IR 05000282/2021011
| ML21155A065 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/03/2021 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2021011 | |
| Download: ML21155A065 (16) | |
Text
June 3, 2021
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000282/2021011 AND 05000306/2021011
Dear Mr. Domingos:
On April 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Prairie Island Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.
Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Hironori Peterson, Chief Branch 3 Division of Reactor Projects
Docket Nos. 05000282 and 05000306 License Nos. DPR-42 and DPR-60
Enclosure:
As stated
Inspection Report
Docket Numbers:
05000282 and 05000306
License Numbers:
Report Numbers:
05000282/2021011 and 05000306/2021011
Enterprise Identifier: I-2021-011-0037
Licensee:
Northern States Power Company, Minnesota
Facility:
Prairie Island Nuclear Generating Plant
Location:
Welch, MN
Inspection Dates:
April 11, 2021 to April 30, 2021
Inspectors:
A. Anderson, Physical Security Inspector
B. Jose, Senior Reactor Inspector
J. Park, Reactor Inspector
K. Pusateri, Resident Inspector
N. Shah, Project Engineer
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Prairie Island Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease (COVID-19), regional inspectors were directed to begin telework. During this time regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. In some cases, portions of an IP were completed remotely and on-site.
The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)
- (1) The inspectors performed a biennial assessment of the licensees corrective action program (CAP), use of operating experience, self-assessments and audits, and safety-conscious work environment.
- CAP Effectiveness: The inspectors assessed the CAPs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Unit 1 and 2 emergency diesel generators (EDGs).
- Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.
- Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Review of Corrective Action Program
Based on the samples reviewed, the team determined that the licensee's performance in each of these areas adequately supported nuclear safety.
Effectiveness of Problem Identification
Overall, the station was effective at identifying issues at a low threshold and properly entering them into the CAP as required by station procedures. The team determined that the station was effective at identifying negative trends that could potentially impact nuclear safety. The inspectors interviewed personnel, reviewed documents, walked down portions of the plant, and assessed licensee problem identification.
The team identified that in January 2021, the licensee had missed an opportunity to identify a condition adverse to quality (CAQ) after several safety-related components were affected by ongoing leakage from the A cooling water supply strainers. Several issues were written (CAP items 501000048188, -46948, and -48109) documenting the leakage, but none addressed the wetting of nearby safety-related components. Ironically, barriers had been set up to prevent further wetting, even though no CAP item was written. After the inspectors raised this concern, CAP item 501000049622 was issued by the licensee to address the wetted equipment. The licensee determined that the affected equipment was operable and the inspectors identified no immediate safety concerns.
Effectiveness of Prioritization and Evaluation of Issues:
ln-depth reviews of a risk-informed sampling of CAP items, work orders (WOs), and cause evaluations were completed. Issue identification and screening was generally good, based on a review of CAP documents and observations of CAP screening, Protective Action Review Board, Plant Operating Review Committee and Plant Health Committee meetings. For these meetings, the inspectors observed that the meeting logistics (quorum, etc.) were enforced and that attendees were prepared and asked good questions. The inspectors observed that the issues were generally being appropriately prioritized and evaluated for resolution, and that the corrective actions (CAs) were implemented to mitigate the risk of issues occurring that could affect overall system operability and/or reliability.
The inspectors noted that while issue evaluations were generally sound, there were several examples where additional research was needed to understand the technical basis and final resolution, primarily due to a lack of clear documentation. This issue had previously been identified in past NRC inspections and licensee self-assessments, most recently in the April 2021 licensee self-assessment conducted in preparation for this inspection. The inspectors noted that the licensee had documented this issue in the CAP and was taking corrective actions.
The inspectors also identified several examples where CAP program requirements as stated in FP-PA-ARP-01, "CAP Process," had not been followed; however, these examples did not result in an inappropriate handling of CAQs or other significant CAP issue. These examples included:
- CAP item 50100023754, "Ground Resistors undersized for EDGs" had four recommendations which were not made into actions under the CAP nor was there any discussion on how they were being addressed. One of these recommendations was later cancelled based on the risk, even though this risk assessment was not documented. The licensee documented this issue as CAP item 501000050714;
- CAP item 500000303858, which was associated with root cause evaluation 501000035531, "Repetitive Corrosion Induced Failures, was to perform a Snapshot assessment; however, this assessment was not completed. The licensee documented this issue as CAP item 501000050482;
- Three CAs for CAP item 501000036932, which was associated with a root cause evaluation for an undersized beaker being installed on one of the EDGs, were inappropriately closed to actions taken, instead of remaining open until the actions were verified completed.
