ML072690050

Email Two Issues at Prairie Island

ML072690050
Person / Time
Site:	Prairie Island
Issue date:	09/24/2007
From:	Kivi J Nuclear Management Co
To:	Mahesh Chawla Office of Nuclear Reactor Regulation
Chawla M, NRR/DORL/LPL3-1, 301-415-8371
References
Download: ML072690050 (2)

Text

From: "Kivi, Jeffrey L." <Jeffrey.Kivi@nmcco.com>

To: "Chawla, Mahesh" <mlc@nrc.gov>

Date: 09/24/2007 4:37:40 PM

Subject:

Two Issues at Prairie Island

1. Changed Commitment to Bull 2003-02

• In our response to 8/21/03 BL 2003-02, we committed to a BMV inspection of the undervessel each outage.

• In the NRC 10/5/04 response, it stated: "NMC is requested to notify the NRC staff in writing of any changes to this commitment prior to implementation." In fact, we changed the commitment twice without prior notification to the NRC:

• On 4/18/05 we approved a change to note that the undervessel inspection could be performed within one month of the actual refueling outage (if an opportunity arose).

• On 11/8/06, we approved a commitment change (per the NRC-endorsed NEI 99-04 commitment change process) to change the inspection frequency to every other refueling outage (this was based largely on the fact that, in a review of industry and available international operating experience, no other undervessel penetration leakage had been identified and, thus, changing the frequency had limited impact on safety (but aided in maintaining dose ALARA).

• We did not inform the NRC in writing or otherwise prior to changing the commitment either time - probably because prior notification was not required by the NEI 99-04 process and, apparently, we did not capture the NRC request from their 10/5/04 letter. Per the NEI process, the correct level of notification is to include a summary in the once-per-cycle 50.59 report.

• Does your staff have a preferred means of dealing with this?

Provide written notification now or provide the summary in the 50.59 report to be submitted later this year?

2. Indication not Reported in 1R24 ISI Summary Report

• Engineering here discovered an error that occurred during the 1R24 outage - Table II of Section 6, Steam Generator Eddy Current Examination Results, should have included the indication identified as No. 4 in the excerpt below.

No. S/G LEG ROW COL PERCENT LOCATION ELEVATION STATUS 1 11 H 50 37 10 04H -0.47 <TS 2 11 H 51 38 8 02H 0.43 <TS 3 11 H 51 39 9 04H -0.51 <TS 4 11 H 51 39 9 06H -0.59 <TS 5 11 H 52 39 8 04H 0.11 <TS

• We are trying to figure out the best way to update the docket:

• Issue a letter identifying the omission (apparently the item was incorrectly deleted from the data set used to develop the ISI Summary Report).

• Issue a letter with errata pages updating Table II

• Issue a letter re-issuing the entire ISI summary report.

• Does your staff have a preferred means of dealing with this?

Jeff Kivi P.E.

Sr Regulatory Compliance Engineer Prairie Island Nuclear Generating Plant 651.388.1121 x4120

CC: "Northard, Scott D." <Scott.Northard@nmcco.com>

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Two Issues at Prairie Island Creation Date 09/24/2007 4:37:10 PM From: "Kivi, Jeffrey L." <Jeffrey.Kivi@nmcco.com>

Created By: Jeffrey.Kivi@nmcco.com Recipients nrc.gov OWGWPO03.HQGWDO01 MLC (Mahesh Chawla) nmcco.com Scott.Northard CC (Scott D. Northard)

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