ML20046A915

LER 93-007-01:on 930413,discovered That Valves Required to Mitigate Consequences of Accident Not Included in Section XI ISI & Testing Program.On 930624,identified Six Addl Valve Inappropriately Ommitted from Subj Program.Valves Included

ML20046A915
Person / Time
Site:	Prairie Island
Issue date:	07/26/1993
From:	Hunstad A NORTHERN STATES POWER CO.
To:
Shared Package
ML20046A908	List: ML20046A907 ML20046A915
References
LER-93-007, LER-93-7, NUDOCS 9308020095
Download: ML20046A915 (8)

Text

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NRC FORM 366 U.S. NUCLEA3 RE(13LATC3Y CDPMISSION APPROUED BT (MB No. 3150-0104 (5 92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

LICENSEE EVENT REPORT (LER) FORWARD COMMENTS RECARDING BURDEN ESTIMATE TO THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, (See reverse for required runber of digits / characters for each block) WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC 20503.

FACILITY KAME (1) DOCKET WUMBER (2) PAGE (3) ,

Prairie Island Nuclear Generating Plant U1 05000 282 1 OF 8 TITLE (4)

Discovery That Certain Valves should Be Subiect to ASME Section XI Testing EVENT DATE (5) LER NUMBER (6) REPORT DATE (7) OTHER FACILITIES INVOLVED (8)

SEQUENTIAL REVISION FACILITY NAME DOCKET NUMBER MONTH DAY YEAR YEAR NUMBER WUMBER

• "" *** '* Prairie Island U2 05000 306 4 13 93 93 -- 07 -- 01 07 26 93 0 0 OPERATING THIS REPORT IS SUBMITTED PURSUANT TO THE REQUIREMENTS OF 10 CFR f: (Check one or more) (11)

M:EE (9) N 20.402(b) 20.405(c) 50.73(a)(2)(lv) 73.71(b)

POWER 20.405(a)(1)(1) 50.36(c)(1) 50.73(a)(2)(v) 73.71(c) 100 LEVEL (10) 20.405(a)(1)(li) 50.36(c)(2) 50.73(a)(2)(vil) OTHER 20.405(a)(1)(lii) X 50.73(a)(2)(1) 50.73(a)(2)(vi ii)( A) (specify in Abstract ow 20.405(a)(1)(iv) 50.73(a)(2)(fi) 50.73(a)(2)(viii)(B) 20.405(a)(1)(v) 50.73(a)(2)(iii) 50.73(a)(2)(x) NRC Form 366A) tlCENSEE CONTACT FOR THIS (ER (12)

NAME TELEPHONE NUMBER (include Area Code)

Arne A Hunstad 612-388-1121 CCMPt ETE ONE L INE FOR EACH COMPONENT FAllORE DFSCRIBEV IN THIS REPORT (13) l CAUSE SYSTEM COMPONENT MANUFACTURER CAUSE SYSTEM COMPONENT MANUFACTURER 0 S SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED MONTH DAY YEAR YES SUBMISSION NO (If yes, cocptete EXPECTED SUBMIS$10N DATE). DATE (15)

ABSTRACT (Limit to 1400 spaces, i.e., approximately 15 single-spaced typewritten Lines) (16)

On April 13, 1993 both units were at 100% power. The Design Basis Reconstitution effort for the Feedwater System revealed that certain

. feedwater valves required to mitigate the consequences of an accident were not included in the Prairie Island ASME Section XI Inservice Inspection and Testing Program. These valves should be classified as ASME Code Class 2 valves.

Subsequently, during the current development of the 3rd 10-year Interval Inservice Testing Program, we took an aggressive approach to determine any ,

weaknesses in the current program in order to strengthen the program for the future. We reviewed violations issued against other licensees,  ;

reviewed generic discussions of industry issues, and discussed some j interpretation questions with cognizant NRC Staff. As a result of this '

approach, we identified other ASME Code Class MC valves and six additional i valves which should have been in the current program but were not.

I An evaluation of the available data for each of these valves has been made to determine their operability. The valves will all be tested per the requirements of ASME Section XI and have been included in the 3rd 10-year interval program.

