IR 05000282/2022003
| ML22300A183 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 11/01/2022 |
| From: | Laura Kozak NRC/RGN-III/DORS/RPB3 |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2022003 | |
| Download: ML22300A183 (1) | |
Text
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - INTEGRATED INSPECTION REPORT 05000282/2022003 AND 05000306/2022003
Dear Mr. Domingos:
On September 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Prairie Island Nuclear Generating Plant. On October 7, 2022, the NRC inspectors 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.
Two findings of very low safety significance (Green) are documented in this report. Two of these findings involved violations of NRC requirements. We are treating these violations as non-cited violations (NCVs) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violations or the significance or severity of the violations documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Prairie Island Nuclear Generating Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Prairie Island Nuclear Generating Plant.
October 31, 2022 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, Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety 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:
05000282/2022003 and 05000306/2022003
Enterprise Identifier:
I-2022-003-0053
Licensee:
Northern States Power Company
Facility:
Prairie Island Nuclear Generating Plant
Location:
Welch, MN
Inspection Dates:
July 01, 2022, to September 30, 2022
Inspectors:
V. Petrella, Resident Inspector
K. Pusateri, Resident Inspector
E. Rosario, Reactor Inspector
D. Tesar, Senior Resident Inspector
Approved By:
Laura L. Kozak, Acting Chief
Reactor Projects Branch 3
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated 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
Failure to Comply with Licensing Basis Requirements for Implementation of NFPA 805,
"Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2022003-01 Open/Closed
[H.6] - Design Margins 71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2 license condition 2.C.4 and 10 CFR 50.48(c) when the licensee failed to maintain compliance with their NFPA 805 license basis. Inspectors questioned the ability of the relay and cable spreading room CARDOX CO2 flooding system to establish and maintain the required concentration of CO2 per their NFPA 805 Section 3.10.1 compliance documents. The licensee determined that the CO2 concentration could not be maintained for the 15 minutes specified in their licensing basis and entered this condition into their corrective action program (CAP) as CAP 501000064651.
Fuel Assemblies Improperly Positioned Within the Spent Fuel Pool Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000282/2022003-02 Open/Closed
[H.12] - Avoid Complacency 71111.12 A self-revealed finding and associated NCV was revealed on August 17, 2022, when the licensee entered the current spent fuel pool (SFP) configuration into their ShuffleWorks program in preparation for new fuel receipt. The software identified that the licensee had failed to maintain compliance with Technical Specification (TS) 3.7.17 in that 29 spent fuel assemblies were not in locations compliant with TS 4.3.1.1.
Additional Tracking Items
None.
PLANT STATUS
Unit 1 began the inspection period at rated thermal power. Unit 1 entered coast down at 09:27 on September 20, 2022, in preparation for the upcoming refueling outage. Unit 1 remained at full-achievable power for the remainder of the inspection period with full-achievable power of approximately 83.5 percent at the completion of the inspection period.
Unit 2 began the inspection period at rated thermal power. On September 8, 2022, at 07:00, the unit was down powered to approximately 40 percent rated thermal power for turbine control valve testing and other corrective maintenance. The unit was returned to full-rated thermal power on September 8, 2022, at 15:42, and remained there the remainder of the inspection period, with the exception of brief power reductions to perform surveillance testing or flexible power operations.
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 performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. 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.
REACTOR SAFETY
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (5 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1B train component cooling system during 'A' train work window on August 9, 2022
- (2) Unit 2B train auxiliary feedwater system on August 30, 2022
- (3) Unit 2 bus 211 on September 8, 2022
- (4) Unit 2 21 battery and related direct current
- (dc) distribution panels on September 9, 2022
- (5) Unit 1 residual heat removal (RHR) 'A' train system walkdown on September 23, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Post fire safe shutdown fan operation and NFPA 805 compliance on July 28, 2022
- (2) Fire Zone (FZ) 25, elevation 735', records room and hot instrument shop on August 8, 2022
- (3) FZ 84, Unit 1 normal switchgear room buses 13 & 14, elevation 715' on August 24, 2022
- (4) FZ 35, elevation 695', battery rooms 21 & 22 on August 24, 2022
- (5) Fire Zone 1, turbine building, elevation 695', battery rooms 11 & 12 on August 24, 2022
- (6) Unit 2 containment spray pump room on July 11, 2022
- (7) Fire Area 90 diesel generator building on August 25, 2022
- (8) Cardox system NFPA 12 and licensing basis compliance on July 13, 2022
71111.07 SIX - Heat Exchanger/Sink Performance Ultimate Heat Sink Containment Device and Dam (IP Section 03.05)
The inspectors evaluated the ultimate heat sink performance containment device and dam on the following:
- (1) Intake bay
71111.07T - Heat Exchanger/Sink Performance Heat Exchanger (Service Water Cooled) (IP Section 03.02)
The inspectors evaluated heat exchanger performance on the following:
- (1) D2 emergency diesel generator jacket water heat exchanger, cooled by service water
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01) (3 Samples)
- (1) The inspectors observed and evaluated licensed operator performance in the control room during downpower for turbine control valve testing and gland seal leak offline repair on September 8, 2022.
