reporting Requirements, is missing two of the 30-day required special reports for ODCM equipment.

• Operating procedures C21.3.2 and C11, RADIATION MONITORING SYSTEM, do not align with ODCM requirements.

• Equipment identifiers associated with ODCM are missing a Requirement and Regulation designator in the PINGP equipment database similar to emergency preparedness and fire protection equipment.

• Responsibilities for ODCM program ownership are not clearly established.

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