ML20135E459
| ML20135E459 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/05/1996 |
| From: | Wadley M NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9612110286 | |
| Download: ML20135E459 (4) | |
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a Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 December 5,1996 10 CFR Pad 2 U S Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Reply to Notice of Violation (Inspection Report 96010),
Failure to Perform Section XI Testing on Chemical Feed Check Valves Your letter of November 5,1996, which transmitted Inspection Report No. 96010, required a response to a Notice of Violation. Our response to the violation is contained in the attachment to this letter.
In this response we have made one new Nuclear Regulatory Commission commitment, indicated as the statements in italics.
Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions related to this letter.
/f//Ic hb y
Michael D Wadley Plant Manager l
j Prairie Island Nuclear r
Plant c:
Regional Administrator - Region 111, NRC Senior Resident inspector, NRC j LO/
NRR Project Manager, NRC J E Silberg
Attachment:
RESPONSE TO NOTICE OF VIOLATION 9612110286 961205 PDR ADOCK 05000282 O
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RESPONSE TO NOTICE OF VIOLATION VIOLATION Technical Specification 4.2.A.2 required that inservice testing of American Society l
of Mechanical Engineers (ASME) Code Class 1, Class 2, and Class 3 pumps and j
valves be performed in accordance with Section XI ' f the ASME Boiler and :
o Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g), except where specific written relief has been granted by the l
NRC.
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Section XI of the ASME Boiler and Pressure Vessel Code (1989) states that j
valve testing shall be performed in accordance with the requirements stated j'
in ASME/American National Standards Institute Operations and Maintenance Standards, Part 10,1988 (ASME/ ANSI OM-10), " Inservice Testing of Valves in Light-Water Reactor Power Plants."
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Paragraph 4.3.2.4(a) of OM-10 required quarterly verification that the disk of i
a normally open check valve travels to its seat on cessation or reversal of i
flow by observing a position indicating device or changes in system pressure, flow rate, level, temperature, seat leakage testing or other positive means.
4 Licensee procedure H10.1, "ASME Section XI l_nservice Testing implementation Program," Appendix B, " Unit 1 and Common Equipment Check Valve Tables,"
revision 4, listed check valve CF-11-2 as requiring a quarterly test in the closed direction using Surveillance Procedure SP 1355. H10.1, Appendix F," Unit 2 Check Valves Tables," revision 4, listed check valve 2CF-11-2 as requiring a quarterly test in the closed direction using Surveillance Procedure SP 2355.
SP 1355, " Checking Chemical Feed and Auxiliary Feedwater Check Valves - Unit 1," revision 6, required testing of CF-11-2 by verifying a differential pressure existed between the downstream and upstream side of the valve with pressure existing on the downstream side. The differential pressure was verified using temporarily installed gauges. Similarly, SP 2355," Checking Chemical Feed and Auxiliary Feedwater Check Valves - Unit 2," revision 2, required similar testing of 2CF-11-2.
Contrary to the above, from about March 1994 until October 1,1996, normally open check valves CF-11-2 and 2CF-11-2 were not properly tested quarterly in that differential pressure across the valves was not adequately verified because the temporary pressure gauges upstream of the valves were isolated.
This is a Severity Level IV Violation (Supplement I).
i 1-Attachment December 5,1996 Page 2 i
RESPONSE TO VIOLATION I
l Reason for the Violation SP 1355, among other things, verifies that CF-11-1 and CF-11-2, the chemical feed to steam generator check valves, travel to their closed position by introducing a pressure source downstream of these valves and monitoring pressure in a closed volume (an j
isolated portion of the chemical feed system) upstream of the valves. No pressure l
increase in the closed volume indicates closure of the check valves.
l The test was written assuming that the cross-tie valves between 11 and 12 Chemical Feed Pumps were normally open. These valves are not normally open and the i
procedure did not verify their positions. The result was that, as the chemical feed j
piping was aligned during the September 30,1996 performance of SP 1355, a j
. postulated failure of CF-11-2 to close would not have been detected.
l The surveillance procedures, SP 1355 (Unit 2: SP 2355) were inadequate in that they l
did not provide instructions to verify the proper alignment of two cross tie valves required to be in the open position. With either of these cross tie valves in the closed position the pressure increase resulting from a postulated failure of CF-11-2 (Unit 2:
l 2CF-11-2) to open would not be monitored at the common pressure gauge location.
Corrective Steos Taken and Results Achieved A temporary memo was initiated in association with SP 1355. The procedure as performed using this temporary memo provides instructions necessary to ensure proper valve alignment. SP 1355 was performed implementing this temporary memo and it was determined that CF-11-2 was operable.
AF-18-9, Chemical Feed to 12 Steam Generator, downstream of 2CF-11-2 was closed, removing 2CF-11-2 from service until SP 2355 could be revised and performed. This surveillance procedure was revised, it has now been completed, and it was determined that 2CF-11-12 was operable.
r Corrective Steos That Will Be Taken To Avoid Further Violations:
SP 1355 has now also been revised to ensure proper valve alignment and the temporary memo has been canceled. Additionally, as revised, the procedures no longer rely on a common pressure monitoring location. Rather an upstream section of piping unique to each check valve will be isolated and pressure monitored in conjunction with the introduction of reverse flow and/or pressure.
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Attachment December 5,1996 Page 3 A several-month long review program has been initiated whereby system engineers are doing walk-throughs ofprocedures during surveillance testing. It is intended to do this i
review for a selection of the safety significant and complex procedures. This has been i
completed for SP 1355 (SP 2355). This reviewprogram willbe completed by June 30, l
1996.
I The Date When Full Comoliance Will be Achieved:
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Full compliance has been achieved.
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