ML20199C432

Responds to NRC Re Violations Noted in Insp Repts 50-282/97-08 & 50-306/97-08.Corrective Actions:Asme Section XI Check Valve Testing Full Flow Valves Were Reviewed & Documented During Plant 10 Yr Program Development

ML20199C432
Person / Time
Site:	Prairie Island
Issue date:	11/14/1997
From:	Sorensen J NORTHERN STATES POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-282-97-08, 50-282-97-8, 50-306-97-08, 50-306-97-8, NUDOCS 9711200014
Download: ML20199C432 (10)

Text

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y Northern States Power Company Prairie Island Nuclear Generating Plant 1717 Wakonade Dr. East Welch, Minnesote $50e9 November 14,1997 10 CFR Part 2 U S Nuclear Regulatory Commission Aitq: Document Control Desk Wasnington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Raply to Notice of Violation (Inspection Report 97008),

Deficiencies in the Test Control, USAR Update and Corrective Action Programs l

Your letter of October 16,1997, which transmitted additional violations from inspection Report No. 97008, required a response to a Notice of Violation. Our response to the notice is contained in the attachment to this letter. Refer to our August 15,1997 response to Notice of Violation for commitments already made in regard to this inspection.

In addition, your July 16,1997 letter had requested that we inform you of "any planned actions, including timo frames, for re-performing the control room habitability dose l

calculations and any plans to test the control room isolation dampers for verification of the inleakage assumptions..." We plan to perform the control room envelope testing in January 1998. The testing is expected to take about a week. Following evaluation of the test results, we will determine the need to perform a control room habitability dose re-analysis.

The $50,000 civil penalty associated with the Severity Level 111 problem was paid by electronic transfer November 7,1997.

We have made new Nuclear Regulatory Commission commitments, indicated as the italicized statements above and in the attachment. Other comrnitments associated with these violations were made in our August 15,1997 letter. [

.xl 9711200014 971114 i bl PDR ADOCK 05000282 G PDR

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USNQC November 14,1997 Page:

P! casa cor.tsci Jack !.sysille (S12 389-1121 Ex!. 4662) if you have any questions related to this letter.

Joel P Sorensen Plant Manager Prairie Island Nuclear Generating Plant c: Regional Administrator - Region 111, NRC Senior Resident inspector, NRC NRR Project Manager, NRC J E Silberg

Attachment:

RESPONSE TO NOTICE OF VIOLATION 4

,1 RESPONSE TO NOTICE OF VIOLATION VIOLATION 1 10 CFR Part 50, Appendix B, Criterion XI, " Test Control," requires, in part, that a test program shall be established to assure that all testing required to demonstrate that systems will perform satisfactority in service is idantified and performed in accordance with written test procedures which incorporate the raquirements and acceptance limits contained in applicable design documents.

Updated Safety Analysis Report (USAR) at Section 11.9.3.a, " Loss of Main Feedwater Transients" documented that during a loss of offsite power transient a single Auxiliary Feedwater ( AFW) pump will provide sufficient flow to prevent water relief from the pressurizer relief valves. USAR Table 11,9-2, " Summary of Assumptions used in the AFW System Design Verificat;on Analysis," stated that the minimum required AFW flow during a loss of offsite power transient was 200 gallons per minute to a steam generator.

Contrary to the above, since at least May 31,1991, and continuing until April 24, 1997, the test program failed to assure that written test procedures incorporated the 200 gallons per minute acceptance limits contained in Sectin n 11.9.3.a of the '

USAR; the applicable design documents. Specifically, the acceptance criteria i for the Unit 1 and Unit 2 monthly and refueling outage AFW eurveillance tests listed below would have permitted the AFW pumps to degrade below (and remain operable) the minimum flow - 200 gallons per minute - to a steam generator during a loss of offsite power transient. (01013)

SP 1103, "11 Turbine-Driven Auxiliary Feedwater Pump Once Ever; i Refueling Outage Test;

SP 1101, "12 Motor. Driven Auxiliary Feedwater Pump Once Every Refueling Outage Test;"