- (2) The inspectors observed and evaluated licensed operator performance in the control room during return to rated thermal power (RTP) following maintenance on September 8, 2022.
- (3) The inspectors observed and evaluated licensed operator performance in the control room during flexible power operation downpower and return to RTP on September 29, 2022.
Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)
- (1) The inspectors observed and evaluated simulator scenario (DEP) on August 2, 2022.
71111.12 - Maintenance Effectiveness
Maintenance Effectiveness (IP Section 03.01) (4 Samples)
The inspectors evaluated the effectiveness of maintenance to ensure the following structures, systems, and components (SSCs) remain capable of performing their intended function:
(1)22 auxiliary building makeup air handling unit maintenance and return to service on August 8, 2022 (2)11 electrohydraulic control oil pump leak and repair on July 27, 2022
- (3) Flood door 46 degradation and maintenance rule evaluation on August 24, 2022
- (4) Fuel assemblies improperly located within spent fuel pool (SFP) during new fuel receipt preps on August 17, 2022
Quality Control (IP Section 03.02) (1 Sample)
The inspectors evaluated the effectiveness of maintenance and quality control activities to ensure the following SSC remains capable of performing its intended function:
- (1) Quality control verification sample on July 1, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
(1)11 electrohydraulic oil leak (emergent) and repair on July 27, 2022
- (2) Bus 26 UV relay OMICRON test on July 27, 2022
- (3) D6 diesel relay replacement on August 3, 2022 (4)22 component cooling HX outlet control valve work window on August 1, 2022
- (5) Risk assessment for upcoming downpower and gland seal replacement on September 7, 2022 (6)risk assessment associated with turbine control trouble alarm 'A' channel on September 14, 2022
- (7) D5 diesel relay replacement on September 14, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (5 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
(1)27A/B12 bus 11 undervoltage relay replacement on July 22, 2022
- (2) Pressurizer power-operated relief valve (PORV) block valve operability on July 5, 2022
- (3) Containment isolation valve operability on July 5, 2022
- (4) 'B' cooling water header following CV-31655 limiting stroke time failure on July 27, 2022
- (5) D6 operability with room dampers not controlling normally on September 26, 2022
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02) (2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (8 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) D5 diesel post-maintenance testing following relay replacement on September 14, 2022
- (2) Work Order (WO) 700097207, "Replace D6 Low Voltage/Low Current Relays," on July 20, 2022
- (3) WO 700092222-12, "Steam Generator PORV controller replacement," on July 18, 2022
- (4) WO 700077983-21, "Containment Spray Pump Oiler Change," on July 11, 2022
- (5) WO 700107078, "Bus 16 Undervoltage Relay Replacement," on July 26, 2022
- (6) WO 700100167, "Stem Lube MV-32017," on August 2, 2022
- (7) WO 700097207, "Replace D6 Low Voltage/Low Current Relays," on August 4, 2022
- (8) WO 700078165, "'A' Train Pressurizer Heater Refueling Inspection," on September 13, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (3 Samples)
- (1) Surveillance Procedure (SP) 1235D, "124 Diesel Generator Fuel Oil Transfer Pump Annual Functional Test," on August 5, 2022
- (3) SP 2155B, "Component Cooling Water Pump Quarterly Surveillance," on September 28, 2022
Containment Isolation Valve Testing (IP Section 03.01) (1 Sample)
- (1) SP 2246 "Containment Isolation Valve for PRT to GAS Analyzer Quarterly Test," on August 23, 2022
FLEX Testing (IP Section 03.02) (1 Sample)
- (1) TP 1479 "Portable 12 kW Diesel Generator Functional Test," on August 11, 2022
71114.06 - Drill Evaluation
Drill/Training Evolution Observation (IP Section 03.02) (1 Sample)
The inspectors evaluated:
- (1) Emergency preparedness drill/evolution (DEP) on August 2,
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04)===
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
MS06: Emergency AC Power Systems (IP Section 02.05) (2 Samples)
- (1) Unit 1 (July 1, 2021, through June 30, 2022)
- (2) Unit 2 (July 1, 2021, through June 30, 2022)
71152A - Annual Follow-Up Problem Identification and Resolution Annual Follow-Up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:
- (1) Annual follow up of switchyard disconnect issue from 2R32 on September 7, 2022
- (2) Annual follow up of CAP 501000059751 Westinghouse RCP design on September 20,
INSPECTION RESULTS
Failure to Comply with Licensing Basis Requirements for Implementation of NFPA 805, "Performance-Based Standard for Fire Protection for Light Water Reactor Electric Generating Plants" Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2022003-01 Open/Closed
[H.6] - Design Margins 71111.05 The inspectors identified a Green finding and associated non-cited violation (NCV) of Prairie Island Nuclear Generating Plant (PINGP) Units 1 and 2 license condition 2.C.4 and 10 CFR 50.48(c) when the licensee failed to maintain compliance with their NFPA 805 license basis. Inspectors questioned the ability of the relay and cable spreading room CARDOX CO2 flooding system to establish and maintain the required concentration of CO2 per their NFPA 805 Section 3.10.1 compliance documents. The licensee determined that the CO2 concentration could not be maintained for the 15 minutes specified in their licensing basis and entered this condition into their corrective action program (CAP) as CAP 501000064651.
