ML20044D224

LER 93-007-00:on 930413,discovered That Certain Feedwater Valves,Required to Mitigate Consequences of Accident,Not Included in ASME Section XI ISI & Test Program.Caused by Failure to Interpret Requirements.Valves Tested

ML20044D224
Person / Time
Site:	Prairie Island
Issue date:	05/13/1993
From:	Hunstad A NORTHERN STATES POWER CO.
To:
Shared Package
ML20044D223	List: ML20044D222 ML20044D224
References
LER-93-007, LER-93-7, NUDOCS 9305180354
Download: ML20044D224 (9)

Text

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F ACILITY NAML pp DOCAET NUMblR A Prat p Prairie Island Nuclear Generating Plant Unit 1 05000 282 1 OF 8 Tmt sai Discovery That Certain Valves Should l Be Subject to ASME Section XI Testing  !

EVENT DATE (5) LER NUMBER (6' REPORT NUMBER (7) OTHER FACILITIES INVOLVED (8)  !

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MODE (9) N 20 402;b) 20 405te) 50 73(aH2Hiv) 73 71(b) j POWER 20 405f a H1 Hi) 50 35(c)ll) 50 73(aH2)tv) 73.71(c)

LEVEL (10) 100 20 405:aH1H..) 50.35(cH2) 50.73;aH2Hvn) OTHER i X M*t% m Abenet  !

20 405(aH1)6n) 50 73(aM2HO 50.73(aH2Hvn HA) bem and m Ted N4C l 20 405;a H1 Hrv) 50 73;aH2Hu) 50 73(aH2)tvsHB)  % 3w.y i 20 405!aH1Hv) 50.73(aH2Hini 50,73;aH2Hx)

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SUPPLEMENTAL REPORT EXPECTED (14) EXPECTED ** * *

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" SUBMISSION l c m c. m e D q c'cc w su:ssos DATO X DATE (15) j ABSTRACT On (Lintt April to 13,14031993 spaces,i both eunits were at 100%

. approomately power.

15 single spaced 1vpewntten knes) (16)The Design Basis ,

! Reconstituition effort for the Feedwater System revealed that certain  !

feedwater valves required to mitigate the consequences of an accident were not {

l included in the Prairie Island ASME Section XI Inservice Inspection and )

Testing Program. These valves should be classified as ASME Code Class 2  !

valves.  !

Subsequently, during the current development of the 3rd 10-year Interval [

Inservice Testing Program, we took an aggressive approach to determine any [

, weaknesses in the current program in order to strengthen the program for the j

future. k'e reviewed violations issued against other licensees, reviewed  ;

generic discussions of industry issues, and discussed some interpretation l questions with cognizant NRC Staff. As a result of this approach, we identified other ASME Code Class MC valves which should have been in the l current program but were not.  !

}

An evaluation of the available data for each of these valves has been made to I 1  !

determine their operability. The valves will all be tested per the requirements of ASME Section XI and have been included in the 3rd 10-year  !

interval program which will be submitted to the NRC in June 1993.  ;

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9305180354 930513 l i PDR ADOCK 05000282 S PDR

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i REQUIRED NUMBER OF DIGITS / CHARACTERS - ,

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BLOCK NUMBER OF TITLE NUMBER DIGITS / CHARACTERS l 1

1 UP TO 46 FACILITY NAME  !

l-2 DOCKET NUMBER 3 IN ADDITION O 05000 3 VARIES PAGE NUMBER [

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4 UP TO 76 TITLE  ;

6 TOTAL EVENT DATE 2 PER BLOCK {

7 TOT AL I 2 FOR YEAR i 3 FOR SEQUENTIAL NUMBER L NUMBER l

2 FOR REVISION NUMBER 6 TOTAL i 7 REPORT DATE j 2 PER BLOCK UP TO 18 - FACILITY NAME l 8

8 TOTAL- DOCKET NUMBER

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3 IN ADDITION TO 05000  ;

9 1 OPERATING MODE f 10 3 POWER LEVEL }

" CHECK BOX THAT APPLIES REQUIREMENTS OF 10 CFR UP TO 50 FOR NAME I

' 14 FOR TELEPHONE ENSEE COMACT CAUSE VARLES  !

