L-PI-08-038, Supplement to License Amendment Request (LAR) to Revise Containment Spray Nozzle Surveillance Requirements (R)
| ML081290287 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/07/2008 |
| From: | Wadley M Nuclear Management Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| L-PI-08-038, TAC MD7362, TAC MD7363 | |
| Download: ML081290287 (5) | |
Text
N Cornmined to Nucl Prairie Island Nuclear Generating Plant Operated by Nuclear Management Company, LLC MAY 0 '7 2008 L-PI-08-038 10 CFR 50.90 U S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant Units 1 and 2 Dockets 50-282 and 50-306 License Nos. DPR-42 and DPR-60 Supplement to License Amendment Request (LAR) to Revise Containment Spray Nozzle Surveillance Requirements (SR) (TAC Nos. MD7362 and MD7363)
Reference:
- 1.
License Amendment Request (LAR) to Revise Containment Spray Nozzle Surveillance Requirements (SR), dated November 19, 2007, Accession Number ML073240086.
In Reference 1, Nuclear Management Company, LLC (NMC) submitted an LAR for the Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2 to replace the current fixed Frequency for testing the containment spray nozzles in SR 3.6.5.8 with a maintenance or event based Frequency. To support the review of Reference I, the NRC Staff has requested additional information which is provided in the Enclosure to this letter. NMC submits this supplement in accordance with the provisions of 10 CFR 50.90.
The supplemental information provided in this letter does not impact the conclusions of the Determination of No Significant Hazards Consideration and Environmental Assessment presented in the November 19, 2007 submittal.
In accordance with 10 CFR 50.91, NMC is notifying the State of Minnesota of this LAR by transmitting a copy of this letter and enclosure to the designated State Official.
Please address any comments or questions regarding this LAR supplement to Mr. Dale Vincent, P.E., at 651 -388-1 121.
171 7 Wakonade Drive East Welch, Minnesota 55089-9642 Telephone: 651.388.1 121
Document Control Desk Page 2 Summary of Commitments This letter contains no new commitments and no revisions to existing commitments.
I declare under penalty of perjury that the foregoing is true and correct.
Executed On MAY 0 7 2008 Michael D. Wadley v
Site Vice President, Prairie Island Nuclear Generating Plant Units 1 and 2 Nuclear Management Company, LLC Enclosures (1) cc:
Administrator, Region Ill, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota
Enclosure The Nuclear Regulatory Commission (NRC) Staff has requested the following additional information to support review and approval of Reference 1.
NRC Question:
The November 19, 2007, letter states that there was a loss of FME [foreign material exclusion] controls on Unit 1 after the last nozzle flow surveillance test. The letter further states that changes were made to the FME program to further assure FME control. (a) What were these changes? (b) What testing or other compensatory measures were taken to ensure that no blockage will occur in the future based on this loss of FME control?
Nuclear Management Company, LLC (NMC) response:
During the containment spray system full flow test line piping installation on Unit 1 during the 2004 refueling outage, foreign material entered a portion of the piping system due to a scope change that required in-place machining of some of the system's installed valves. Following this modification, a containment spray system check valve failed its leakage test. The cause was determined to be foreign material contained in the newly installed full flow recirculation line piping. Due to the fact that the manual isolation valves to the spray rings were isolated during the piping installation, no foreign material could have progressed to the containment spray nozzles. The newly installed piping was vacuumed to remove any foreign material by removing valve bonnets to gain access to the affected piping. Corrective Actions under the NMC Corrective Action Program (CAP) were issued to strengthen the FME procedures to further minimize loss of FME control in the future. The same piping modification was installed on the Unit 2 containment spray system in 2005 without any FME concerns. Following this modification, the containment spray system check valves passed their leakage tests.
Since the containment spray system full flow test line modifications in 2004 and 2005, the FME program has been revised to increase controls and provide further compensatory measures, for site work in general, and specifically with respect to the containment spray system. The current site FME procedure implements the following controls for foreign material exclusion during work activities for which foreign material intrusion may be a challenge:
Control materials allowed into the Foreign Material Exclusion Zone (FMEZ).
Assign responsibility for tool and materials control.
Document the use and removal of tools and materials.
Control the introduction of personal objects (such as jewelry, coinage, ink pens or other potentially loose objects) into the FMEZ.
Positively secure all required potentially loose objects (such as, gloves, badges, dosimeters, and glasses) using tape, lanyards or other appropriate devices.
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Enclosure Ensure that these security devices do not have the potential to become introduced into the system or component as foreign material.
Limit access into the FMEZ to necessary personnel only.
Pipe dams and temporary covers are also considered as preventive measures during activities such as grinding, valve lapping or filing. Pipe dams, as with all FME barrier materials, are used in a manner such that they do not become part of the foreign material intrusion problem. Acceptable levels of cleanliness are identified in the work packages. This may include system flushes, inspections or other activities in accordance with plant procedures, industry standards or regulatory requirements. The procedural guidance recommends that Operating Experience from the Prairie Island Nuclear Generating Plant (PINGP) and other plants be reviewed to help determine possible risk areas.
At the start of any work activities that could involve foreign material, an FMEZ boundary is set up and boundary markers are placed. Non-essential material is removed from the FMEZ area. The procedural guidance recommends the area be kept clean and free of unnecessary tools and equipment; unattended openings be covered; and transparent materials be plainly marked because they are difficult to detect and retrieve.
All site personnel and contractors are trained on foreign material exclusion. Continuing training is also given and includes the following topics:
Observed weaknesses Operating experience Lessons learned from outage critiques and normal plant operations Training for infrequent or difficult tasks Reinforcement of management expectations Specifically with respect to the containment spray system, FME requirements are as follows:
If any part of containment spray or caustic addition system is planned to be opened, an FME Plan will be prepared prior to allowing internal access to the associated pump or piping. The Very High level of FME controls is required. (Very High FME requirements are: boundary markers, signage, restricted personnel access, FME monitor, FME briefing sheet, FME log, FMEZ pre-cleaning required, periodic FMEZ inspections, FME barrier devices where possible, and a documented close-out FME inspection). Prior to system closure two independent "As Left" inspections are required to be performed to ensure that all covers (barriers) have been removed and no foreign material is present.
Designation as a system for which Very High level FME control is required is a new requirement for the containment spray system which provides additional compensatory measures to ensure that no FME blockage will occur in the future.
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Enclosure
References:
- 1.
License Amendment Request (LAR) to Revise Containment Spray Nozzle Surveillance Requirements (SR), dated November 19, 2007, Accession Number ML073240086.
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