ML20245E793

Responds to NRC Re Violations Noted in Insp Repts 50-282/88-16 & 50-306/88-16.Corrective actions:as-found Calibr Data Will Be Required on Purchase Orders for Calibr of Flow Meters Used for Local Leakage Rate Tests

ML20245E793
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)
Shared Package
ML20245E791	List: IR 05000282/1988019 ML20245E793
References
NUDOCS 8901170341
Download: ML20245E793 (6)

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Northem States Power Company

) 414 Nicollet Mall Minneapolis. Minnesota 55401-1927 i

Temph ne (s12) 330.ssoo 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 PIANT 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-I~ ing information is offered.

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- 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 be calculated using absolute values corrected for instrument error.

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C C Uright Northem States Power Company

• i December 21, 1988 Page 2 Contrary to the above, the licensee's CILRT procedure or computer program for Total Time did not reflect a method to calculate the leakage rate using absolute values corrected for instrument error or specify a method to calculate the leakage rate at the 95% upper confidence level,

c. Prairie Island Nuclear Generating Plant, Inte5 rated 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 Beeq 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 1969 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 (1LRT); verifica-tions were performed by the plant QC group. The i valve in question, HC-1-2, was not on the indepen-dent verification list for the ILRT. The indepen- j i

dent verification list will be reviewed for accu- {

racy and completeness. The list will then be up- l

{ dated to reflect this review. This task will be 1

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. December 21, 1988 Page 3-completed prior to the next IIRT, planned for the .

March,1989 Unit. 2 outage.

Corrective Actions That Vill Be Taken to Avoid Further Violations Procedures will be updated as described above prior to the next IIRT.

Date When Full Como11ance Vill 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 em, ducted Type B tests on 51 Unit 1 electrical penetrations and the 52 Unit 2 electrical penetrations since 1983.

This is a Severity Level IV violation (Supplement I).

Responne 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 Vill 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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- G C Wright December 21, 1988 Page 4 Date When Full Como11ance Will Be Achieved Full compliance has been achieved.

Violation

3. Prairie Island Technical Specification 4.4.A.2,_

Containment Leakage Tests, states,- in part, . . . when containment system integrity is required, each airlock shall be tested every 3 days if it is in'une by pressurizing the intergasket space to 10 psig.

Contrary to the above,-the licensee entered the Unit 1 personnel airlock on May 26, 1988, but failed to perform the required surveillance test.

This is a Severity Level IV violation (Supplement I).

Response

Corrective Actions That Have Been Taken and Results Achieved

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. 3 We understand that this violation will be rescinded. A similar violation was issued in Inspection Reports 50-282/88019 and 50-306/88019.

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 11.ER 88-006; a similar event occurred on September 21, 1988 and was reported as Unit 2 LER 88-001.

The personnel airlock door seal test was successfully performed on July : 2 1988 indicating that the door seals were operable and leak tigt.'.

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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c Date When Full Comoliance Will Be Achieved Full compliance has been achieved.

Violation

4. 10 CFR 50, Appendix J, paragraph III.A.S.(b)(1) states, in part, "If. local leakage measurements are taken to effect repairs in order to meet the acceptance criteria, H

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 tLa 1985 and 1988 Unit 1 containment integrated leak rate tests (CILRT) and the 1985 Unit 2 CIIRT 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 Vi?1 Be Taken to Avoid Further Violations The local leakage rate test procedures, SP1072 and SP2072, j 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.

These changes will be in place before the next leakage tests which are planned for the Unit 2 March, 1989 outage.

Date When Full Compliance Vill Be Achieved Full compliance has been achieved.

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Northern States Power Company f -, . G C Wright December 21, 1988 i Page'6 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

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' 0" . See the following section for a description of'the corrective action we will take to resolve this violation.

Corrective Actions That Will Be Taken to Avoid Further violations 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 exemptint.

The basis for granting an exemption would rely on the special design features of the containment spray system.

Date When Full Comoliance Will Be Achieved 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 e, 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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j C C Wright December 21, 1988-r--: Page 7 Please contact us if you have any questions related to our responses to these violations.

w C E Larso Vice president Nuclear Generation c: Regional Administrator-III,'NRC NRR Project Manager,. NRC Senior Resident Inspector, NRC C Charnoff

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