05000306/FIN-2011005-07

Finding

Title

Licensee-Identified Violation

Description

Title 10 CFR 50.59 states that a licensee may make changes in the facility as described in the final safety analysis report (as updated), make changes in the procedures as described in the final safety analysis report (as updated), and conduct tests or experiments not described in the final safety analysis report (as updated) without obtaining a license amendment pursuant to Part 50.90 as long as a change to the TS is not required and the change, test or experiment does not meet any of the criteria in Paragraph 50.59(c)(2). Paragraph 50.59(d)(1) states that the licensee shall maintain records of changes in the facility, of changes in procedures, and of tests and experiments made pursuant to paragraph (c) of this section. These records must include a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment. Contrary to the above, on October 11, 2011, licensee personnel made changes to procedures as described in the final safety analysis report (as updated) as part of implementing a compensatory measure and supporting continued operability of the D1 EDG without creating a written record which provided the bases for the determination that the change did not require a license amendment. The NRC considered failures to comply with the requirements of 10 CFR 50.59 as violations that impacted the regulatory process. As a result, the NRC dispositioned these types of issues using the traditional enforcement process. However, the underlying technical issue was evaluated using the SDP. Based upon the information available during the inspection, the inspectors determined that the underlying technical issue was associated with a lack of configuration control which caused the installation of potentially improper fuses in the D1 EDG metering circuitry. The inspectors determined that the failure to properly control the configuration of the D1 EDG fuses was a performance deficiency which required evaluation using the SDP. The inspectors determined that this issue was more than minor because, if left uncorrected, the improper configuration control could result in safety-related equipment being improperly protected from electrical faults (a more significant safety issue). The inspectors determined that the underlying technical issue was of very low safety significance because it did not result in a loss of safety function for any mitigating system. In accordance with the NRC Enforcement Policy, the licensees failure to comply with 10 CFR 50.59 was classified as a Severity Level IV violation since the underlying technical issue was of very low safety significance (Green), was not willful or repetitive, and was entered into the licensees CAP as CAP 1307933. Corrective actions for this issue included ensuring that personnel were aware of the requirement to perform a 10 CFR Part 50.59 evaluation for compensatory measures used to maintain operability.

07
Site:	Prairie Island
Report	IR 05000306/2011005 Section 4OA7
Date counted	Dec 31, 2011 (2011Q4)
Type:	NCV: Green
cornerstone	Initiating Events
Identified by:	Licensee-identified
Inspection Procedure:
Inspectors (proximate)	R Baker S Bell D Mcneil D Oliver K Riemer K Stoedter M Phalen P Voss P Zurawski
INPO aspect
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v • d • e

Finding - Prairie Island - IR 05000306/2011005

2(4)3(13)4(9)5(9)6(0)7(0)8(0)9(0)10(1)11(0)12(2)201(0)202(0)403(1)404(0)405(2)406(0)502(1)14(0)

