05000282/FIN-2018001-02
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Finding | |
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| Title | Questions Regarding the Corrective Action and Aging Management Programs Following the Discovery of 122 DDCLP FOST Vent Piping Degradation |
| Description | On November 28, 2017, the inspectors identified a small hole in the vent piping for the below-ground 122 DDCLP FOST (located outside and adjacent to the plant screenhouse). The station generated AR 501000005894 and the shift manager declared the supported 22 DDCL pump operable-but-degraded with a temporary procedure change to AB4, Flood as a compensatory measure and wrapping of the pipe to preclude foreign material intrusion. The site backed up the immediate operability determination with a POD, evaluated past operability (no issues identified) and, subsequently replaced the affected portion of the pipe to restore full qualification. The inspectors concluded that these short term actions were acceptable to address the issue, but identified several concerns regarding prior actions to address the vent pipe corrosion. On March 1, 2018, the inspectors were provided the final evaluations for AR 501000005894. After review, the inspectors were concerned that the evaluations did not perform a sufficient review of: whether the corrective action program properly dispositioned corrosion of the pipe when first identified in July of 2015;whether the corrective action program and aging management program (AMP) performed as required to correctly classify and correct and/or manage the corrosion aging mechanism; and whether the extent of cause/condition for the adjacent 121 DDCLP FOST vent pipe was properly addressed.The inspectors passed these concerns to individuals in the engineering and regulatory affairs departments, but the licensee then stated that the evaluations provided on March 1, were, in actuality, still in a revision/review phase. The licensee stated that the final evaluations would likely address the inspectors concerns. On March 22, the inspectors were provided the final evaluations, but it appeared that only minor changes were made and the inspectors concerns were not addressed. On March 28, the inspectors again voiced their concerns with the licensee and two new ARs (501000010169 and 501000010178) were created documenting the following:the AR written identifying corrosion of the piping in July of 2015 was not evaluated under the AMP, the condition was determined to be operable and fully qualified, and it was closed to a work request to re-coat the piping but was never performed.the AR written in April of 2016 again noted the corrosion, but was closed to a non-conservative evaluation, the issue was not evaluated under the AMP, operability was again assessed as operable and fully qualified, and a work request was issued to apply a coating (not completed until May of 2017)
12 the AMP engineer was not consulted in 2015 or 2016 to determine if/how the issue fit into the AMP requirements for increased monitoring, development of acceptance criteria, and final corrective actions.Planned Closure Actions: To resolve this item, the inspectors will review planned actions regarding the degraded 121 DDCLP FOST vent pipe, further extent of condition reviews, and review planned licensee condition and causal evaluations regarding programmatic and/or human performance aspects of the issue.Licensee Actions: At the end of the inspection period, the licensee began excavation activities to replace the 121 DDCLP FOST vent pipe and had apparent cause and extent of condition evaluations in progress.Corrective Action Program References: ARs 501000005894, 501000010169 and 501000010178. |
| Site: | Prairie Island  |
|---|---|
| Report | IR 05000282/2018001 Section 1R18 |
| Date counted | Mar 31, 2018 (2018Q1) |
| Type: | URI: |
| cornerstone | Mitigating Systems |
| Identified by: | NRC identified |
| Inspection Procedure: | IP 71111.18 |
| Inspectors (proximate) | L Haeg P Laflamme A Shaikh S Bell E Fernandez K Riemer |
| INPO aspect | |
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Finding - Prairie Island - IR 05000282/2018001 | |||||||||||||||||||||||||||||||||||||||||
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Finding List (Prairie Island) @ 2018Q1
Self-Identified List (Prairie Island)
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