ML20235T175
| ML20235T175 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 12/21/1988 |
| From: | Larson C NORTHERN STATES POWER CO. |
| To: | Wright G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8903080178 | |
| Download: ML20235T175 (7) | |
Text
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Northem States Power Company g i g
414 Nicollet Mall l
Minneapolis, Minnesota 55401-1927 Telephone (612) 330-5500 December 21,.1988 Mr G C Wright, Chief Operations Branch, Region III U S Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Response to Inspection Reports 50-282/88016 and 50-306/88016 In response to your letter of November 21, 1988, which transmitted Inspection Reports No. 50-282/88016 and No. 50-306/88016, the follow--
ing information is offered.
Violation 1.
10 CFR 50, Appendix B, Criterion V, as implemented by the Prairie Island Quality Assurance Plan, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions or procedures, a.
Prairie Island Nuclear Generating Plant, Calibration Control procedure no. 5ACD 3.14, paragraph 6.6, requires that procurement documents shall specify as a minimum the as-found condition and the as-left condition for instrument calibration.
Contrary to the above, the procurement documents which requisition the calibration of flowmeters did not require that an as-found condition be determined.
b.
10 CFR 50, Appendix J, paragraph III.A.3.(c) re-quires that for Type A tests the leakage rate shall i
be calculated using absolute values corrected for instrument error.
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Contrary: to the above, the licensee's CILRT procedure or computer program for Total Timefdid not' reflect a method to calculate the leakage rate using absolute values. corrected for instrument error or specify a q;
method to calculate che leakage' rate at the 95% upper yp confidence level.
c.
Prairie Island Nuclear Generating Plant, Integrated Leak Rate. Test Program procedure no. SP 1071(4), pg.
76, Valve Lineup, requires vent valve HC-1-2 to be in the open position.
Contrary to the above, the' inspector observed valve
~HC-1-2 to be in the closed position, although the valve position checklist had been initialed and dated.
This is a Severity Level IV violation (Supplement I).
Response
Corrective Actions That Have Been Taken and Results Achieved
- a. _As-found calibration data will be required on pur-chase orders for calibration of the~ flow meters used for local leakage rate tests. These require-ments will be in place before flow meters are used again for local leakage rate testing, planned for the March 1989 Unit 2 outage.
b.
On September 27, 1988 the NRC approved our request for exemption from the requirements of Appendix J thus permitting the use of the mass point method of calculating containment leakage.
c.
Pre-test valve lineups were developed that required independent verification of' vent and drain paths for the integrated leakage rate test (ILRT); verifica-tions were performed by the plant QC group.
The valve in question, HC-1-2, was not on the indepen-dent verification list for the ILRT.
The indepen-dent verification list will be reviewed for accu-racy and completeness. The list will then be up-dated to reflect this review.
This task will be
L Northern States Power Company
- G C Wright December 21, 1988 Page 3 completed prior to the next ILRT, planned for the March, 1989 Unit 2 outage.
Corrective Actions That Will Be Taken to Avoid Further Violations Procedures will be updated as described above prior to the next ILRT.
Date When Full Como11ance Will Be Achieved Full compliance has been achieved.
Violation 2.
10 CFR 50, Appendix J, paragraph III.D.2 requires that Type B tests shall be performed during reactor shutdown-for refueling or other convenient intervals but in no case at intervals greater than 2 years.
Contrary to the above, the licensee has not conducted Type B tests on 51 Unit i electrical penetrations and the 52 Unit 2 electrical penetrations since 1983.
This is a Severity Level IV violation (Supplement I).
Response
Corrective Actions That Have Been Taken and Results Achieved The electrical penetrations were tested shortly after this error was discovered confirming their leak tightness.
Corrective Actions That Will Be Taken to Avoid Further Violations Standing procedures for these tests will be in place before the next leakage tests, which are planned for the March, 1989 Unit 2 outage.
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.Date When Full Comoliance'Will Be Achieve'd
~ Full" compliance has been achieved.
e Violation
[3. Prairie' Island Technical Specification 4.4.A.2,.