The licensee documented this issue as CAP item 501000050896; and
- CAP item 501000049074 D2 LO STRNR Leak; did not follow the administrative requirements of FP-OP-ACM-01 Adverse Condition Monitoring Plan Process to track an instance of Adverse Condition Monitoring (ACM). The licensee documented this issue as CAP item 501000051144.
As with the documentation issues previously discussed, the inspectors noted that this was also a continuing issue identified in April 2021, and earlier licensee self-assessments, for which CAs had been taken.
Effectiveness of Corrective Actions:
The team concluded that the licensee was generally effective in developing CAs that were appropriately focused to correct the identified problem and to address the root and contributing causes for significant issues in order to preclude repetition. The licensee generally completed CAs in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue. For NRC identified issues, the team determined that the licensee generally assigned CAs that were effective and timely.
However, the inspectors noted that there was no clear basis for documenting the risk basis for due date extension. Attachment 8 of CAP procedure FP-PA-ARP-01, "CAP Process,"
required that "an assessment of the risk associated with extending the Activity," be documented as part of the due date extension; however, this procedure did not describe how this requirement should be met. The inspectors identified several examples where the risk assessment was lacking, in that it could not be determined how the assessor concluded that there was no risk. For example, CAP 501000023754 re: an issue with emergency diesel generator grounding resistors had "none" under the risk justification for the due date extension without any further detail. After additional information was provided by the engineering staff, the inspectors were subsequently able to conclude that the justification was supported. The inspectors were concerned with how management approval of the due dates was considered, absent a clearly documented risk basis, and how any future justifications could be properly evaluated, absent the previous documented risk assessment. Although the inspectors were able to determine that the risk assessment was appropriate for the items reviewed, this lack of documentation was a concern as discussed. The licensee documented this concern as CAP item 501000050871.
No violations or findings were identified.
Assessment 71152B The inspectors performed an expanded 5-year review of the Units 1 and 2 EDGs; specifically, by performing system walk-downs and evaluating condition reports, engineering changes, and WOs. Overall, the inspectors determined that the licensee was effectively managing issues associated with this system.
No violations or findings were identified.
Assessment 71152B The inspectors reviewed operating experience (OpE) captured in the CAP and sampled OpE from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the OpE was appropriately screened and evaluated for applicability, and was effectively used by the station. It was also noted that it was properly considered as a potential precursor in issue evaluations, and during interviews and observations of daily plant meetings, the inspectors concluded that it was seen as a useful learning tool and being used appropriately in daily plant activities.
Nuclear Oversight audits and department self-assessments were generally of good quality, thorough and critical with identified issues being properly dispositioned in the CAP. The audits and assessments were performed in accordance with licensee procedures. Of note, the inspectors observed that the overall conclusions of the licensees self-assessment of the CAP program done prior to this NRC inspection, was consistent with the inspectors observations.
No violations or findings were identified.
Assessment 71152B The inspectors observed various station meetings, including those in which new CAP items were reviewed, and interviewed a representative cross-section of station personnel.
Additionally, the inspectors interviewed the Employee Concerns Program Coordinator, reviewed recent case logs and case files and inquired about the program during interviews with station personnel.
Overall, there is a strong safety culture at the site. Workers felt encouraged to identify issues and felt encouraged to use the CAP. Generally, there was a feeling that issues would be evaluated and corrected. Generally, workers felt that that station management had taken reasonable measures to ensure that focus remained on safe operation and engagement, even given the circumstances due to COVID.
The licensee's 2020 USA safety culture survey identified a potential issue with Knowledge Transfer at the site affecting several departments, including maintenance and engineering.
