ML20099L921
| ML20099L921 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 10/15/1984 |
| From: | Larson C NORTHERN STATES POWER CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20099L905 | List: |
| References | |
| NUDOCS 8412030145 | |
| Download: ML20099L921 (2) | |
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3 Northem States Power Company 414 Nicollet Mall Minneapolis Minnesota 55401 Telephone (612) 330-5500 October 15, 1984 Mr R L Spessard, Director Division of Reactor Safety U S Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, IL 60137 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 In response to your letter dated June 29, 1984 which transmitted Inspection Reports Nos. 282/84-08(DRS) and 306/84-07(DRS), the following information is provided.
VIOLATION The Prairie Island Nuclear Generating Station, Unit 1 Technical Specification
4.2 states
" 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 50.55a(g)."
Contrary to the above, five motor operated, Category A Residual Heat Removal System valves are not leak tested or trended per the requirements of IWV-3420 of Section XI of the ASME Code.
This is a Severity Level V violation.
(Supplement II),
RESPONSE
A commitment was made during the inspection to make procedure changes to correct the identified noncompliance.
In response to that commitment, techniques for quantitative determination of leakrate using the testing methods described in Prairie Island Inservice Testing (IST) Program Request for Relief #59 were eva lua ted. A technique for quantitatively determining the leakrate of valves MV-32066, 32165 and 32231 has been developed and will be incorporated into the appropriate procedures.
The engineering analysis is available at the site for your review.
Even though a quantitative measurement technique has been developed, we still believe that IST Program Request for Relief #59, as approved by the Commission, exempted Prairie Island from testing valves MV-32066, 32165 and 32231 to the requirements of IWV-3420(d).
Items 2.a.1 and 2.b.3 of Request for Relief #59 were submitted because it was found at the time to be impractical to quantita-tively determine the leakage from these valves. We bel'. eve the Commission stated their agreement with this position in Section 3.2.1 of the IST Program SER dated January 4, 1983.
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8412030145 841016 PDR ADOCK 05000282 G
Dirrctor of Rerctor S:fety October 15, 1984 Page 2 Nodbem States Power Company However, portions of the same SER imply that leakrates would be measured by the alternate test procedure described in Request for Relief #59 and compared against established leakage limits.
It was never the intent of the test procedure described in Request for Relief L59 to provide quantitative leakrate data or to impose specific leakrate criteria. The described procedure was only intended to provide a qualitative assessment of the integrity of the subject valves.
If this qualitative determination indicated that leakage was occurring, further investigative actions would be taken.
We believe that the violation described in the inspection report was not a result of a failure to comply with regulations.
Rather, it resulted from differing interpretations of Request for Relief #59 and the IST Program SER.
On this basis we feel that it is appropriate to request that the citation be withdrawn and lef t as an open matter to resolve with F(R.
In order to avoid further confusion with respect to the intent of Request for Relief #59, the present wording will be revised to clarify the intent of the request for relief and to include the recently developed quantitative measure-ment technique.
This revision will be submitted for NRR review and approval.
Please note that contrary to item 3.b of the subject inspection report, valves MV-32064 and 32065 are category B valves and are not subject to the requirements of IWV-3420(d).
Please contact us if you require further information related to our response.
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-auwm C E Larson Vice-President, Nuclear Generation CEL/bd c: Resident Inspector, NRC G Charnoff