SP 2101, "21 Motor-Driven Auxiliary Feedwater Pump Once Every l Retueling Outage Test;"

SP 2103, "22 Turbine-Driven Auxiliary Feedwater Pump Once Every Refueling Outage Test,"

SP 1102, "11 Turbine-Driven Auxiliary Feedwater Pump Monthly Test,"

SP 1100, "12 Motor-Driven Auxiliary Feedwater Pump Monthly Test,"

l SP 2100, "21 Motor-Driven Auxiliary Feedwater Pump Monthly Test,"

SP 2102, "22 Turbine-Driven Auxiliary Feedwater Pump Monthly Test."

Response to Violation 1 Reason for the Violation The Prairie Island Nuclear Generating Plant had implemented pump performance I testing acceptance criteria in accordance with ASME B&PV Code Section XI criteria.

Attachment

. November 14,1997

• Page 2 The ASME acceptance criteria were not conservative for AFW pump design basis flow

, requirements considering instrument inaccuracies, pump recirculation flow, and allowances for steam generator safety valve setpoliM variance.

Corrective Actions Taken end Results Achievad All monthly and refueling outage AFW surveillance tests (SP1103, SP1101, SP2103, SP2101, SP1102, SP1100, SP2102 and SP2100) have been updated with appropriate acceptance criteria.

The revised acceptance criteria have always been met by the AFW pumps, except previously when one pump was declared out of service for not meeting its ASME Section XI acceptance criteria. Three of the AFW pumps installed in 1973 are stillin service and operable with the revised acceptance criteria. The AFW pumps are operable with some margin to the new acceptance criteria. Prairie Island is investigating several options to improve the AFW pump performance margin.

Benchmark data has been gathered during the current Unit 1 refueling outage.

Verification calculations to confirm hydraulic model results are in progress.

Corrective Steos That Have Been or Will Be Taken to Avoid Further Violations Completion of previous Prairie Island initiatives, coupled with a review of all ASME Section XI pumps, has yielded a comprehensive review of the Prairie Island ASME Section XI testing program. ASME Section XI valve limiting stroke time design basis review was started in 1996. The review was completed in July 1997, with all valves determined to be operable. A smell number of surveillance test procedures required revision. These procedure changes have been completed.

ASME Section XI check valve testing full flow values were reviewed and documented during the Prairie Island third ten year program development.

ASME Section XI pump performance limits have also been reviewed. The AFW pump surveillance test acceptance criteria were reviewed and revised during the SSOPl.

Cooling Water pump criteria were previously reviewed. The review determined the ASME Section XI limits were conservative to the USAR stated design requirement, for one Cooling Water pump supplying one train of safeguards equipment. Safety injection pump criteria were previously revised as noted in the Notice of Violation. However, an NSP Quality Assurance department audit conducted at the same time as tne SSOPl ,

found that the Safety injection pump USAR design criteria were not conservative to the ACME Section XI110% criteria in one small area. The Safety injection pumps' performance was verified to meet the more restrictive ASME criteria. Unit 1 Safety injection pump performance test procedures were revised before use during the Oc'ober 1997 refueling outage. Residual Heat Removal pump and Containment Spray

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e Attachment

,_ ._* November 14.1997

-- Page 3 pump criteria were reviewed and found to be acceptablo. Margin exists on Residual Heat Removal and Containment Spray pumps between the ASME Section XI criteria and the USAR design requirements, considering instrument inaccuracies. Component Cooling and Control Room Chilled Water pump capacities exceed the DBA loads listed in the USAR or applicable design documents. The extra capacities available from these closed loop system pumps ensure test acceptance criteria exceeds USAR

- requirements.

The design criteria gathered during the valve limiting stroke time reviews and the pump performance criteria reviews is being incorporated into Prairie Islands ASME Section XI program coritrol document H10.1. Any future cornponent test procedure changes will have easy reference to the design criteria. Engineering support personnel have received training on these changes to H10.1.

Date When Full Comollance Will Be Achieved Pump and valve test procedures described above have been revised. Full compliance has been achieved.