2 FOR SYSTEM f 13 4 FOR COMPONENT EACH COMPONENT FAILURE 4 FOR MANUFACTURER NPRDS VARIES 1

'# SUPPLEMENTAL REPORT EXPECTED CHECK BOX THAT APPUES f 15 EXPECTED SUBMISSION DATE 2 PER BL CK i  !

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Prairie Island Unit 1 -

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EVENT DESCRIPTION On April 13, 1993 both units were at 100% power. The Design Basis t Reconstituition effort for the Feedwater System revealed that certain t

feedwater valves required to mitigate the consequences of an accident were not included in the Prairie Island ASME Section XI Inservice Inspection and  ;

Testing Program. These valves should be classified as ASME Code Class 2 f j valves. This omission is in violation of Technical Specification 4.2.A.2, [

which states. ,

i In addition to other specified tests, inservice testing of ASME Code Class t 1, Class 2, and Class 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable  ;

Addenda as required by 10 CFR 50, Section 50.55 (g), except where specific ,

written relief has been granted by the h1C.  !

ASME Section XI requires periodic exercising of all valves required to f mitigate the consequences of an accident. In this instance, four valves (two  !

per Unit) were not included in the Section XI program as required. >

l Subsequently, during.the current development of i'e 3rd Interval Inservice 4 Testing Program, we took an aggressive approach tu determine any weaknesses in '

the current program in order to strengthen the program for the future. We reviewed violations issued against other licensees, reviewed generic discussions of industry issues, and discussed some interpretation questions with cognizant NRC Staff. As a result of this approach, we identified other ASME Code Class MC valves which should have been in the current program but were not. The valves which had been omitted from the program based on an earlier erroneous interpretation are listed in the following table:

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F ACILITY hAME (1) oOcAET NUMBER (23 LER NUMBER (S) PAGE (3)

MQulN% REVMpd j NUMBER NUMBER r 05000 282 3 OF 8 [

Prairie Island Unit 1 93 -

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00 ,

TLxT w more space a reena. see ensonn' coo es or N8C form assA) (17}

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S U Valve # Valve Name Accident Testing Which has Been When Testing ,

T N Function Performed or Other Will Se S 1 Basis for Determining Performed to T Fuctionality the ASME

1. Section XI Reouirements FW 1 32023 11 STEAM GENERATOR TO CLOSE Stroked during Next Unit FEEDWATER ISOLATION WOTE 5 Integrated Safety cold Shutdown l 1 Injection Test FW 2 32028 21 STEAM GENERATOR TO CLOSE Stroked during 4t Unit FEEDWATER ISOLATION NOTE 5 Integrated Safety id Shutdown  ;

} Injection Test l FW 1 32024 12 STEAM CENERATOR TO CLOSE Stroked during Next Unit [

] FEEDWATER ISOLATION WOTE 5 Integrated Safety Cold shutdown l 0 Injection Test FW 2 32029 22 STEAM GENERATOR TO CLOSE Stroked & ring Next Unit

FEEDWATER ISOLATION NOTE 5 Integrated Safety Cold Shutdown i Injection Test CC 1 32095 11 EXCESS LETDOWN INLET TO REMAIN Stroked during August 1, HEAT EXCHANGER ISOLATION CLOSED Integrated $afety 1993 NOTE 5 Injection Test j CC 2 32130 21 EXCESS LETDOWN OUTLET TO REMAIN Stroked during August 1, 3 HEAT EXCHANGER ISOLATION CLOSED Integrated Safety 1993 i NOTE 5 inJeetion Test  !

h CC 1 31252 11 EXCESS LETDOWN OUTLET .TO REMAIN Stroked daring August 1, j

, HEAT EXCHANGER ISOLATION CLOSED Integrated Safety 1993 f injection Test

}

CC 2 31253 21 EXCESS LETDOWN OUTLET TO REMAIN Stroked durirf August 1, I HEAT EXCHANGER ISOLATION CLOSED Integrated Salsty 1993 Injection Test l CC 1 CC-23-1 11 EXCESS LETDOWN INLET NOTE 1 Verified Open; kext Unit HEAT EXCMANGER ISOLATION NOTE 3 Cold shutdown .