This issue was captured in the CAP and several actions were underway to address this. The team did not have any issue with the actions proposed, but it is too early to assess their effectiveness.
No violations or findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 30, 2021, the inspectors presented the biennial problem identification and resolution inspection results to you and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
71152B
Corrective Action
Documents
500000309985
Modify FP-S-FSIP-17: Security Program to Evaluate Need
for Additional Training Evolutions for Strategy Changes
2/23/2020
500001184867
Adverse Trend in 11 Battery Jar/Cover Leakage
06/08/2009
500001192499
Nuclear Safety Advisory Letter RAOC Technical
Specification Actions
08/06/2009
500001227543
MS Snubbers Overloaded - Torsional Acceleration
04/16/2010
500001238619
2" MS Piping Added to High Energy Line
06/23/2010
500001494324
Potential Operable but Non-Conforming D5/D6 Fuel Oil
Day Tank
09/23/2015
500001553539
Issues with the Results Obtained for New Battery
Calculations
03/30/2017
5010000023859
Unit 1 EDG Unavailability Question
05/28/2019
501000007086
Main Steam Valve Maintenance Has AFW MSPI Impact
01/10/2018
501000007811
D2 Lockout During Slow Start Test
01/29/2018
501000011209
Battery 21 Has Misaligned Separator Plate
04/25/2018
501000012189
Identification of Latent OE Trend
05/20/2018
501000012293
Residual Heat Removal Flood Barriers Compensatory
Measures
2/03/2018
501000016536
Unacceptable Void Found in 2RH-11
2/04/2020
501000022183
Fuel Oil Leak on 2EG-9-53 Increased Rate
01/20/2019
501000022281
FW SYS Hanger Snubber Leaking 1-FWH-40B
01/23/2019
501000023141
EEQ DBAI; Motor Operated Valve (MOV) Grease Grading
Criteria in Procedure D70.1
03/07/2019
501000023875
2019 Problem Identification and Resolution Non-CAQ
Items for Rescreening
03/20/2019
501000023915
2019 NRC Ultimate Heat Sink Auxiliary Feedwater Room
UC DP Testing
03/06/2019
501000023925
ACE; 2019 NRC Ultimate Heat Sink (UHS) Inspection:
Auxiliary Feedwater Room Cooler Heat Exchanger
Differential Pressure Testing
04/05/2019
501000024755
Apparent Cause Evaluation (ACE); Breaker 221B-27 A
Phase Will Not Close
06/21/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000025116
ACE; 121 Motor Driven Cooling Water Pump (MDCLP) as
Found Condition - Motor Vibration High
05/30/2019
501000025908
1Q2019 Violation - 12 DDCLP Jacket Water
04/19/2019
501000026390
CL Piping Vulnerability - MIC
04/26/2019
501000026633
FW Pump Outboard Oil Leak
05/01/2019
501000027914
Received Multiple Unexpected Alarms
05/29/2019
501000028820
NRC Inspector Observations WC System
06/21/2019
501000028971
Potential U1 RCS Flow Anomaly
05/25/2019
501000029823
CV-31209 Failed PMT
07/20/2019
501000030520
ACE; Potential Diaphragm Degraded on MV-32410
09/16/2019
501000031008
Missing Recommended Actions in LMP
08/21/2019
501000031076
ACE; 2019 AFI ER.1, Equipment Reliability - Emergency
Diesel Generators (EDGs)
10/15/2019
501000031220
Snubber PI-335 Failed As-Found Test
08/26/2019
501000031991
MOVs to Be Rescoped to GL Program
09/16/2019
501000033223
2MS-15-2 Bonnet Sealing Area Degraded
10/13/2019
501000033230
MSSV RS-21-18 Failed as Found Testing
10/12/2019
501000033699
SV-37465 Venting Continuously Post SI Test
10/22/2019
501000034170
SP 1151B Unsat, Stroke Time CV-31654
10/30/2019
501000034334
Fuel Oil Leak at 2EG-9-13 Valve Stem