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Attachment

. Ncvember 14,1997 Pege 4 VIOLATION 2 10 CFR 50.71(o),' Maintenance of Records, Making of Reports," requires, in part, that each license periodically update the final safety analysis report (FSAR)

(now know as the USAR at Prairie Island) to assure that the information included in the FSAR contains the latest mater;al developed.

10CFR50.71(e)(4) requires, in part, that revisions be filed such that the intervals between successive updates to the USAR do not exceed 24 months. It further states that the revisions must reflect all changes up to a maximum of 6 months prior to the date of filing.

The applicable section of the FSAR, now titled the Updated Safety Analysis Report (USAR), is Section 11.9.3," Performance Analysis Condensate, Feedwater, and Auxiliary Feedwater Systems" Contrary to the above, as of May 16,1997, the licensee had not assured that the information included in the FSAR contained the latest material developed and had not updated the FSAR periodically, as required in 10 CFR 50.71.

Specifically, in October 1992 the licensee identified that the 400 gpm Auxiliary Feedwater Pump (AFW) flow rue specified in USAR Section 11.9.3 Ur Jer the Main Feedwater Line Rupture accident scunario disagreed with actual Auxiliary Feedwater pump performance capabilities of approximately 200 gpm with only one pump available. Since October 1992, three opportunities to update this section of the USAR were available, yet the revisions of September 1993, June 1994 and December 1995, did not contain the latest material developed or reflect all changes prior to the date of the filing. (01023)

Re nonse to Violation 2 Reason for the Violation The Prairie Island design basis analysis of record for Main Feedwater Line Rupture is stated in the October 1969 Westinghouse letter PlW-P-540, indicating a 200 gpm requirement for Prairie Island specific analysis. As noted in the Notice of Violation, Prairie Island initiated a Design Basis Document Follow On Item A0781 in October 1992 describing the inconsistency with the USAR text on Main Feedwater Line Ruptuie analysis. Operability and reportability were assessed. The Nuclear Analysis Depcrtment was requested to verify the Main Feedwater Line Rupture analysis with an alternate calculation. This item was inappropriately given a low priority and not completed until 1997.

Attachment November 14,1997

• Page5 Corrective Actions Taken and Results Achieved The Nuclear Analysis Department's verification of the Main Feedwater Line Ruptuie analysis by alternate calculation was completed May 1997. The safety evaluation to incorporate the USAR change was approved July 1997. The USAR revision was submitted to the NRC in September 1997.

Corrective Steps That Will Be Taken to Avoid Further Violations:

Prairie Island's configuration management efforts over the past few years has resulted in the development and verification of 34 Design Basis Documents. This effort resulted in 910 Follow-On items (FOls) with 1311 recommended action items. All 910 FOls were assessed (100%) which included operability and reportability determinations,851 FOls are closed (94%) ,1200 actions are completed (92%).

Efforts to close the remaining action items are in progress.

Ninety-five action items pertained to updating the USAR, with 70 items complete as of August 8,1997. The September 1997 USAR submittal incorporated eleven rnore items for a total of 85% complete at this update. Plans are to complete the remaining fou.4een items over the interval before the USAR submittal oflate 1998.

Date When Full Compliance Will Be Achieved The USAR update of Main Feedwater Line Rupture was submitted in September 1997.

Full compliance has been achieved.

A

o Attachmer.t

> November 14,1997

• Page 6 VIOLATION 3 10 CFR Part 50,- Appendix B, Criterion XVI, " Corrective Action," requires, in part, that conditions adverse to quality are promptly identified and corrected; and in the case of significant conditions adverse to quality, the cause of the condition shall be documented, appropriately reported to levels of management, and corrective action taken to preclude repetition.

A. Contrary to the above, as of May 16,1997, the ticensee had not resolved a significant condition adverse to quality that was identified on March 6,1991, and

- documented on the assessment of Operating Experience Document NSD-TB 11, "High Head Safety injection". Specifically, the assessment documented that design requirements -- such as flow - had not been adequately considered when the safety injection pump surveillance procedures acceptance criteria were determined and there was a need to ensure that design requirements were correctly incorporated for other pumps' surveillance test acceptance criteria.