CHECK l CC 2 2CC-23-1 21 EXCESS LETDOWN OUTLET NOTE 1 Verified Open; Next Unit HE AT EXCHANGER ISOLATION NOTE 3 Cold shutdown  ;

CHECK i CC 1 32089 11 REACTOR COOLANT PUMP TO CHANGE Stroked during heat Unit i t COMPONENT COOLING INLET POSIT 10N Containment Integrated Cold Shutdown  !

NOTE 6 Leak Rate Test j k

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l FACILITY NAME (1) I DOCKET NUMBER (2) LER NUMBER (t) S' AGE (3)

LEQJEN W RU GON NJMBER NJpBER 05000 282 4 OF 8 Prairie Island Unit 1 --

93 007 - 00 rEn w m ua, a nwn .a mm coom or w<uam asvy eTu S U Valve # Velve Name Accident Testing Which Has Been When Testing j Y N Fmetion Perforned or other Will Be S I Basis for Determining Performed to T Fuctionality the ASME

1. Section XI Recuirements I CC 2 32124 21 REACTOR COOLANT PUMP TO CHANGE Stroked during Next Unit COMPONENT COOLING INLET POSITION Contaifunent Integrated Cold Shutdown NOTE 6 Leak Rate Test  ;

CC 1 32091 12 REACTOR COOLANT PUMP TO CHANGE Stroked during Next Unit +

COMPONENT COOLING INLET POSITION Containment Integrated Cold Shutdown NOTE 6 Leak Rate Test CC 2 32126 22 REACTOR COOLANT PUMP TO CHANGE Stroked during hext Unit COMPOWENT COOLING INLET POSITION Containment Integrated Cold Shutdown NOTE 6 Leak Rate Test CC 1 CC-18-1 12 REACTOR COOLANT PUMP NOTE 1 Verified Open; Wext Unit COMPONENT COOLING INLET NOTE 3 Cold Shutdown CHECK i CC 2 2CC-18-1 22 REACTOR COOLANT PUMP NOTE 1 Verified Open; Next Unit COMPONENT COOLING INLET NOTE 3 Cold Shutdown CHECK CC 1 CC-18-2 11 EEACTOR COOLANT PUMP NOTE 1 Verified Open; Next Unit  !

COMPONENT COOLING INLET NOTE 3 Cold Shutdown i I

CHECK CC 2 2CC-18-2 21 REACTOR COOLANT PUMP NOTE 1 Verified Open; Next Unit COMPONENT COOLING INLET NOTE 3 Cold Shutdown CHECK CC 1 32090 11 REACTOR COOLANT PUMP TO CHANGE Stroked during Next Unit '

COMPONENT COOLING OUTLET POSITION Containment Integrated Cold Shutdown NOTE 6 Leak Rate Test i CC 2 32125 21 REACTOR COOLANT PUMP TO CHANGE Stroked during Next Unit COMPONENT C00LikG OUTLET POSITION Containment Integrated Cold Shutdown NOTE 6 Leak Rate Test ,

CC 1 32092 12 REACTOR COOLANT PUMP TO CHANGE Stroked during Next Unit i COMPOWENT COOLING OUTLET POSITION Containment Integrated Cold shutdown i NOTE 6 Leak Rate Test CC 2 32127 22 REACTOR COOLANT PUMP TO CHANGE Stroked during hext Unit COMPONENT C00LlhG OUTLET POSITION Containment Integrated Cold Shutdown NOTE 6 Leak Rate Test  ;

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MANAGEMENT AND BJDGET, WAS WN3% DC 20501 F ACiUTY hAME {1) DOCAET NUMBE R (2) LER NUMBER (5) PAGE (3) bEO4NT.A. ftEv&ON (

NUMBER NUMBER 5 05000 282 5 OF 8  !