Description:
On September 6, 1979, per License Amendment Request 39 (and subsequent submittals),
Northern States Power Company submitted to the NRC as having a CO2 (CARDOX) fire suppression system designed to establish a 50% CO2 concentration, with capability of maintaining that concentration for 15 minutes as their basis for compliance with NFPA 12.
In NRC Inspection Report 50-282/01-05(DRS); 50-306/01-05(DRS), dated July 16, 2001, the NRC requested additional information to support resolution of an unresolved item specific to questions regarding the CO2 concentrations in the relay/cable spreading room; including CO2 leakage out of the room. Part 1 of the NRC request for Information was: Provide an evaluation which demonstrates functionality of the Fire Area 18 carbon dioxide (C02) system i.e., the ability to suppress a deep-seated fire by providing a C02 concentration of at least 50 percent for at least 15 minutes.
Prairie Islands formal response (13 NOV 2001) indicated that: Calculation M-4163-001 Rev. 1 evaluates the C02 concentrations in the Relay/Computer Room (Fire Area 18). This calculation was provided to the NRC Inspection Team. This calculation concluded that the CO2 system would effectively extinguish a deep-seated fire in this Fire Area and would provide at least 50 percent concentration for at least 15 minutes with the existing injection settings. In addition, the Licensees response indicated that: the calculation also concluded that an equivalent "double shot" capacity is available, because the 50 percent concentration can be maintained for an additional 15 minutes (total 30-minute soak time), with a properly-timed second shot of the remaining storage tank contents.
CAP 500001305680 originated on September 27, 2011, identified that during an NFPA 12
[1972 Edition] Code Compliance Review, it was discovered that calculation ENG-ME-420 was an unverified draft calculation which was not prepared in accordance with typical calculation criteria including purpose, methodology, assumptions, and inputs. M-4163-001 R1 was an approved site calculation that verified the concentration and hold times for the Cardox suppression system. The unverified relay room leakage rate in ENG-ME-420 was used as an input in M-4163-001 Revision 1 which was submitted as part of the response to NRC Requests for Information from Inspection Report 50-282/01-05 & 50-306/01-05. The NRC accepted NMCs responses to the inspection report findings based in part upon the information provided in that calculation.
CAP 500001386878 originated on June 17, 2012, identified that the Cardox system did not meet design/licensing requirements. An alternate test to determine the adequacy of the Cardox system was performed in lieu of a full discharge test to verify the design of the system. The test was performed to resolve an issue with an unverified input in the system design calculation documented in CAP 500001305680. A new calculation, ENG-ME-804, performed with the test results found that the tank level needed to be increased and the discharge timer adjusted to meet the 50 percent design concentration for a double shot capability due to the amount of leakage from the relay/cable spreading room. The site licensing basis from NRC BTP 9-5.1 was that the Cardox system was designed for 50 percent concentration for 15 minutes and the tank provides for a double shot capacity.
By letter L-PI-12-089, dated September 28, 2012 (supplemented by letters dated November 8, 2012; December 18, 2012; May 3, 2013; October 17, 2013; April 30, 2014; May 28, 2015; June 19, 2015; October 6, 2015; October 22, 2015; January 20, 2016; May 24, 2016; August 17, 2016; December 14, 2016; and March 6, 2017), PINGP submitted a license amendment request (LAR) to adopt NFPA 805 Performance-Based Standard for Fire Protection for Light Water Reactors. Enclosure 1 contained the PINGP transition report (TR) and its supporting attachments. The TR provided the required technical and regulatory assessments to enable NRC review and approval of the new licensing basis. The Xcel Energy transition report dated September 2012, described the transition methodology utilized and documented how PINGP complied with the new requirements. The purpose of the transition report was in part to:
1) explain the bases for conclusions that the fire protection program complies with 10 CFR 50.48(c) requirements; and 2) describe the new fire protection licensing basis.