2 NRC FORM 366 (5-92) 93 80200] 90 00 S

1 NRC FORE 1 366A U.S. NUCLEAR RECJLATQ3Y CupWISSICO APPROVED BY OMB CD. 3150-0104 1 (5-92) EXP!RES 5/31/95  ;

EST! MATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNss m 4), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK 1 REDUCT!ON PROJECT (3150-0104), OFFICE OF '

MANAGEMENT AND BUDCET, WASHINGTON, DC 20503.

FACitITY NAME (1) DOCKFT NtMBER (?) (FR NUMBER (6? PAGE (3)

SEQUENTIAL REVISION YEAR

. . NWEE R NWBER Prairle Island Unit 1 2 OF 8 05000 282 93 -- 007 -- 01 TEXT (If more space is recuired. Use additional copies of NRC Form 366A) (17)

EVENT DESCRIPTION On April 13, 1993 both units were at 100% power. The Design Basis Reconstitution effort for the Feedwater System revealed that certain feedwater valves required to mitigate the consequences of an accident were not included in the Prairie Island ASME Section XI Inservice Inspection and Testing Program. These valves should be classified as ASME Code Class 2 valves. This omissio.1 is in violation of Technical Specification 4.2.A.2, which states:

In addition to other specified tests, inservice testing of ASME Code Class 1, Class 2, and Class 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55 (g),

except where specific written relief has been granted by the NRC.

ASME Section XI requires periodic exercising of all valves required to mitigate the consequences of an accident. In this instance, four valves (two per Unit) were not included in the Section XI program as required.

Subsequently, during the current development of the 3rd Interval Inservice Testing Program, we took an aggressive approach to determine any weaknesses in the current program in order to strengthen the program for the future. +

We reviewed violations issued against other licensees, reviewed generic discussions of industry issues, and discussed some interpretation questions with cognizant NRC Staff. As a result of this approach, we identified other ASME Code Class MC valves which should have been in the current program but were not. On June 24, 1993 which was subsequent to the submittal of the 3rd Interval Inservice Testing Program, and based on _'

review of a violation issued against another licensee, we determined that six additional valves were inappropriately omitted from our 2nd Interval Program and were not included in the recently submitted 3rd Interval -

Program. The valves which had been omitted from the program based on earlier erroneous interpretations are listed in the following table:

S U valve 9 valve Name Accident Testing Which Bas Been When Testing Will Y N Function Forformed or Other Basis for Be Perfomed to S I Determining Fuctionality the ASME Section T XI Requirement.s 9

TW 1 32023 11 STEAM CENERAT0rt TO CLOSE Stroked during Integrated Next Unit Cold FEEDWATER ISCLATICN NOTE 5 Safety Injection Test Shutdown FW 2 32028 21 STEAM GENERATOR TO CLOSE Stroked during Integrated Next Unit Cold FEEDWATER ISOLATION NOTE 5 Safety Injection Test Chutdown FW 1 32024 12 STEAM CENERATOR TO CLOSE Strcked during Integrated Next Unit Cold FEEDWATER ISOLATION NOTE 5 Safety injection Test Shutdown

9 MRC FORM 366A U.S. NUCLEAR RECULAT O Y COPMISSICJ APPROVED BY OMB NO. 3150-0106 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS RECARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDCET, WASHINGTON, DC 20503.

FACILITY NAME (1) DOCKET RMRER (2) LER RMBER (6? PAT (3)

SEQUENTIAL REVISION YEAR NUMBER NUMBER Prairie IE. land Unit 1 05000 282 93 -- 007 -- 01 TEXI (It mere space is reouired, use edditional copies of NRC f orm 366A) (17)

S U Valve i Valve Name Accident Testing Which Ene Been When Testing Will Y N Tunction Performed or Other Basis for Be Performed to S I Determining Fuctionality the ASME Section T XI Requirements i