Prairie Island Urlt i 93 -

007 - 00  !

ext pr ma o soue e muso. ao eaasore copoes or wC Fo m assra p n i t

S U Vrrive # Valve Name Accident Testing Which Has Been When Testing .

Y N Eunction Performed or other Will Be S I Basis for Determining Performed to i Fuctionality the ASME  !

1. Section XI >

Requirements SS 1 31402 11 STEAM GENERATOR TO CLOSE Stroked during August 1, BLOWDOWN SAMPLE ISOLATION Integrated safety 1993  ;

Injection Test j t

SS 2 31639 21 STEAM GENERATOR TO CLOSE Stroked during August 1, ,

BLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 -

Injection Test SS 1 31637 11 STEAM GENERATOR TO CLOSE Stroked during August 1, ,

CLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 l Injection Test SS 2 31412 21 STEAM GENERATOR TO CLOSE Stroked during August 1, BLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 Injection Test SS 1 31403 12 STEAM GENERATOR TO CLOSE Stroked during August 1, BLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 Injection Test J

SS 2 31640 22 STEAM GENERATOR TO CLOSE Stroked during August 1, BLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 In}ection Test l

SS 1 31638 12 STEAM GENERATOR TO CLOSE Stroked during August 1, '

BLOWDOWN SAMPLE ISOLATION In ngrated Safety 1993 i Injection Test SS 2 31413 22 STEAM GENERATOR TO CLOSE Stroked during August 1,

[

BLOWDOWN SAMPLE ISOLATION Integrated Safety 1993 ,

In}ection Test .

AF 1 32242 AUXILIARY FEEDWATER TO 11 TO REMAIN Stroked during NeKt Unit STEAN GENERATOR ISOLATION OPEN; Integrated Safety Cold Shutdown l' WOTE 4 Injection Te t AF 2 32248 AUXILIARY FEEDWATER TO 21 TO REMAIN Stroked during NeKt Unit STEAM GENERATOR ISOLATION OPEN; It tegrated Safety Cold Shutdown NOTE 4 In}ection Test  ;

AF 1 32243 AUXILIARY FEEDWATER TO 12 TO REMAIN Stroked during Next Unit STEAM GENERATOR !$0LAil0N OPEN; Integrated Safety Cold Shutdown i NOTE 4 Injection Test I t

NRC CORM 366A 15 s2;

NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 W EXPIRES 5/31/95 ESTMA'ED BJRDEN PER RESPONSE TO COMPLY wiH TH:S i N80RMA' ION COLLECTION REOJEST: 53.0 HRS. FORWARO I LICENSEE EVENT REPORT (LER) COMME.cs RE2ma.3 BURDEN EsTucE TO THE woRucem .

TEXT CONTINUATION AC REC R S MAWMEC BriANOH (MNBB WWs. NMR REGJLATORY COMM:sS10N. WASHNGTON, DC 20$$5-00ct. AND TO I THE PAPERWDAK REQUCTION PRWECT (3153-01041. OFFCE Or i MANAGEMENT AND BJD3ET, WASHw3 TON, DC 23503 P ACILfTY hAME (1) oOCKET NUMiiER (2) LER NUMBER (6) FAGE(3) g SE QUE NT *AL REVSON j NUMBER NUMBER >

Prairie Island Ur.it 1 05000 282- 6OF8 93 - 007 -

00 TLxT m == srme n = pes m emonw cas, a ei ec Fonn see,9 tu)

S U Valve # Valve Name Accident Testing Which Has Been When Testing Y N Function Performed or Other Will Be

• S 1 Basis for Determining Performed to ,

T Fuctionality the ASME

1. Section XI  ;

Requirements  !

