ML20247R876
| ML20247R876 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/22/1998 |
| From: | Sorensen J NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9805290234 | |
| Download: ML20247R876 (4) | |
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Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesota 55089 May 22,1998 10 CFR Part 50 Section 50.9 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 10CFR50.9 Reporting of incorrect Information Previously Provided to the NRC Regarding Auxiliary Feedwater Pump Surveillance Procedure Acceptance Criteria On April 26,1998 it was determined that there was an error contained in a presentation made to the NRC on August 8,1997 and repeated in a submittal dated November 14, 1997. This error was reported to Region ll1 by telephone on April 28,1998.
Summarv During the course of the August 8,1997 Predecisional Enforcement Conference held to discuss the apparent violations at Prairie Island identified in NRC Inspection Report 50-282(306)/97008(DRS), representatives of Northern States Power Company - Prairie Island stated that all monthly and outage test procedures for all AFW pumps had been updated with appropriate acceptance criteria. On April 26,1998 it was determined that 22 TD AFW pump had been run on March 4,1998, using a surveillance procedure in which the acceptance criteria had not been updated. Further investigation revealed that 21 MD AFW pump had been run on March 5,1998, also using a procedure that had not been updated.
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Qiscussion 1i9 In May of 1997, in response to an inquiry made by the NRC during it's System Operational Performance Inspection, Prairie Island staff concluded that the acceptance i
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USNRC NORTHERN STATES POWER COMPANY May 22,1998 Page,2 criteria contained in its AFW pump testing surveillance were inadequate. It was determined that the acceptance criteria, which had been established using the ASME Section XI requirement of +/- 10% from the established pump operating curve, were not sufficient to ensure that these pumps could meet their design flow requirements.
Engineering calculation ENG-ME-321 was performed to determine the required acceptance criteria. It was approved for use on June 10,1997.
In conjunction with the development of ENG-ME-321, procedure change requests were issued for each of the eight affected surveillance procedures (one monthly surveillance and one refueling surveillance for each of the four AFW pumps). These procedure change requests were issued on June 8,1997 with one exception. A change request had been issued May 5,1997 to change the acceptance criteria in the monthly surveillance for 21 MD AFW pump. This change request was amended per ENG-ME-321.
In addition to the above procedure change requests, on June 8,1997 temporary memos were issued to incorporate the new acceptance criteria into any surveillance procedure that might be performed prior to the completion of the procedure change process. These temporary memos were issued for each of the monthly surveillance and for the Unit i refueling surveillance. However, based upon the fact that the next scheduled refueling for Unit 2 was not scheduled until October of 1998 (16 months later) it was assumed that there was sufficient time to ensure that the change process for the unit 2 refueling surveillance would be completed prior to their use.
On August 8, at the Predecisional Enforcement Conference the statement was made that all monthly and outage test procedures for all AFW pumps had been updated with appropriate acceptance criteria. This statement was based on the first page of a condition report which indicated that temporary memos had been used to update all such test procedures. At that time the conference participants did not recognize that a subsequent electronic screen stated that six of the eight effected surveillance were updated with temporary memos and the remaining two surveillance had procedure change requests submitted. None of the personnel assigned to update these surveillance were participants in the predecisional enforcement conference. A discussion did occur between these personnel and conference participants regarding whether a procedure that was amended via a temporary memo could be categorized as l
updated. This discussion set a trap which resulted in a misunderstanding between the two groups. When the conference participant reviewed the first page of the condition l
report indicating that temporary memos had been completed, no further verifications were made.
IR97006D. DOC l
USNRC NORT* *ERN STATES POWER COMPANY May 22,1998 Page,3 On November 17,1997 the decision was made to include the two Unit 2 refueling surveillance in the Prairie Island procedure upgrade program. As such they were to receive additional changes and be submitted to an extensive review process. At that time the acceptance criteria changes were still outstanding so they were incorporated into the more extensive procedure upgrade. This resulted an additional delay of the implementation of he acceptance criteria changes.
On January 24,1998 Prairie Island's Unit 2 was forced to shut down to repair a leak in a Part Length Control Rod Drive Mechanism. The scope of this outage expanded to include the removal of all four of Unit 2's Part Length CRDMs. Since Unit 2 was in cold shutdown, testing was scheduled for all ASME Section XI components required to be tested at a cold shutdown frequency. This requirement applied to the AFW check valves but not to the pumps themselves. Because the pump and check valve testing for a given AFW pump and its associated valves is accomplished under one refueling surveillance (two surveillance per unit), the refueling surveillance for both Unit 2 AFW pumps were performed to meet Section XI requirements. At this point the acceptance criteria changes for these procedures had not been incorporated into the standing surveillance. As a result, while testing of the pumps themselves was not required, the performance of the pumps was evaluated based upon incorrect acceptance criteria.
This error was identified on April 26,1998 while the procedure change request facilitating the acceptance criteria and procedure improvement changes to 22 TD AFW pump's refueling surveillance was being reviewed for final approval. On April 27,1997 it was determined that 21 MD AFW pump's refueling surveillance had also been performed while Unit 2 was shut down for removal of the Part Length CRDMs and that the incorrect acceptance criteria had been used. In both cases this was the first and only use of these surveillance procedures, with the unacceptable acceptance critella, since the determination of the correct acceptance criteria. A review of all applicable pump performance data was performed and resulted in the determination that both Unit 2 AFW pumps remained operable.
Corrective Actions The two Unit 2 refueling surveillance procedures were quarantined April 29,1998.
They will remain in quarantine until the associated procedure changes have been implemented. Currently these procedure changes have received final technical review and are awaiting operations committee review prior to implementation.
The proceduto change process is being modified by way of a revision to the form used to implement the process. This revised form will require the individual making the initial technical review to determine whether the change is needed prior to the next use of the IR97008D. DOC
USNRC NORTHERN STATES POWER COMPANY May 22,1998 Page 4 pmcedure. If this is the case, the procedure change form and process will require that thu procedure immediately be quarantined or have a temporary change made to the procedure.
Plant management willprovide expectations to the plant staff on the closure of corrective action items to a change process (procedure change request, modification, etc.).
10CFR50.9 Applicability At the time of discovery it was concluded that the NRC staff had been provided with inaccurate information regarding the completion of the surveillance procedure changes.
Notification to the Regional Office was made April 28,1998, fulfilling the two working day deportability requirement.
It is recognized that if an AFW pump's performance had degraded to the point that it would have been unable to meet its design requirements, performing the surveillance procedures with the existing acceptance criteria created a situation in which the pump could have been inappropriately evaluated as operable. However, the performance of the affected pumps did not degrade to such a point. Further, the performance of these pumps was periodically verified via the satisfactory completion of the monthly surveillance.
In this letter we have made three new Nuclear Regulatory Commission commitments; these are the italicized statements in the " Corrective Actions" section. Please contact Jack Leveille (612-388-1121, Ext. 4662) if you have any questions related to this letter.
h Joel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region lil, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg IR97008D. DOC
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