FW 2 32029 22 STEAM GENERATOR TO CLOSE Stroked during Integrated Next Unit Cold TEEDWATER ISOLATION NOTE 5 Safety Injection Test Shutdown CC 1 32095 11 EXCESS LETDOWN INLET TO REMAIN Stroked during Integrated August 1, 1993 HEAT EXCEANGER ISOLATION CLOSID Safety Injection Test NOTE 5 CC 2 32130 21 EXCESS LETDOWN OUTLET TO REMAIN Stroked during Integrated August 1, 1993 EEAT EXCHANGER ISOLATION CLOSED Safety Injection Test NOTE 5 CC 1 31252 11 EXCESS LETDOWN OUTLET TO REMA!N Stroked during Integrated August 1, 1993 EEAT EXCEANGER ISOLATION CLOSED Safety Injection Test CC 2 31253 21 EXCESS LETDOWN OUTLET TO REMAIN Stroked during Integrated August 1, 1993 EEAT EXCHANGER ISOLATION CLOSED Safety Injection Test CC 1 CC-23-1 11 EXCESS LETDOWN INLET NOTE 1 Verified Open; Next Unit Cold EEAT EXCHANGER ISOLATION NOTE 3 Shutdown CHECK CC 2 2CC-23-1 21 EXCESS LETDOWN OUTLET NOTE 1 Verified Open; Next Unit Cold HEAT EXCEANGER ISOLATION NOTE 3 Shutdown CEECK CC 1 32089 11 REACTOR COOLANT PIMP TO CF.ANGE Stroked during Containment Next Unit Cold COMPONENT COOLIN3 INLET POSITION Integrated Leak Rete Test Shutdown NOTE 6 CC 2 32124 21 REACTOR COOLANT PUMP TO CHANGE Stroked during Containment Next Unit Cold CCHPONENT COOLING INLET POSITION Integrated Leak Rate Test Shutdown NOTE 6 CC 1 32091 12 REACTOR COOLANT PLMP TO CHANGE Stroked during Containment Foxt Unit Cold COMPONENT COOLING INLET POSITION Integrated Leak Rete Test Shutdown NOTE 6 CC 2 32126 22 REACTOR COOLANT PUMP TO CHANGE Stroked during Conteinment Next Unit Cold CCHPONENT COOLING TNLET POSITION Integrated Leak Rate Test Shutdown NOTE 6 CC 1 CC-18~1 12 REE~ TOR COOLANT PUMP NOTE 1 Verified Open; Next Unit Cold CCEPONENT COOLING INLET NOTE 3 Shutdown CEECK CC 2 2CC-18-1 22 REACTOR COOLANT PUMP NOTE 1 Verified Open; Next Unit Cold COMPONENT COOLING INLET NOTE 3 Ehutdown CHECK CC 1 CC-18-2 11 REACTOR COOLANT PUMP NOTE 1 Verified Open; Next Unit Cold COMPONENT COOLING INLET NOTE 3 Shutdown CHECK CC 2 20C-18-2 21 REACTOR COOLANT PLEP NOTE 1 Verified Open; Nsxt Unit Cold COMPONENT COOLING INLET NOTE 3 Shutdown CHECK

NRC FORM 366A U.S. OCLEAR REQJLATQ3Y COpMIESIEJ APPROVED BY OMB CA 3250-0104 (5-92) EXPIRES 5/31/95 EST] MATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE thFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION w as m 4), U.S. NUCLEAR REGULATORY COMMIS$10N, WASHlWGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDCET, WASHINGTON, DC 20503.

FACILITY NUtE (1) DOCyIT WLMBER (2) h LER NUMBER (6? PAGF (3) ygg SEQUENTIAL REVISION Prairie Island Unit 1 WLe8PER NUMBER 05000 282 93 __

997 __ 01 TLXT tif mnre space is rer.rJired, use additional copies of ARC Form 366A) (17)

S U Valve i Valve Name Accident Testing Which Ene Been When Testing Will Y N Function Performed or Other Basis for Be Forformed to j S I Determining Fuctionality the ASME Section i T XI Requirements I 9 l CC 1 32090 11 TEACTOR COOLANT PUMP TO CHANGE Stroked during Containment Next Unit Cold ,

C TEDNENT COOLING OUTLET POSITION Integrated Leak Rete Test Shutdown NOTE 6 CC 2 32125 21 REACTOR COOLANT PUMP TO CHANGE Stroked during Containment Next Unit Cold COMPONENT COOLING OUTLET POSITION Integrated Leak Rate Test Shutdown NOTE 6 CC 1 32092 12 REACTOR COOLANT PUMP TO CEANGE Strched during Containment Next Unit Cold C T20NENT COOLING OUTLET POSITION Integrated Leak Rate Test Shutdown NOTE 6 CC 2 32127 22 REACTOR COOLANT PUMP TO CHANGE Stroked during Containment Next Unit Cold C TIONENT COOLING OUTLET POSITION Integrated Leak Rate Test Shutdown l No!E 6 j SS 1 32402 11 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 BLOWDOWN SAMPLE ISOLATION Safety Injection Test I SS 2 31639 21 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 i ELOWDOWN SAMPLE ISOLATION Safety injection Test 1

SS 1 31637 11 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 1 ELOWDOWN SAMPLE ISOLATION Safety Injection Test SS 2 31412 21 STEAM CENERATOR TO CLOSE Stroked during Integrated August 1,1993 .

