Text

Triennial Fire Protection Inspection Report 05000282/2022010 and 05000306/2022010
	ML22173A245
Person / Time
Site:	Prairie Island
Issue date:	06/24/2022
From:	Richard Skokowski; Engineering Branch 3
To:	Domingos C; Northern States Power Company, Minnesota
References
	IR 2022010
	Download: ML22173A245 (19)
	v • d • e

SUBJECT:

PRAIRIE ISLAND NUCLEAR PLANT - TRIENNIAL FIRE PROTECTION INSPECTION REPORT 05000282/2022010 AND 05000306/2022010

Dear Mr. Domingos:

On May 11, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Prairie Island Nuclear Plant and discussed the results of this inspection with Harlan Hansen 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.

Licensee-identified violations which were determined to be of very low safety significance are documented in this report. We are treating these violations as 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 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 Plant.

June 24, 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, Richard A. Skokowski, Chief Engineering Branch 3 Division of 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:

DPR-42 and DPR-60

Report Numbers:

05000282/2022010 and 05000306/2022010

Enterprise Identifier:

I-2022-010-0042

Licensee:

Northern States Power Company

Facility:

Prairie Island Nuclear Plant

Location:

MN, Red Wing

Inspection Dates:

March 28, 2022 to April 15, 2022

Inspectors:

K. Barclay, Reactor Inspector

B. Daley, Senior Reactor Inspector

J. Gilliam, Senior Reactor Inspector

Approved By:

Richard A. Skokowski, Chief

Engineering Branch 3

Division of Reactor Safety

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a triennial fire protection inspection at Prairie Island Nuclear 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.

Licensee-identified non-cited violations are documented in report section: 71111.21N.0

List of Findings and Violations

Failure to Perform Aging Management External Walkdowns of Systems in High Radiation Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000306,05000282/2022010-01 Open/Closed

[H.7] -

Documentation 71111.21N.05 The inspectors identified a finding of very low safety significance (Green) and a Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B,

Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to periodically accomplish instructions for external monitoring. Specifically, procedural Update Safety Analysis Report (USAR) specifications and associated work orders for external monitoring of the Chemical and Volume Control System (CVCS) were not performed periodically and documented properly for components in High Radiation areas.

Failure to Protect the Motor-Driven Fire Pump Controller from Moisture Intrusion Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2022010-02 Open/Closed None (NPP)71111.21N.05 A self-revealed finding of very low safety significance (Green) and associated a Non-Cited Violation (NCV) of License Condition 2.C(4) occurred when the licensee failed to implement a corrective action program that promptly identified and corrected a condition adverse to quality.

Specifically, after identifying that the motor-driven fire pump (MDFP) controller enclosure was permitting water intrusion, which was degrading the internal 480-volt controller components, the licensee failed to correct the adverse condition and protect the controller from water intrusion.

Additional Tracking Items

Type Issue Number Title Report Section Status URI 05000282,05000306/

2021010-01 Unexpected Opening of the Battery Charger Output Breaker 71111.21N.05 Closed

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.

REACTOR SAFETY

71111.21N.05 - Fire Protection Team Inspection (FPTI) Structures, Systems, and Components (SSCs) Credited for Fire Prevention, Detection, Suppression, or Post-Fire Safe Shutdown Review (IP Section 03.01)

Main article: IP 71111.21

The inspectors verified that components and/or systems will function as required to support the credited functions stated for each sample. Additional inspection considerations are located in the fire hazards analysis (FHA) or safe shutdown analysis (SSA).

(1) Unit 1 Turbine-Driven Auxiliary Feedwater Pump (11 TDAFW)

(2)12 Charging Pump

(3) Pre-Action Suppression System (Unit 1, FA 25)

(4) Fire Pumps

Fire Protection Program Administrative Controls (IP Section 03.02) (2 Samples)

The inspectors verified that the selected control or process is implemented in accordance with the licensees current licensing basis. If applicable, ensure that the licensees Fire Protection Program contains adequate procedures to implement the selected administrative control. Verify that the selected administrative control meets the requirements of all committed industry standards.