AF 2 32249 AUXILIARY FEEDWATER TO 22 TO REMAIN Stroked during Next Unit STEAM GENERATOR ISOLAT10N OPEN; integrated Safety. Cold Shutdown NOTE 4 Injection Test

• CL 1 CW-12-1 C00 LING WATER TO 11 FAN NOTE 2 Inspected June 1991 Next Unit Coll UNIT ISOLATION CHECK Cold Shutdown ,

CL 2 2CL-12-1 COOLING WATER TO 21 FAN NOTE 2 Verified Open; Next Unit C0ll UWli ISOLATION CHECK WOTE 3 Cold Shutdown i CL 1 CW-12-2 COOLING WATER 10 13 FAN NOTE 2 Inspected June 1991 Next Unit C0!L UNIT ISOLAT10W CHECK Cold Shutdown CL 2 2CL-12-2 COOLING WATER TO 23 FAN NOTE 2 Verified open; Next Unit COIL UNIT !$0LAT10N CHECK WOTE 3 Cold shutdown .

I CL 1 CW '2-3 C0 CLING WATER TO 12 FAN WOTE 2 verified open; Next Unit COIL UNIT ISOLATION CHECK NOTE 3 Cold Shutdown CL 2 2CL-12-3 CTLING WATER TO 22 FAN WOTE 2 Verified Open; Next Unit Coll UW1T ISQLAT10W CHECK NOTE 3 Cold Shutdown i

CL 1 CW-12-4 COOLING WATER TO 14 FAN NOTE 2 Verified Open; Next Unit COIL UNIT !SQLAT10N CHECK WOTE 3 Cold Shutdown CL 2 2CL-12-4 COOLING WATER TO 24 FAN NOTE 2 Verified open; Next Unit f COIL UNIT ISLtATION CHECK WOTE 3 Cold Shutdown  !

SI 1 32073 SAFETY INJECTION C TLING TO REMAIN Strc,ked during Next Unit f WATER ISOLATION OPEN Operating Procedure Cold Shutdown

• NOTE 4 C1.3

}

i SI 2 32176 SAFETY INJECTION COOLING TO REMAIN Stroked during Next Unit WATER ISOLATION OPEN Operating Procedure Cold Shutdown NOTE 4 C1.3  !

t NOTE 1: Based upon system design Technical Specification Table 4.4-1 states the "--- cooling water and }

closed cooling water system (conponent cooling) valves tare) not relied upon to prevent containnent '

leakage. The primary function of the cc check valves is to open to provide cooling to PCP and to the excess letdown heat exchanger.

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB NO. 3150-0104 a s2'

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YEAR s00 4 hAi REWsCN NJUBER NUMBER 05000 282 7 or 8  ;

s Prair.ie Island Unit 1 93 -

007 -

00 ,

TEXT in rw oc u bea. we naame;c er ec wm xra p73

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WOTE ?: The cooling water supply lines to the fan cell units are provided with a check valve inside containnent and a raanual motor operated gate valve outside contalrnent. Return lines are provided

• with a manual motor operated gate valve inside contairnent and a manual motor operated globe valve i outside containment.

In the event of accident, the cooling water supply and return isolation valves position to full open to satisfy their safeguards f metion. In the event of a fon coil unit or associated piping rupture r the cor.tainment manual isolation valves would be closed to prevent the entry of non-borated water into containment. Pressure against the closed isolation valves is maintained by 1/2-inch equalizing lines.

The check valves have no close function for accident sitigation or in taking the plant to safe shutdown. The open function of the check valve is verified as part of normal surveillance ,

associated with the fan coil unit. Technical Specification TABLE TS.4.4.1 states the "-- cooling  !

water and closed cooling water system (component cooling) valves [are) not relied upon to prevent f contairnent tenkage."

NOTE 3: (A) Our Operating Experience Assessment program data for industry operating experience leads to the conclusion that there is no reason to suspect any of the check valves are inoperable.