ELOWDOWN SAMF11 ISOLATION Safety Injection Test j SS 1 31403 12 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 ELOWDOWN SAMPLE ISOLATION Safety Injection Test SS 2 31E40 22 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 ELOWDOWN SAMPLE ISOLATION Safety Injection Test ,

I SS 1 31638 12 STEAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 ELOWDOWN SAMPLE ISOLATION Safety Injection Test SS 2 31413 22 STLAM GENERATOR TO CLOSE Stroked during Integrated August 1, 1993 BLOWDOWN SAMPLE ISOLATION Safety Injection Test l

/J 1 32242 AUXILIARY TEEDWATER TO 11 TO REMAIN Stroked during Integrated Next Unit Cold STEAM GENERATOR ISOLATION OPEN; Safety Injection Test Shutdown NOTE 4 AF 2 32248 A"XILIARY TEEDWATER TO 21 TO REMAIN Stroked during Integrated Next Unit Cold STEAM GENERATOR ISCLAT!ON OFEN; Safety Injection Test Shutdown NOTE 4

/J 1 32243 AUXILIARY TEEDWATER TO 12 TO REMAIN Stroked during Integrated Next Unit Cold STEAM CENERATOR ISOLATION OPEN: Safety Injection Test Shutdown NOTE 4 AF 2 32249 AUXILIARY FEEDWATER TO 22 TO RDiAIN Stroked during Integrated Next Unit Cold STEAM CENERATOR ISOLATION OPEN; Safety Injection Test Shutdown NOTE 4

NRC FORM 366A U.S. Q) CLEAR REGJLATIOV COMISSI(O APPROVED BY OMB NO. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS RECARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001 AND TO THE PAPERWORC REDUCTION PROJECT (31$0-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHINGTON, DC ?O503.

FACILITY NAME (1) DoctTT NtMBER (?) LFR WlMBER (61 PA E (3)

SEQUENTIAL REVISION YEAR Prairie Island Unit 1 NuwstR NtmeER 93 01 5W8 05000 282 -- 0 0 7 --

TEXT (1f more space is reauired use edditional copies of NRC Form 366A) (17)

S U Valve f Valve Name Accident Testing Which Has Been When Testing Will Y N Function Performed or Other Basis for Be Performed to S I Determining Fuctionality the ASME Section T XI Requirements CL 1 CW-12-1 COOLING WATER TO 11 FAN NOTE 2 Inspected June 1991 Next Unit Cold COIL UNIT ISOLATION CEECK Shutdown CL 2 2CL-12-1 COOLING WATER TO 21 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CEECK NOTE 3 Shutdown CL 1 CW-12-2 COOLING WATER TO 13 FAN NOTE 2 Inspected June 1991 Next Unit Cold COIL UNIT ISOLATION CHECK Shutdown CL 2 2CL-12-2 COOLING WATER TO 23 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CEECK NOTE 3 Shutdown CL 1 CW-12-3 COOLING WATER TO 12 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CHECK NOTE 3 Shutdown CL 2 2CL-12-3 COOLING WATER TO 22 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CEECK NOTE 3 Shutdown CL 1 CW-12-4 COOLING WATER TO 14 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CEECK NOTE 3 Shutdown CL 2 2CL-12-4 CCOLING WATER TO 24 FAN NOTE 2 Verified Open; Next Unit Cold COIL UNIT ISOLATION CEECK NOTE 3 Shutdown CL 1 313B1 11 CC EEAT EXCHANGER CL TO OPEN Valve cycled to open position Next Unit Cold OUT TCV monthly for flushing (SP1617); Shutdown no failures to cpsn since placed in service in 1973 CL 1 31411 12 CC EEAT EXCHANGER CL TO OPEN Valve cycled to open position Next Unit Cold OUT TCV monthly for flushing (SP1617); Shutdown no failures to open since placed in service in 1973 CL 2 31383 21 CC HEAT EXCHANGER CL TO OPEN Valve cycled to open position Next Unit Cold OUT TCV monthly for flushing (SP1617); Shutdown no failures to open since placed in service in 1973 CL 2 31364 22 CC EEAT EXCHANGER CL TO OFEN Valvo cycled to open position Next Unit Cold OUT TCV monthly for flushina (SP1617); Shutdown no failures to open since placed in service in 1973 CL 1 CL-76-3 CV-31769 BYTASS TO OPEN Valve cycled open to verify Complete operability (per WR-U3528-ZH CL 1 CL-76-4 CV-31785 BYPASS TO OPEN Valve cycled open to verify Complete operability (per WR-U3528-IH SI 1 32073 SAFETY INJECTION COOLING TO REMAIN Stroked during Operating Next Unit Cold WATER ISOLATION OPEN Procedure C1.3 Ehutdown NOTE 4 T