. Containment' Imakage, Tests, states, in part, ".. when L
containment system integrity'is required, each airlock
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shall be tested'every 3 days if it is in use by
. pressurizing the intergasket space to 10 psig, h
e c-Contrary;to the.above, the licensce entered the Unit 1 personnel airlock on May 26, 1988, but failed to perform L
.the required surveillance test.
This is a Severity Level IV violation (Supplement I).
Resoonse
- Corrective' Actions That Have Been Taken and Results Achieved s
We underst'and chst this violation will be rescinded. A i
simil.ar violation was issued in Inspection Reports 50-282/88019 and 50 306/88019.
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-Failure to perform the personnel airlock door seal test was due to an oversight during the performance'of the test procedure. This event was reported as Unit 1 LER 88-006; a similar event occurred on September 21, 1988 and was reported as Unit 2 iLER 88-001.
The personnel airlock door seal test was successfully performed on July 13, 1988 indicating that the door seals were operable and leak tight Personnel and maintenance airlock test procedures have been revised to incorporate changes designed to prevent the re-currence of these events in the future.
Corrective Actions That Will Be Taken to Avoid Further Violations No additional corrective actions are thought to be required at this time.
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Page 5 Date When Full Comnliance Will Be Achieved Full compliance has been achieved.
Violation 4
10 CFR 50, Appendix J, paragraph III.A.5.(b)(1) states, in part, "If local leakage measurements are taken to effect repairs in order to meet the acceptance criteria, these measurements shall be taken at a test pressure Pt (1/2 Pa)."
Contrary to the above, the licensee testing in response to repairs and maintenance on containment boundaries during the 1985 and 1988 Unit 1 containment integrated leak rate tests (CILRT) and the 1985 Unit 2 CILRT was performed at a pressure equal to Pa.
This is a Severity Level IV violation (Supplement I).
Response
Corrective Actions That Have Been Taken and Results Achieved See the following description of corrective actions to be taken prior to the next ILRT.
Corrective Actions That Will Be Taken to Avoid Further Violations The local leakage rate test procedures, SP1072 and SP2072, will be revised to identify this requirement.
Specifi-cally, the changes will require:
- Flowmeter calibrations at Pt for outages when an ILRT will be done.
- Local leakage rate testing at Pt for valves that are to be repaired.
'As changes will be in place before the next leakage tests which are planned for the Unit 2 March, 1989 outage.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
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' December 21, 1988 Page 6 t-Violation
=5.
10 CFR 50, Appendix J, paragraph III.C.2, Test Pressure, requires that Type C tests, valves shall be pressurized with air or. nitrogen at a pressure Pa.
Technical Specification Section 4.4.A.2, containment leakage tests require that Type C tests of penetrations shall be performed at a pressure of 46 psig. Additionally, Technical Specification TS 4.4-1 requires that Containment Spray Penetrations 29A and 29B be Type C tested.
Contrary to the above, the licensee does not Type C test the Unit 1 containment spray. valves MV-32105 and MV-32103 for penetrations 29A and 29B, respectively.
This is a Severity Level IV violation (Supplement I).
Response
Corrective Actions That Have Been Taken and Results Achieved 9
1x-See the following section for a description of the corrective action we will take to resolve this violation.
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Corrective Actions That Will Be Taken to Avoid Further Violations f.-
Due to the configuration of the containment spray penetra-tions, MV-32105 and MV-32103 cannot be Type C tested in full compliance with Appendix J.,
This issue will be resolved with the Commission either-though an approved exemption'from the requirements of Appendix J, and a' Technical Specification change, or through plant modifications if a convincing case cannot be presented to the NRC Staff for granting such an exemption.
The basis for granting an exemption would rely on the special design features of the containment spray system.
y Rate When Full Compliance Will Be Achieved
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A request for exemption from the requirements of Appendix J for the valves in question will be submitted and NRC action requested on a schedule which will permit this issue to be fully resolved in Unit 1 prior to the January, 1990 outage, and in Unit 2 prior to the September, 1990 outage.
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- Please contact.us if,you have any' questions related to our responses to
- these violations.-
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.C.E Larso lVice, president Nuclear Generation c::/ Regional Administrator-III, NRC.
NRR Project Manager, NRC Senior-Resident (Inspector,-NRC G Charnoff
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