Corrective action was not taken for the Auxiliary Feedwater, Residual Heat Removal, and Containment Sprsy Pumps. This was demonstrated when the NRC inspectors determined that the Auxiliary Feedwater Pump Surveillance tests' acceptance criteria would have allowed an AFW pump to be cunsidered operable even if the pump parameters were below the minimum design requirements. (01033)

B. Contrary to the above, as of May 16,1997, the licensee had not resolved a condition adverse to quality that was identified on November 18,1992, and documented on Configuration Management Follow-On item FOI [A]O781, " Basis For AFWP Requiremente After Line Break". Specifically, FOI[A]O781 documented a deviation from the updated final safety analyCs (USAR) in that the AFW pumps were not in conformance with the 400 gpm flow rate for a main feedwater pipe rupture accident scenario as specified in section 11.9.3 of the USAR with only one pump available. The licensee failed to promptly correct the deviation by demonstrating that the AFW pump capacity of approximately 200 gpm with on!v one pump available would be sufficient during a main feedwater pipe rupture. (01043) 3 Response to Violation 3 Reason for the Violation The Prairie Island staff has been proactive in identifying problems, and maintaining equipment operability and reliability. Numerous problems of generic significance have been identified by Prairie Island staff (e.g., Loss of Feedwater ATWS AFW l

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Attachment

, November 14,1997

' Page 7 performance, Containment pressure response to Cont. Spray versus Fan Coll Units, dilution events at cold shutdown, ATWS power setpoint). However, Prairie Island has not always bcon timely in resolving issues. In response to untimely corrective action program concerns noted in the 1997 Aux Feedwater System SSOPl , NSP assessed its corrective action program. This assessment identified the following concerns:

. Corrective action items locked management involvemen, in prioritizatir>n.

. Many separate corrective action vehicles lead to a poor understanding of the wnole program.

. Resources were not allocated to promptly resolve issues.

• The status of some corrective action programs was not reported to upper management for prioritization and resource loading.

Corrective Actions Taken and Results Achieved Actions to review the operability and reportability determinations made in previous FOI assessments were committed to in LER 1-96-13 on cable tray separation issues. A review of a sample of previous assessments was completed in October 1996.

Management review of old OEA recommendations was completed in July 1997. The items were reviewed for regulatory significance, priority and schedule. Management expectations for timely closure were communicated to the staff.

An NSP Quality Assurance Department Finding on ORA recommendations led to process revision in April 1997. This process change provides more management involvement in OEA prioritization, by requiring management concurrence on the due dates and any scheduled completion dato chenges.

A corrective action process ov;ner was named in September 1997. The Employee Observation Reporting system was revised in September 1997. A new condition reporting system which consolidates mariy correctiva action vehicles was introduced in mid October 1997. These changes should improvs understanding and prioritization of corrective action items. Better tracking of these items shouid assist in proper resource loading to resolve the actions.

Additional personnel resource authorizatioris were approved in February 1997 and these vacancies are being filled.

Corrective Steos That Will De faken to Avoid Further Violations in response to untimely corrective action concerns roted in the July 15,1997 SSOPl Notice of Violation, NSP committed to the following additional program changes. Refer

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e Attachment l

.. November 14,1997  ;

• Page 8 l 7

to the August 15,1997 response to Notice of Violation.

e Institute a management oversi0ht committee by December 1997 ,

, e improve corrective action status reporting functions by December 1997 e Perform industry review of effective corrective actions programs by December 1997

. Institute additional corrective action program improvements in 1998 Date When Full Comoliance Will Be Achieved Design requirements have been proper!y incorporated into the AFW pump surveillance test acceptance criteria. Additionally, AFW pump flow rate specified in the USAR, section 11.9.3 for Main Feedwater Line Rupture has been corrected. Some corrective '

action program enhancements have been completed to date. Other corrective actions listed in the August 15,1997 response that address untimely corrective action will be

-completed in 1997 and 1998. Full compliance has been achieved.

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