l

=

l i

1(RC FORQ 366A U.S. CELEAR REGULATOY CupMISSIO APPROVED BY OMB Wo. 3250-0104 (5-92) EXPIRES 5/31/95 l ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESilMATE TO  ;

LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH i TEXT CONTINUATION (MNBB 7714), U.S. NUCLEAR REGULATORY COMMIS$10N, i WASHINGT ON, DC 20555-0001, AND TO THE PAPERWORK <

REDUCTION PROJECT (3150-0104), OFFICE OF l MANACEMENT AND BUDGET, WASHlWCTOW, DC 20503. l FACit1TY KAME (1) DOCKET RMBER (?) LER RMBER (69 PAGE (3)

YEAR SEQUENTIAL REVISION Prairie Island Unit 1 N'M ER NUwBER 05000 282 93 -- 007 -- 01 1

TEXI (if more spece is reovired. Use additional copies of MC Form 366A) (17) i l

S U Valve f Valve Name Accident Testing Which Eas Been When Testing Will l Y N Function Forformed or Other Basis for Be Performed to  !

S I Determining Fuctionality the ASME Section  !

T XI Requirements j E l SI 2 32176 SAFETY INJECTION COOLING TO REMAIN Stroked during Operating Next Unit Cold WATER ISOLATION OFEN Procedure C1.3 Shutdown NOTE 4 NOTE 1: Based upon a stem design Technical Specification Table 4.4-1 states the "--- cooling water and closed cooling water j system (component cooling) valves [are] not relied upon to prevent containment leakage. The primary function of the cc check valves is to cpen to provide cooling to RCP and to the excess letdown heat exchanger.

NOTE 2: The cooling water supply lines to the fan coil units are provided with a check valve inside containment and a manual motor operated gate valve outside containment. Return lines are provided with a sianual motor operated gate valve ,

inside containment and a manual motor oyerated globe valve outside containment.

In the event of accident, the cooling water supply and return isolation valves position to full open to satisfy i I

their safeguards function. In the event of a fan coil unit or associated piping rupture the containment manual isolation valves would be closed to prevent the entry of non-borated water into containment. Pressure against. the closed isolation valves is maintained by 1/2-inch equalising lines.

The check valves have no close function for accident mitigation or in taking the plant to safe shutdown. The open function of the check valve is verified as part of normal surveillance associated with the fan coil unit. Technical Specification TABLE 75.4.4.1 states the "--- cooling water and closed cooling water system (component cooling) valves [are] not relied upon to prevent containment leakage."

NOTE 3: (A) Our Operating Experience Assessment pregram data for industry operating experience leads to the conclusion that there is no reason to suspect any of the check valves are inoperable.

(B) The open function of the check valves is demonstrated as part of normal operation. A search of NPRDS data shows a f ailure to close frequency of 1.5E-6 f ailures/ component-br.

(C) Machine history shows two of eight coolir.g water to containment fan coil unit check valves were inspected in June 1991. Inspection results indicated that the valves are aging but operable. Plans are to inspect t.he remaining six valves based upon diagnostic testing.

(D) The closed cooling water system (component cooling) is a chemically inert environment and free of abrasives.

Based upon this information, there is reasonable assurance the non-tested or non-inspected check valves are operable.

NOTE 4; Each of these valves is locked in the open position by having t.he the motor control center supply breaker locked in the off position (TS.3.4.B.1.d), (TS.3.3.A.1.g).

