ML20094B683

Responds to NRC Re Violations Noted in IE Insp Repts 50-282/84-04 & 50-306/84-04.Corrective Actions:Reactor Coolant Vent Sys Solenoid Valve Fuses Removed & Will Not Be Installed Until Requirements Met

ML20094B683
Person / Time
Site:	Prairie Island
Issue date:	07/13/1984
From:	Larson C NORTHERN STATES POWER CO.
To:	Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20094B668	List: ML20094B683
References
NUDOCS 8408070197
Download: ML20094B683 (2)

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Northem States Power Company 414 Nicollet Mall Minneapohs, Minnesota 55401 Telephone (612) 330 5500 July 13, 1984 W D Shafer, Chief Projects Branch No. 1 U S tbclear 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 No. 282/84-04(DPRP) and 306/84-p p (DPRP), the following information is provided.

DEVIATION The NRC March 27, 1984 transmittal letter for Amendment No. 69 to DPR-42 and Amendment No. 63 to DPR-60 (relating to the reactor coolant system ventsf states that the amendments will not become effective until; (1) after the first cold shutdown occurring after April 1, 1984 or after the next refueling outage, whichever is earlier for each unit; and (2) after audit of the plant operating procedures related to the vent systems by the Prairie Island resident inspector.

Contrary to the above, on April 11, 1984, with both units at essentially full power, fuses were installed in the vent valve circuits for both units thus making the vent systems operational before meeting commitments 1 and 2 above.

This is a Deviation.

RESPONSE

The reactor coolant vent system solenoid valve fuses were removed on April 12, 1984 making the vent systems again inoperable for both units.

A subsequent audit by the NRC Resident Inspector found the emergency procedure which discusses vent valve operation to be adequate. Vent system blocking and tagging requirements will be met at the next cold shutdown or refueling outage. The reactor coolant vent system fuses will not be reinstalled until the blocking and tagging requirements have been met.

While we have provided our commitment not to replace the fuses for the vent systems without meeting the conditions discussed above, we must take issue with the need for this action and the basis for issuance of this deviation. In our view, the conditions of the license amendment dated March 27, 1984 did not preclude the installation of the vent system iuses prior to manual valve blocking and tagging and NRC procedure audit.

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0 ' LRa'theriit stated that the' subject license amendment would not become

' ^ ~ effective until. the specified conditions were met. There were no explicit

- 1 restrictions on installation of the power supply. fuses.

as ,

3TNe ' sole ~ purpose of the delayed implementation provision in the March

<27,~1984111 cense amendment was to prevent a Technical Specification

~.; , violation since the required valve blocking and tagging would require a Pi Econtainment entry. All other requirements of the Technical Specifications

could .have been implemented immediately since the reactor coolant vent ssystems'were. complete and fully operable with the exception of the power 1 supply; fuses. . With the fuses removed, there is no control board indication lofsvalve position.- Installation of the fuses was therefore highly desirable and appeared to be permissible based on the design approval

. Leontained in the NRC Staff Safety Evaluation Report which accompanied the

. March ~27,.1984 license amendments.

The deviation appears to be based on the premise that a system cannot be

' made : operational unless its respective Technical Specifications are in effect. In reality, additions and changes to the plant which are not

prohibited by the Technical Specifications or in conflict with the l Technical Specifications are made frequently. Technical Specifications applicable ; to these "new" plant features may be requested by a licensee

.and issued by the NRC _af ter the change to the plant has been made operable.

~ Our actions energizing .the vent systems were taken in an effort to

. increase the level of safety of the plant, by establishing control board

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valve position indication ~for the vent systems as soon as it was prudent

.to do so. We do not believe that such actions constitute a failure to

'- -meet the requirements of the March 27, 1984 license amendment- and request -

s that the deviation be withdrawn.

'Please contact us if yor require further information related to our response.'

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C E Larso

'Vice President - Nuclear Generation

P CEL/bd c: Resident Inspector, NRC NRR Project Manager, NRC G Charnoff (Attn: A D Wasserman) i.

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