(1) Combustible Control Program

(2) Fire Watches

Fire Protection Program Changes/Modifications (IP Section 03.03) (2 Samples)

The inspectors reviewed the following changes to the plant's National Fire Protection Association (NFPA) 805 program:

(1) FPCE 18-017, Rev. 1, Loss of Control Room Cooling and 121 Portable 480 Volt Diesel Generator Maintenance

(2) FPCE 19-005, Post Fire Nuclear Safety Capability Assessment Report

INSPECTION RESULTS

Failure to Perform Aging Management External Walkdowns of Systems in High Radiation Areas Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000306,05000282/2022010-01 Open/Closed

[H.7] -

Documentation 71111.21N.05 The inspectors identified a finding of very low safety significance (Green) and a Non-Cited Violation (NCV) of Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," for the licensee's failure to periodically accomplish instructions for external monitoring. Specifically, procedural Update Safety Analysis Report (USAR) specifications and associated work orders for external monitoring of the Chemical and Volume Control System (CVCS) were not performed periodically and documented properly for components in High Radiation areas.

Description:

The Prairie Island USAR, Appendix L, Section L.2.14, describes the External Surfaces Monitoring Program. It states that periodic system inspections and walkdowns are conducted to visually inspect accessible external surfaces of piping, piping components, ducting, and other metallic and non-metallic components (including bolting) for aging degradation. Additionally, the NRC Safety Evaluation Report (SER) for the Prairie Island license renewal states that these inspections and walkdowns will ensure that surfaces that are inaccessible or not readily visible during plant operations will be inspected during refueling outages. These external inspections and walkdowns are specified to be performed for the CVCS system.

Contrary to this specification, inspectors found that work orders used to conduct these procedural inspections and walkdowns for the CVCS system have not been periodically performed in High Radiation areas at the plant. In the work order for the CVCS system, High Radiation areas were categorized as inaccessible areas, and therefore equipment in the areas did not receive an external walkdown inspection. However, the areas themselves are not inaccessible during refueling outages, and portions of the system can be walked down and inspected. While the licensee clearly could inspect other facets of systems in these areas (In-Service Inspection, Micro-Biologically Induced Corrosion, etc.,) during refueling outages, there were not documented records showing designated external inspections that could be credited to show that all accessible surfaces were inspected per the aging management program.

Corrective Actions: The licensee entered this issue in their corrective action process. Items to be evaluated to correct the performance deficiency include adding instructions to work orders to ensure external monitoring is completed for components that are accessible and in the aging management program, and providing clearer guidance so that aging management requirements for walkdowns are clearer for performers of the walkdowns. The licensee also reviewed the results of external inspection for other systems' components in the area, and because of the acceptability of those components, the licensee determined it reasonable that the CVCS components in the same area would similarly be acceptable.

Corrective Action References: CAP 501000062256 - Inaccessible External Surfaces Review, and CAP 501000062304, External Surfaces Program Documentation

Performance Assessment:

Performance Deficiency: The inspectors determined that the failure to perform external monitoring of the CVCS system for components in High Radiation areas was contrary to their periodic aging management procedural USAR specifications and did not fully accomplish the associated work orders.

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. Specifically, the failure to perform external monitoring could lead to the failure of components due to aging mechanisms that could have been prevented by identification through inspection.

Significance: The inspectors assessed the significance of the finding using Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was determined to be of very low safety significance (Green), because the failure to perform external monitoring in this case did not affect the operability of any equipment.

Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. The licensee did not document external inspection of CVCS components in High Radiation Areas, and instead justified not performing the inspections by deeming the areas inaccessible, thereby designating the work orders as complete.

Enforcement:

Violation: 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Contrary to the above, prior to April 15, 2022, the licensee has not had a procedure for periodically accomplished instructions for external monitoring. Specifically, procedural USAR requirements and associated work orders for external monitoring of the CVCS system have not been performed periodically and documented properly for components in High Radiation areas that were accessible during refueling outages.

Enforcement Action: This violation is being treated as an NCV consistent with Section 2.3.2 of the Enforcement Policy.