A, Table B-1 of the transition report indicated that compliance with NFPA 805 Section # 3.10.1 was based upon having a CO2 suppression system for the relay and cable spreading room which was designed for a total flooding application of 50 percent concentration for 15 minutes and had a storage capacity capable of providing a double shot of CO2.
By safety evaluation report (SER) dated August 8, 2017, the NRC approved (amendments 220 and 207) Prairie Islands LAR based upon the submittals and transition report previously provided to the NRC.
NRC identified CAP 501000060642 - Potential invalidated assumption, originated on February 17, 2022, indicated that there was a potential invalidated assumption in calculation ENG-ME-804. The calculation documented the results of leakage in the relay room and indicated that the CO2 system could maintain the required concentration of CO2 in the room for a sufficient duration to meet license basis and NFPA 12 [1972 Edition] code requirements.
The calculation assumed a bias pressure of
.5 water column (WC) with a normal operating
band of
.2 - 1.0 WC. The calculation looked at a 30-day period in April when determining
bias pressure across the room. However, bias pressure changes with ventilation lineups throughout the year. In many instances the bias pressure is significantly higher (almost double) that assumed in the calculation and therefore, reasonably challenged the functionality of the CO2 system in the relay room. Specifically, the inspectors could not reasonably determine whether the CO2 system would be able to meet the requirements set forth in A, Table B-1 of the PINGP TR. As a result of the inspectors concern, the licensee performed an evaluation of the concentration profile in the relay room and determined that the CO2 system would maintain the 50 percent for a hold time of less than 15 minutes [approximately 11 minutes] when turbine-auxiliary building differential pressure was at the high end of the normal operating band (>.5 WC) as documented in CAP 501000064651.
License condition 2.C.4 states, in part, that the PINGP fire protection (FP) program incorporates NFPA 805 per 10 CFR 50.48(c) as documented in letter dated September 28, 2012. In addition, attachment A, table B-1 of the PINGP TR for NFPA 805 implementation states, in part, that compliance with NFPA 805 section 3.10.1 was based upon having a CO2 suppression system for the relay and cable spreading room which was designed for a total flooding application of 50 percent concentration for 15 minutes and had a storage capacity capable of providing a double shot of CO2. In addition, an Engineering Evaluation per License Requirement 2.C.(4)(b)1 was not performed to change the licensing basis by removing these requirements.
Contrary to the above, since September 6, 1979, the licensee failed to ensure that the relay and cable spreading room would maintain a total flooding application of 50 percent concentration for 15 minutes as documented in CAP 501000064651.
Corrective Actions: The licensee has entered this issue into their CAP. In addition, they performed an evaluation of "alternate compensatory measures" for continued use of the Cardox system as an interim measure.
Corrective Action References:
500001305680, "Cardox Fire Suppression System Calculati" 500001386878, "Cardox System Does Not Meet Design/Licen" 501000060642, "Potential Unvalidated Assumption" 501000063724, "CO2 System Needs Evaluation" 501000064651, "NRC Question - CO2 Concentration" 501000066542, "CO2 Licensing Basis"
Performance Assessment:
Performance Deficiency: The Licensee's failure to maintain compliance with their licensing basis did not comply with their license condition 2.C.4 and 10 CFR 50.48(c).
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. This finding was considered more than minor in accordance with IMC 0612, Power Reactor Inspection Reports, because it was associated with the Mitigating System cornerstone attribute of Protection Against External Factors, and affected the cornerstone objective of ensuring the availability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the inability to maintain the required concentration of CO2 for the hold time committed to in the licensing basis potentially reduced the fire suppression capacity and capability for protecting the relay and cable spreading room, therefore having an adverse impact on equipment important to safety.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. Inspectors determined the significance of the violation using IMC 0609, Appendix F, "Fire Protection Significance Determination Process", specifically Attachment 1, "Fire Protection Significance Determination Process Worksheet".
In step 1.2, table 1.2.1, inspectors assigned a category of 1.4.2 for "Fixed Fire Suppression Systems (automatic or manual)". Step 1.3 referred inspectors to IMC 0609, Appendix F 2, "Degradation Rating Guidance", where the inspectors determined that the level of degradation was "High" based upon "Gaseous Based Suppression: Design concentration achieved but cannot be maintained for sufficient time to ensure fire extinguishment."