01/11/2019
501000034334
D5 Fuel Oil Leak at 2EG-9-13 Valve Stem
501000035150
11/26/2019
501000035213
Hole Found in 3" Fuel Oil Supply Line
2/02/2019
501000035531
Repetitive Corrosion Induced Failures
2/10/2019
501000036932
Breaker 26-16 Found Wrong Frame Size
01/24/2020
501000036932
Root Cause Evaluation (RCE); Breaker Removed from
Bus 26, Cubicle 26-16 Was Found to Be a 1200 Ampere
Breaker Instead of 2000 Ampere
01/24/2020
501000037118
CV-31654 Opening Outside of Reference
01/28/2020
501000037475
Cognitive Trend of MIC Comp Beyond RSL
2/07/2020
501000037993
CC PMP Outboard Bearing Oil Leak
2/22/2020
501000038254
2019 AF-2 Off Track
2/29/2021
501000038356
LR Fuel Oil Buried Pipe Inspection Challenge
03/04/2020
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000038616
Corrective Action Due Date Extension Not in Accordance
with FP-PA-ARP-01
04/29/2020
501000039650
CC HX Temp CV Failed to Control Temp
04/14/2020
501000039958
PMT UNSAT Due to Leak
04/23/2020
501000040752
DPM Water Drip from 11 TDAFWP CV Stem
05/16/2020
501000041444
Visible Degradation to Auxiliary Feedwater Piping
08/19/2020
501000041819
CV-39409 Stroked Outside the Limit
06/25/2020
501000041863
Ctrl Rod Lifetime Ext Assumptions
05/25/2020
501000041973
Roof Leak in 121 CR Chiller Room
06/30/2020
501000043602
U1 Flux Rate Reactor Trip
08/26/2020
501000043786
20 Problem Identification and Resolution Focused Area
Self-Assessment: A/B Corrective Action Extension
Review
09/02/2020
501000044071
PI&R Focused Area Self-Assessment: Adverse Condition
Monitoring Plan Trending
09/11/2020
501000046312
Fire Extinguisher in D4 Room Degraded
11/03/2020
501000046590
ACE - Players Did Not Respond as Expected - Limited
Scope Drill; Drill Performance
11/19/2020
501000049074
D2 Lube Oil Strainer Leak
03/03/2021
501000049074
D2 Lube Oil Strainer Cover Leakage
501000050432
Security Zones 5 and 6
04/16/2021
501000050460
Security Force Member Annual Physical - Human
Performance
04/16/2021
501000050529
Critical CC Check Valves - No PMs
04/16/2021
50100022183
Prompt Operability for D6 Fuel Oil Leakage
50100023754
Ground/Resistors Undersized for Emergency Diesel
Generators
03/01/2019
50100031909
D5/D6 Fuel Sulfur Additive Nearly Depleted
09/16/2019
50100042597
NSCA General Observation Continuous Learning CL.4
07/24/2020
50130583
ACE; Fuse Blown During CV-31621 Work
09/17/2019
606000000560
10CFR50.65(a)(3) Periodic Assessment
04/01/2020
606000000952
Self-Assessment in Preparation for License Renewal
Phase 4 Inspection
09/12/2019
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
606000001078
Focused Self-Assessment: Problem Identification and
Resolution at Prairie Island Nuclear Generating Plant
04/30/2021
609000001541
Training Revision Request
06/11/2019
60EER1547051
IER L3-16-24 Emergency Diesel Generator
610000000498
ICES 437352 Diesel Generator Air Receiver
610000000632
Westinghouse TB-19-2 Control Rod Drive
05/02/2019
610000001185
OE IRIS 486479; Ultrasonic Inspection on Palisades
Reactor Vessel Head
03/16/2021
610000001211
Operating Experience; Applicability Review of License
Renewal Interim Staff Guidance 2012-02
03/03/2021
61000000691
2168 Diesel Oil Transfer Pump Breaker Failure
06/26/2019
6100000913
501000039063 Monticello Nuclear Generating Plant QIM
Nuclear Oversight: Monticello Programs Audit Technical
Specifications
06/03/2020
610000742
Winter Weather Readiness from NERC
09/05/2019
61000588881