NOTE 5: This POV is included in our CL 89-10 HOV program.

NOTE 6: This valve is open during best up, cooldown, and power operation with its motor control center supply breaker in the off position. The valves are accessible locally et the handwheel for cycling.

CAUSE OF THE EVENT The cause of this event was the failure to properly interpret and implement ASME Section XI requirements by plant engineering staff. It was erroneously thought that the valves which were classified as Code Class MC (metal containment) were not required to be additionally classified as Code Class 1, 2, or 3 and were thereby inadvertently left out of the ASME

NRC FORM 3664 U.S. NUCLEAR REGULDTOY CDMISSIO APPROVED BY OMB C3. 3150-0104 (5 92) EXP!RES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REouEST: 50.0 HRS.

FORWARD COMMENTS RECARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH TEXT CONTINUATION (MNBo m4). U.S. NUCLEAR REGULATORY COMMISSION, WASHINGTON, DC 20555-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150-0104), OFFICE OF MANAGEMENT AND BUDGET, WASHlWCTON, DC 20503.

FAClllTY NAME (1) DOCKET NtMBER (2) LER WLMBER (6? PAGE (3)

YEAR SEQUENTIAL REVISION NUMBER NLWBER Prairie Island Unit 1 05000 282 93 --

007 -- 01 IExt < it mee space is reaut ree. use ecoitionat copies o+ wnc Form 366A) (tr>

Section XI Inservice Testing program from the initial classification in 1976. This understanding was in error. We believe that the six valves added to the list in this supplemental report were excluded from the Section XI Program by erroneous interpretation of the code; they had been in the 1st Interval Program and were erroneously omitted from the 2nd Interval Program.

ANALYSIS OF THE EVENT This event is reportable pursuant to 10CFR50.73 (a) (2) (1) (B) since Technical Specification 4.2.A.2 was violated. The valves have been determined to be operable on the basis of testing, inspection, verification of desired position, and/or evaluation of historical data; this information is referenced in the above table. Since all components are believed to be operable there were no consequences to the health and safety of the public.

CORRECTIVE ACTION An evaluation of the available data (as discussed in the table above) for each of these valves has been made to determine their operability.

The valves will all be tested per requirements of ASME Section XI per the schedule listed in the table.

All safety-related control valves were reviewed again following the June  ;

24, 1993 discovery and it was concluded that the six identified (two of the six were manual bypass of control valves) were the only ones inappropriately excluded from the Program.

These valves have been included in the Prairie Island ASME Section XI 3rd 10-year program for future testing.

FAILED COMPONENT IDENTIFICATION j None. i PREVIOUS SIMILAR EVENTS Unit 1 Licensee Event Report 90-018, Rev. 1 identified certain cooling water and chilled water valves which had not previously been identified as i performing an active function to mitigate the consequences of a design l basis event and therefore should have been evaluated for inclusion in the l l

1 1

• i NRC' FORM 366A U.S. C3X1 EAR REGULATOY CupMISSIC APPROVED BY OMB No. 3150-0104 (5-92) EXPIRES 5/31/95 ESTIMATED BURDEN PER RESPONSE TO COMPLY WITH THIS INFORMATION COLLECTION REQUEST: 50.0 HRS.

FORWARD COMMENTS REGARDING BURDEN ESTIMATE TO LICENSEE EVENT REPORT (LER) THE INFORMATION AND RECORDS MANAGEMENT BRANCH (MNsB 7714), U.S. NUCLEAR REGULATORY COMMISSION, TEXT CONTINUATION WASHINGTON, DC 20555-0001, AND TO THE PAPERWORC REDUCTION PROJECT (3150-0104), OFFICE OF i MANAGEMENT AND BUDCET, WASHlWGTON, DC 20503. j F ACit ITY NAME (1) DOCKET NtMBfR (?) LER NLMBER (65 PA M (3)

YEAR SEQUENTIAL REVISION WUMPER NUMBER Prairie Island Unit 1 g g 05000 282 93 __

007 __ 01 TEXT (if more space is recrJired, USe Bddit10nBl CODieS Of NRC Form 366A) (17)

ASME Section XI Inservice Testing Program. The corrective action for that event (" Design Bases reconstitution will continue to ensure that other similar oversights, if they exist, will be discovered.") resulted in I identification of the feedwater isolation valves reported in this event. l l

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