Continuing on to Step 1.4 (specifically 1.4.2 for Fixed Fire Protection Systems), the inspectors determined that the degraded or non-functional detection or fixed suppression system did not adversely affect the ability of the system to protect any equipment important to safe shutdown based upon the probabilistic risk assessment the licensee has performed as well as procedures and actions that are in place to facilitate safe shutdown in the event of the need for control room evacuation (F5 Appendix B, "Control Room Evacuation (Fire)". Therefore, the violation was of very low safety significance and screened to "Green."
Cross-Cutting Aspect: H.6 - Design Margins: The organization operates and maintains equipment within design margins. Margins are carefully guarded and changed only through a systematic and rigorous process. Special attention is placed on maintaining fission product barriers, defense-in-depth, and safety related equipment. A crosscutter of design margins was selected because the licensee was unable to demonstrate compliance with their licensing basis, and discussion with Inspectors was required to understand what the licensing basis was. The licensee did not initially believe the 50 percent concentration for 15 minutes with a double shot capability was in their licensing basis. In addition, an engineering evaluation per License Requirement 2.C.(4)(b)1 was not performed to change the licensing basis by removing these requirements.
Enforcement:
Violation: License condition 2.C.4 states, in part, that the PINGP FP program incorporates NFPA 805 per 10 CFR 50.48(c) as documented in letter dated September 28, 2012. In addition, attachment A, table B-1 of the PINGP TR for NFPA 805 implementation states, in part, that compliance with NFPA 805 section 3.10.1 was based upon having a CO2 suppression system for the relay and cable spreading room which was designed for a total flooding application of 50 percent concentration for 15 minutes and had a storage capacity capable of providing a double shot of CO2.
Contrary to the above, since September 6, 1979, the licensee failed to ensure that the relay and cable spreading room would maintain a total flooding application of 50 percent concentration for 15 minutes. Specifically, on July 12, 2022, PINGP documented in CAP 501000064651 that they could maintain the 50 percent CO2 concentration for 11 minutes versus the 15 minutes specified in license documents. Inspectors determined this to be a performance deficiency and a violation of 10 CFR 50.48(c).
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Fuel Assemblies Improperly Positioned Within the Spent Fuel Pool Cornerstone Significance Cross-Cutting Aspect Report Section Initiating Events Green NCV 05000282/2022003-02 Open/Closed
[H.12] - Avoid Complacency 71111.12 A self-revealed finding and associated NCV was revealed on August 17, 2022, when the licensee entered the current spent fuel pool (SFP) configuration into their ShuffleWorks program in preparation for new fuel receipt. The software identified that the licensee had failed to maintain compliance with Technical Specification (TS) 3.7.17 in that 29 spent fuel assemblies were not in locations compliant with TS 4.3.1.1.
Description:
On August 15 and 16, 2022, PINGP performed fuel moves (checkerboarding) in the SFP in preparation for new fuel receipt for the upcoming 1R33 refueling outage (RFO). The fuel moves completed on these two dates were in accordance with move sheets dated August 4, 2022, which were developed utilizing the ShuffleWorks software.
On August 17, 2022, while preparing for subsequent fuel moves, reactor engineers entered the then current SFP configuration into the ShuffleWorks software. Once the configuration was entered, the software flagged several fuel assemblies that were incorrectly located within the SFP. Upon review, it was determined that 38 fuel assemblies were improperly located, 29 of which were not in compliance with TS 3.7.17 and 4.3.1.1.
The cause of the event was determined to be a Human Performance error when entering the date into the ShuffleWorks software. The year was entered as 2029 versus 2022, resulting in the software adding 7 years of additional decay time to all spent fuel assemblies when determining suitability for moves.
The licensee-initiated actions to immediately restore compliance with TS. All fuel assemblies were restored to TS compliant locations within the fuel pool at 10:32 a.m. on Friday, August 19, 2022.
Corrective Actions: The Licensee entered this issue into their CAP and initiated immediate action to restore TS compliance. TS compliance was restored on August 19, 2022, at 10:32 a.m.
Corrective Action References: 501000065627, "Fuel Assemblies not in TS Compliance"
Performance Assessment:
Performance Deficiency: The licensee's failure to maintain proper configuration control of spent fuel assemblies within the SFP was a violation of TS 3.7.17 and 4.3.1.1.
Screening: The inspectors determined the performance deficiency was more than minor because if left uncorrected, it would have the potential to lead to a more significant safety concern. This issue screened to more than minor (MTM) because if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, if left uncorrected, it could potentially challenge barrier integrity on a loss of boron concentration in the SFP.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria. The inspectors determined the significance of this issue utilizing IMC 0609, "The Significance Determination Process for Findings At-Power". Specifically exhibit 3, section E.4.a which directed them to IMC 0609, Appendix M, "Significance Determination Process Using Qualitative Criteria." The Inspectors determined that this violation screened to Green based upon the following:
1) There were no actual consequences (changes in temperature, reactivity, or radiation levels).