Clearance and Tagging Inspection Report
09/30/2019
A-DES-PINGP-2020-
Nuclear Oversight Audit on Design Control
04/24/2020
QA500000309575
Evaluate Alternate Breaching Simulations
04/15/2021
QA500000311461
Perform Evaluation on T3 IP
04/15/2021
QIM5010000046590
Players Did Not Respond as Expected During NRC FoF
Exercise
11/19/2020
QIM5010000049332
Human Performance Related Security Loggable Events -
Perform Common Cause Evaluation
03/09/2021
QIM5010000050392,
393, 394
Security Deep Dive on Protected Area Barriers
04/10-
2/2021
QIM5010000050463
Security Camera Monitor Malfunction
04/16/2021
QIM5010000050466
AVBS Control Touch Screen
04/16/2021
QIM5010000050481
X-Ray Glass Chipped
04/16/2021
QIM5010000050490
COVID19 Disinfecting Wipes Causing Hand Geometry
Errors
04/14/2021
QIM5010000050498
Thermal Optic Broken Power Switch
04/14/2021
Corrective Action
501000050482
21PIR: Action Not Performed as Written
04/13/2021
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Documents
Resulting from
Inspection
501000050714
CE 500000294364: Recommendations Not Addressed
04/20/2021
501000050871
PI&R Observation: Opportunity for Improvement
04/22/2021
501000051144
Administrative Deficiency via FP-OP-ACM-01
04/27/2021
Engineering
Changes
601000001465
Prairie Island Security Upgrades - Change Request
Report
04/15/2019
601000001947
Repair Fuel Oil Supply Line for 23 D5
60100001947
Repair Fuel Oil Supply Line for 23 D5 FO
2/02/2019
Miscellaneous
Units 1 and 2 4th Quarter Mitigating Systems Performance
Indicator AC Power Submittal
December
20
Emergency Diesel Generator System Health Reports for
D1, D2 and D5
2/01/2021
Procedures
FP-OP-OL-01
Operability
Revision 22
FP-PA-ARP-01
CAP Process
Revision 59
FP-PA-ARP-01
(QF0400)
Issue Report/Change Request Form
Revision 3
FP-PA-OE-01
Operating Experience Program
Revision 29
FP-PA-PAR-01
Performance Assessment Review Board and Performance
Assessment Oversight
Revision 18
FP-PA-RMS-01
Risk Management Screening
Revision 2
FP-S-FSIP-16
Security Training
Revision 14
FP-STND-MTG. 01
Fleet Meeting Standards - Participation
Revision 3
FP-WM-SCH-01
Online Scheduling Process
Revisions 23
and 24
NSPM-1
Quality Assurance Topical Report
Revision 14
Self-
Assessments
500000305009
MM Elevation - Snapshot Assessment
04/14/2020
500000306242
External Surfaces Corrosion SSA
2/24/2021
606000001079
INPO Mid-Cycle FSA Prairie Island
08/21/2020
60600000869
SNAPSHOT Report: Self-Assessment on 71130.04,
Equipment Performance, Testing and Maintenance and
71151, Performance Indicator Verification
06/17/2020
60600000906
SNAPSHOT Report: Self-Assessment on 71130.02,
Access Control
01/20-
24/2020
60600001360
SNAPSHOT Report: Self-Assessment on 71130.02,
03/29-
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Access Control and 71151, Performance Indicator
Verification
04/11/2021
A-INSP/TEST-
PINGP-2020-1
20 Nuclear Oversight Audit of PINGP Inspection and
Testing
06/01/2020
A-MAINT-PINGP-
2019-1
2019 NOS Maintenance Audit
06/10/2019
A-PROG-PINGP-
2019-1
2019 Nuclear Oversight PINGP Audit of Programs
10/01/2019
Nuclear Oversight
(NOS) Audit Report
2019 NOS Audit of PINGP Security (#A-SEC-PING-2019-
1)
07/15-
26/2019
Nuclear Oversight
Audit (NOS) Report
20 NOS Audit of Fleet Security and Cyber Security
(A-SEC-FLT-2020-1)
07/13-
31/2020
Work Orders
700036051
Replace D2 Monal Field Flash dP
01/12/2021
700036053
Replace D1 Shutdown Pushbutton
08/15/2018