(B) The open function of the check valves is demonstrated as part of normal operation. A search of WPRDS data shows a f ailure to close f requency of 1.5E-6 f altures/ component-hr.

f (C) Machine history shows two of eight cooling water to containment f an colt unit check valves I were inspected in June 1991. Inspection results indicated that the valves are aging but  ;

s operable. Plans are to inspect the remaining six valves based upon diagnostic testing, j (D) The closed cooling water system (component cooling) is a chemically inert environment and free l of abrasives. i I

Based upon this information, there is reasonable assurance the non-tested or non-inspected check valves are operable. ,

WOTE 4: Each of these valves is locked in the open position by having the the motor control center supply l breaker locked b the off position (TS.3.4.B.1.d), (TS.3.3.A.1.g).

l NOTE 5: This MOV is included in our CL 89-10 MOV program.  ;

WOTE 6: This valve is open during heat-up, cooldown, and power operation with its motor control center supply breaker in the off position. The valves are accessible locally at the handwheet for cycling. ,

CAUSE OF THE EVENT  :

The cause of this event was the failure to properly interpret and implement  !

ASME Section XI requirements by plant engineering staff. It was erroneously i thought that the valves which were classified as Code Class MC (metal containment) were not required to be additionally classified as Code Class 1, 2, or 3 and were thereby inadvertently left out of the ASME Section X1 Inservice Testing program from the initial classification in 1976. This understanding was in error.

N40 FORM 366A (S 92)

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NRC FORM 366A U.S. NUCLEAR REGULATORY COMMISSION  ;

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, EXPIRES 5/31/95 ,

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INFORMA'ON COLLECTON REQUEST: 50.0 NRS.. FORAARD LICENSEE EVENT REPORT (LER) CoMMtN s REsAeN2 BvRoEN EswcE To T,E ,,onMem ,

TEXT CONTINUATION AN RECOROS MANAGEMENT BFANCH (MNBB WWS. WGAR AE3ULATony CoMM:SSoN, W AE tN3 TON. DC 20S55 0001. AND TO THE FAPERWORK REDUC'ON PRO, JECT 015:>01041. oFFCE or ,

MANAGEMENT AND BJDGET. WASHN3 TON, DC 20503 F AC!UTV NAME (1) DOCfLET NUMBER (2) LiR NUMBER (S) FAGE (3)

, nauEm RcuoN NUMBER NUMBER Prairie Island Unit 1 05000 282 8 OF 8 93 -

007 -

00 ,

b TEXT pt we space n revea. see esasore copses et NRC form MA,t (1TI j

P M4ALYSIS OF TJ1E E E.NT This event is reportable pursuant to 10CFR50.73(a)(2)(1)(B) since Technical  ;

Specification 4.2.A.2 was violated. The valves have been determined to be I operable on the basis of testing, inspection, verification of desired  :

position, and/or evaluation of historical data; this information is referenced  ;

in the above table. Since all components are believed to be operable there were no consequences to the health and safety of the public.

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CORRECTIVE ACTION ,

An evaluation of the available data (as discussed in the table above) for each of these valves has been made to determine their operability.

i The valves will all be tested per requirements of ASME Section XI per the schedule listed in the table.  !

These valves have been included in the Prairie Island ASME Section XI 3rd 10-year program, which will be submitted to the NRC in June 1993, for future testing. ,

FAILED COMPONENT IDENTIFICATION  !

None.

PREVIOUS SIMIIAR EVENTS

. Unit 1 Licensee Event Report 90-018, Rev. 1 identified certain cooling water  !

and chilled water valves which had not previously been identified as l performing an active function to mitigate the consequences of a design basis l l event and therefore should have been evaluated for inclusion in the ASME j Section XI Inservice Testing Program. The corrective action for that event [

(" Design Bases reconstitution will continue to ensure that other similar -

oversights, if they exist, will be discovered.") resulted in identification of the feedwater isolation valves reported in this event. j l

I J

NRO FORM MSA ;S B2;

_ - __ - _. _ - - _ _ _ _ _ _ _ - - _ - -