2) The licensee had an accident analysis, WCAP-17400-P, Supplement 1, Revision 2 which demonstrated that with a spent fuel pool full of fresh 5 weight percent U235 fuel (worst case scenario). They were shown to meet the keff accident limits, provided soluble boron was above 2030 ppm, which is less than the TS 3.7.16 limit of >= 2500 ppm (current concentration in the SFP is 2873 ppm).
Cross-Cutting Aspect: H.12 - Avoid Complacency: Individuals recognize and plan for the possibility of mistakes, latent issues, and inherent risk, even while expecting successful outcomes. Individuals implement appropriate error reduction tools.
Enforcement:
Violation: TS Limiting Condition for Operation (LCO) 3.7.17 requires that "Each fuel assembly, fuel insert, or hardware stored in the spent fuel pool shall satisfy the loading restrictions of Specification 4.3.1.1." TS 4.3.1.1 specifies that: The spent fuel storage racks are designed and shall be maintained with:
a. fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent; b. keff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties as described in USAR Section 10.2; c. keff < 0.95 if fully flooded with water borated to 400 ppm, which includes an allowance for uncertainties as described in USAR Section 10.2; d. a nominal 9.5 inch center to center distance between fuel assemblies placed in the fuel storage racks; and e. new or spent fuel assemblies, fuel inserts, and hardware loaded in accordance with figure 4.3.1-1.
Contrary to the above, it was identified that 38 spent fuel assemblies were improperly located within the SFP. Specifically, on August 17, 2022, it was identified that 29 fuel assemblies within the SFP were in locations that were not in compliance with TS 3.7.17 and 4.3.1.1.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Annual Follow-Up of Reactor Coolant Pump Casing Code Non-Compliance 71152A Inspectors conducted an annual problem identification and resolution follow-up sample (IP 71152) for CAP 501000059751, OE Westinghouse RCP design." This CAP documented that Westinghouse identified that the legacy reactor coolant pump (RCP) casing design analyses of record (AOR), which was based on two-dimensional (2D) analytical methods, did not adequately represent the casing design geometry. The original 2D analysis method was not the optimal method given the numerous and complex geometric discontinuities of the casing design. In addition to this, it was identified that the as-analyzed casing wall thickness was non-conservative with respect to thermal stress. Consequently, the ASME Code evaluations of the primary plus secondary stress ranges, the cumulative fatigue usage factor, and other elastically calculated thermal stresses were determined to be non-conservative.
After updating the elastic analysis to a three-dimensional (3D) finite element model (FEM),and considering the thicker casing, the ASME Code limits could not be met for the specified loadings and design transients. The increased RCP casing wall thickness presented a greater challenge with respect to meeting the ASME Code limits. Westinghouse determined there was no immediate impact on RCP operability because Westinghouse demonstrated through conservative elastic analysis that the conservative ASME Code limits would not be exceeded until the plant had experienced at least 120 heat up and cooldown cycles (versus the 200 cycles previously determined).
A review of the completed and proposed actions in place to address this issue revealed that the proposed corrective action to implement an Engineering Change (ECR 601000003567) is due June 30, 2023. The extended due date is due to the need for Westinghouse to update their basis documents. The inspectors verified that sufficient margin exists prior to reaching any threshold for the RCP heat up cycles. As of February 2022, the current heat up cycle count is 76 and 68 cycles respectively for Unit 1 and Unit 2, with a normal increase of one cycle every 2 years per unit on an alternating basis. The inspectors determined that based upon the vendor support required, and the margin which exists to reaching any limits, that the actions being taken are commensurate with the safety significance of the issue. The resident inspectors office has no concerns at this time.
Observation: Annual Follow-Up of Root Cause Associated with the Inadvertent De-energization of Switchyard Transformer 2RSY 71152A Inspectors selected the root cause corrective actions associated with CAP 501000057355 for an annual follow-up sample to ensure that corrective actions were commensurate with the significance, and to evaluate the timeliness of the actions taken. Inspectors reviewed the CAP documents associated with the 2RSY transformer inadvertent de-energization during the
2R32 RFO. The inadvertent opening of the disconnect caused an event resulting in
de-energization of several vital busses and a Unit 1 down power to 95 percent. The licensee was able to take prompt actions to restore the electrical buses and recover from the down power of Unit 1. The licensee conducted a root cause evaluation and determined that Risks are not adequately assessed and mitigated for Operation[s] substation switching activities. The licensee created actions to revise fleet procedures to ensure all substation switching activities are graded as high risk, requiring supervisory oversight in the field.