IR 05000306/2011005: 1 2 3 4 5 6 7 8 9

Finding List (Prairie Island) @ 2011Q4

CCA Matrix: 2011Q4

	Q	CCA	Title
05000282/FIN-2011002-04	2011Q1		Evaluation of Equipment Stored near Safety-Related Equipment
05000282/FIN-2011002-01	2011Q1	H.4 H.5	Flammable Gas Cylinders Stored in Safety-Related Area
05000282/FIN-2011002-02	2011Q1	P.3	Failure to Appropriately Complete an Operability Recommendation for the Unit 1 Battery Calculations
05000282/FIN-2011002-03	2011Q1	P.2	Failure to Appropriately Complete an Operability Recommendation on the Unit 1 Fuel Oil System
05000282/FIN-2011003-05	2011Q2		Evaluation of Equipment Stored near Safety-Related Equipment
05000282/FIN-2011403-01	2011Q2	H.8	Security
05000282/FIN-2011010-01	2011Q2		Failure to Ensure that the Train A and Train B DC Electrical Power Subsystems Remained Operable in Modes 1 through 4
05000282/FIN-2011003-10	2011Q2	H.5	Failure To Prescribe Appropriate Procedure For In-Service Testing of Check Valves
05000282/FIN-2011003-09	2011Q2	H.2	Alternate Methods Were Not Developed for Monitoring Inaccessible Susceptible Locations
05000282/FIN-2011003-08	2011Q2	P.5	Failure to Evaluate the Effects of Dynamic Loads at the CS Discharge Piping
05000282/FIN-2011003-07	2011Q2	P.5	GL 2008-01 Evaluations Did Not Adequately Verify the Design for Susceptible Locations of Gas Accumulation in Piping Systems
05000282/FIN-2011003-06	2011Q2		No Full Flow Testing of PORV Air Supply Check Valves
05000282/FIN-2011003-02	2011Q2		Failure to Assess the Impact of Changes in the Plants Isotopic Profile
05000282/FIN-2011003-01	2011Q2	H.2	Failure to Maintain Reactor Head Height/Distance Limitation From Reactor Vessel
05000282/FIN-2011502-01	2011Q2		Incomplete and Inaccurate Emergency Action Level Change Submittal
05000306/FIN-2011003-03	2011Q2		Unit 2 Reactor Trip during Severe Weather
05000306/FIN-2011003-04	2011Q2		Multiple SAMG Procedures not Consistent with Industry Guidance
05000306/FIN-2011004-01	2011Q3	H.14	Radiation Monitors Not Fully Scoped Into or Assessed by the Maintenance Rule Program
05000306/FIN-2011004-05	2011Q3		Failure to Incorporate Revised Battery Room Temperature Information into Existing Operability Recommendation
05000306/FIN-2011004-08	2011Q3	P.5	Unit 2 Reactor Trip due to Mis-operation of Substation Breakers
05000282/FIN-2011004-07	2011Q3		Failure to Provide Complete and Accurate Information in a Licensee Event Report
05000282/FIN-2011004-04	2011Q3	H.8	Failure to Make Eight Hour Report Pursuant to 10 CFR 50.72
05000306/FIN-2011004-02	2011Q3	H.8	Corrective Action Assignments Closed Without Completion of Tasks
05000306/FIN-2011004-06	2011Q3		Failure to Provide Complete and Accurate Information in a Licensee Event Report
05000306/FIN-2011004-03	2011Q3	H.8	Failure to Make Eight Hour Report Pursuant to 10 CFR 50.72
05000306/FIN-2011005-04	2011Q4	H.14	Failure to Complete Immediate Operability Determination on Molded Case Circuit Breakers
05000282/FIN-2011012-01	2011Q4		Flammable Gas Bottles Installed and/or Stored in the Auxiliary Building
05000282/FIN-2011012-02	2011Q4	H.13	Failure to Correct a Condition Adverse to Quality
05000306/FIN-2011005-01	2011Q4		Potential Technical Specification NON-COMPLIANCE While Completing Repairs on Motor Damper 32421
05000306/FIN-2011005-03	2011Q4		Potential Maintenance Rule Scoping Issue for Residual Heat Removal Pump Pit Sump Pumps and Level Switches
05000306/FIN-2011005-05	2011Q4		Potential Safety System Functional Failure Due to Steam Exclusion Damper Issues
05000306/FIN-2011005-02	2011Q4		Appendix R Fire Barrier Degraded Between Fire Areas 118 and 128
05000282/FIN-2011405-01	2011Q4	H.14	Security

Self-Identified List (Prairie Island)

	Q	Title
05000282/FIN-2011003-11	2011Q2	Licensee-Identified Violation
05000282/FIN-2011003-12	2011Q2	Licensee-Identified Violation
05000282/FIN-2011003-13	2011Q2	Licensee-Identified Violation
05000306/FIN-2011004-09	2011Q3	Licensee-Identified Violation
05000306/FIN-2011005-07	2011Q4	Licensee-Identified Violation
05000282/FIN-2011405-02	2011Q4	Security
05000306/FIN-2011005-06	2011Q4	Licensee-Identified Violation
05000306/FIN-2011005-08	2011Q4	Licensee-Identified Violation
05000306/FIN-2011005-09	2011Q4	Licensee-Identified Violation

[Prairie Island Findings full list]

05000306/FIN-2011005-07

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