The inspectors determined that the actions taken were completed in a timely manner commensurate with the safety significance. The inspectors did not identify any findings or violations during the review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On October 7, 2022, the inspectors presented the integrated inspection results to Mr. C. Domingos, Site Vice President, and other members of the licensee staff.
On August 12, 2022, the inspectors presented the triennial heat sink inspection results to Mr. C. Turner, Director and Site Performance and Operations Support, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
ENG-ME-804
CO2 Concentration in the Relay and Cable Spreading
Room
M-385-FP-001
Cardox Piping Equipment Length Calc
Calculations
M-4163-001
CO2 Concentrations in the Relay and Cable
Spreading/Computer Room
500001305680
Cardox Fire Suppression System Calculation
01/01/1970
500001386878
Cardox System Does Not Meet Design/Licen
01/01/1970
501000060642
Potential Unvalidated Assumption
2/17/2022
501000061115
Unclear CO2 System Desc in FS App. K
03/08/2022
501000063724
Relay Room CO2 System
06/08/2022
501000063724
CO2 System Needs Evaluation
06/08/2022
501000064175
Inability to Resolve NRC Concern - CARDOX
06/21/2022
501000064651
NRC Question - CO2 Concentration
07/12/2022
Corrective Action
Documents
501000066542
CO2 Licensing Basis
09/18/2022
FPEE-11-038
Code Compliance Review; NFPA 12, Standard on Carbon
Dioxide Extinguishing Systems, 1972; Relay and Computer
Room, Fire Area 18
QF0739
Discussion on the Original Calculation (ENG-ME-804) and
the Recently Completed Evaluation Door 56 and 57
Opening (Minor Rev)
06/08/2022
Transition Report
Transition to 10 CFR 50.48(c) - NFPA 805,
Performance-Based Standard for Fire Protection for Light
Water Reactor Electric Generating Plants, 2001 Edition
09/2012
Miscellaneous
Transition Report
Transition to 10 CFR 50.48(c) - NFPA 805
Performance-Based Standard for Fire Protection for Light
Water Reactor Electric Generating Plants, 2001 Edition
04/2014
Calculations
Calc. No. M-
4163-001
CO2 Concentrations in the Relay and Cable
Spreading/Computer Room
Corrective Action
Documents
501000063724
CO2 System Needs Evaluation
06/08/2022
Fire Plans
F5 Appendix A
Fire Area 90 Diesel Generator Building West Side of Unit 2
Turbine Building
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CARDOX Walkthrough Document
07/13/2022
FPEE-11-038
Fire Protection Engineering Evaluation, NFPA 12 Code
Compliance Report, Relay and Computer Room
QF0739
FPEE for NPA12 Code Compliance for Fire Area 18 was
Requested for Review
08/11/2022
QF0739
Licensing Basis for CO2 System/NFPA 12
09/20/2022
QF0739
Original Calculation (ENG-ME-804), Evaluation Door 56
and 57 Opening
06/08/2022
Miscellaneous
QF0739, Request
- 236
Provide the Current Fire Protection License Basis
Requirements for CARDOX Fire Suppression System
07/20/2022
Procedures
C37.9 AOP1
Loss of Control Room Cooling
Work Orders
Maintenance Plan
10006911/7052
Annual Post Fire Safe Shutdown Portable Fan PM
Calculations
ENG-ME-347
Minimum Required Intake Bay Volume
Corrective Action
Documents
Resulting from
Inspection
501000065496
2UHS - SP 1690 Issues
08/11/2022
21 Additional Hydrographic Survey Pictures
09/02/2021
Miscellaneous
July 23, 2020, Bathymetric Survey of the Intake/Recycle
Canal and the Approach Channel
09/03/2020
SP 1690 Site Canals Hydrographic Survey
2/12/2022
SP 1690 Site Canals Hydrographic Survey
2/19/2021
SP 1128 Backflush of Emerg Bay Intake
01/02/2022
SP 1128 Backflush of Emerg Bay Intake
01/30/2022
71111.07SIX
Work Orders
SP 1128 Backflush of Emerg Bay Intake
03/05/2022
Calculations
ENG-ME-479
Tube Plugging Criteria for Unit 1 Diesel Generator Heat
Exchangers
501000062013
Missing Records for Work Order
04/06/2022
501000062161
Incomplete Information Provided to NRC
04/14/2022
501000065437
2UHS Incorrect Value in B38A
08/09/2022
501000065447
2UHS Different Values in Documents
08/09/2022
Corrective Action
Documents
Resulting from
Inspection
501000065453
2UHS Missed Place Keeping in 700031696
08/09/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000065455
2UHS: CL Flow to U1 EDG HX RM Heatup
08/09/2022
501000065457
2UHS - Typo in ENG-ME-347
08/10/2022
501000065461
2UHS Record Could not be Located
08/08/2022
501000065465
2UHS: NSR Coded Valve with SR Function
08/10/2022
501000065471
PM 3001-2-D2 Copy Paste Error
08/09/2022
501000065482
2UHS-Duct Taped Conduit by TB Elevator
08/09/2022
501000065500
2UHS LR Inspection Answers Exceed 24 Hr
08/10/2022
NF-39216-1
Flow Diagram Cooling Water - Screenhouse Unit 1 &
Unit 2
103
NF-39217-1
Flow Diagram Cooling Water - Turbine Build Unit 2
NF-39217-2
Flow Diagram Cooling Water - Aux BLDG Unit 2
Drawings
NF-39255-1
Flow Diagram Diesel Generators D1 & D2 Unit 1 & 2
Air Cooler Heat Exchanger Data Sheet
04/17/1970
Jacket Water Heat Exchanger Data Sheet
03/24/1970
Miscellaneous
Lube Oil Cooler Heat Exchanger Data Sheet
03/24/1970
NDE Reports
D2 Emergency Diesel Generators AL6XN Tubed
Replacement Heat Exchangers Air, Jacket & Lube Oil
Coolers
01/18/2017
CL/FP Pipe or CL HX Internal Inspection
01/10/2017
PM 3001-2-D2 - D2 DG 24 MNTH INSP
01/28/2019
River Water Component Inspection
01/28/2019
Work Orders
Autumn Zebra Mussel Treatment
09/21/2021
MP D5.1
Spent Fuel Pit Fuel Handling Operations
08/15/2022
SP 1272
Reactor Makeup Water and Nitrogen Containment Isolation
Control Valves Quarterly Cycling
08/23/2022
Procedures
SP 2246
Containment Isol Valve for PRT to Gas Analyzer Quarterly
Test
08/23/2022
Move Fuel in SFP into Checkerboard(U1)
08/16/2022
SP 2246 CTMT ISOL VV for PRT to GA Test
09/06/2022
WO SP 1272 - RMU WTR & N2 CNTMT ISOL CV CYC
08/23/2022
Work Orders
07/27/2022
Procedures
SP 2856
4kV Bus 26 Undervoltage Relay Test (Omicron)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Work Orders
SP 2856 - Bus 26 Under-Voltage Omicron Test
07/28/2022
ENG-ME-804
CO2 Concentration in the Relay Room and Cable
Spreading Room
Calculations
ENG-ME-804
CO2 Concentration in the Relay and Cable Spreading
Room
QF0739
What is the Impact on the Results of ENG-ME-804
Assuming the Doors Open?
2/16/2022
QF0739
Expansion Tank Level Modification...What as the Purpose
of the Modification?
08/09/2022
QF0739, Request
- 212
CAP 501000059308 States Unit 2 Side Door 56 Will Not
Unlatch Via Card Reader...
2/10/2022
QF0739, Request
- 238
For the DD Pumps, Should Speed be Taken as Part of the
IST Data to Ensure +/- 1% of Reference Speed Due to
Potential Speed Variations from the Governor
08/09/2022
Miscellaneous
QF1146
Past Operability Review, CAP: 501000064451
Relocate 21 CS PMP Oiler EC 601000002229
07/12/2022
Work Orders
Replace Foxboro Modules with NUS Module
07/18/2022
Corrective Action
Documents
501000056365
Arteche Relay Documentation Issue Including Voltage
Range Issue for RD-2 Relays
09/23/2021
Procedures
D70.12
Motor Operated Valve Stem Lubrication
Relocate 21 CS Pmp Oiler EC 601000002229
01/19/2021
PM 3115-1-11-11 PRZR HTRS INSPS
09/20/2022
PM 3115-1-11-11 PRZR HTRS INSPS
08/12/2022
Replace Foxboro Modules with NUS Module
07/18/2022
Replace D6 Low Voltage/Low Current RLYS
08/03/2022
MV-32017 LP B MS to 11 DAFWP Lube
08/02/2022
SG MS SPLY TO 11 TD AFW PMP MV Lubrication
Work Orders
27S-LV/B16 Seq Drop Out
08/25/2022
SP 1194
CARDOX (Carbon Dioxide) 18 Month System Test
SP 2089A
Train 'A' RHR Pump and Suction Valve from the RWST
Quarterly Test
Procedures
TP 1479
Portable 12 KW Diesel Generator Quarterly Functional
Test
08/11/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
SP 1194 18 MNTH CARDOX (CO2) SYS TEST
05/13/2021
SP 2089A-2A RHR PMP & SUCT VLV FRM RWST
2/28/2022
Work Orders
TP 1479 Port 12 KW DG Qrtly Func Test
08/22/2022