Failure to Protect the Motor-Driven Fire Pump Controller from Moisture Intrusion Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2022010-02 Open/Closed None (NPP)71111.21N.05 A self-revealed finding of very low safety significance (Green) and associated a Non-Cited Violation (NCV) of License Condition 2.C(4) occurred when the licensee failed to implement a corrective action program that promptly identified and corrected a condition adverse to quality. Specifically, after identifying that the motor-driven fire pump (MDFP) controller enclosure was permitting water intrusion, which was degrading the internal 480-volt controller components, the licensee failed to correct the adverse condition and protect the controller from water intrusion.

Description:

On May 28, 2019, the licensee received multiple alarms in the control room, including a valid fire alarm. The licensees fire brigade responded to the MDFP room and confirmed that no fire was present; however, they did identify that the MDFP controller enclosure was hot and smoking, with electrical charring evident. The licensees investigation found that water dripping from above had entered the controller and likely caused arcing or a fault within the controller. The licensee replaced the complete controller and restored the MDFP on October 4, 2019.

Discussions with licensee staff that were involved in the controller replacement revealed that a patch plate was not flush with the enclosure surface and a channel or gap existed that allowed accumulated water to enter the enclosure. The patch plate was in place because a conduit hole that was previously cut in the top of the enclosure was either originally cut in the wrong location or the conduit was moved sometime in the past and the original hole had to be patched. A review of photos found that the current conduit configuration existed prior to October 2011.

The inspectors reviewed the licensees apparent cause evaluation (ACE) for the 2019 MDFP failure and found that in October of 2011, while starting the MDFP, a short caused electrical sparks and smoke, which was attributed to an inadequately sized lug on the B phase conductor. During controller repairs, extensive corrosion was identified in the enclosure and the system engineer recommended corrective actions to change the enclosure and install a heater, these actions were to eliminate / reduce moisture intrusion and mitigate humidity impacts in the area. The associated condition evaluation stated, in part, walkdown performed and the degradation within the panel is significant. A new enclosure qualified for the environment should be installed to prevent further degradation. A corrective action was created to track initiation of an Engineering Initiation Request (EIR) for replacement of the enclosure; however, because of EIR funding threshold requirements, a work request (WR)was generated instead. The WR / work order (WO) did not contain the necessary detail or requirements to replace the enclosure. The licensees 2019 ACE stated, in part, The WO did not appropriately specify the scope of the work needing to be performed, resulting in corrective actions that only performed repair versus addressing the inadequate design of the cabinet. The inspectors independently reviewed the WO, which consisted of two tasks, and did not identify any corrective actions to address water intrusion of the enclosure. The first task had a stated purpose to clean the corrosion and rust from the equipment and wiring mounted on the back plates of the controller; however, the inspectors found that the step to clean and inspect the components was marked as not applicable. The second task was associated with rust removal and painting of the lower portion of the enclosure. The inspectors did not identify any issues with the performance of the second task.

The inspectors review found evidence of moisture intrusion that was also documented in May of 2017. Specifically, while investigating a ground on Bus 180, the licensee-identified that the MDFP relief valve had sprayed onto the MDFP controller enclosure. During the process of drying out the enclosure they identified that the interior and starter components were severely rusted and needed to be cleaned and inspected. The licensee closed the corrective action document to a WR / WO. The inspectors reviewed the WO notification details associated with a preliminary walkdown and found that it stated, in part, motor driven fire pump starter panel is very rusty / dirty and needs to be cleaned. This will require replacement of the contactor as the component is probably beyond any reasonable type of cleanup. The 2019 ACE documented that the WO was never performed. It was originally scheduled for June 2019, but in May 2019, prior to the controller failure, the WO was extended to 2020.

The inspectors also reviewed revisions of the licensees Quality Assurance Topical Report (QATR), Section A.6 Corrective Action, from 2011 through 2019, which all stated, in part, NSPM [Northern States Power Company - Minnesota] implements a corrective action program to promptly identify, control, document, classify, and correct conditions adverse to quality. The licensee confirmed that QATR, Section A.6 was applicable to their fire protection program.

The inspectors found that Chapter 500, Electric Drive Controllers, Section 513, Item

(c) of National Fire Protection Association (NFPA) 20, Standard for the Installation of Stationary Pumps for Fire Protection 1969, which is the Prairie Island code of record for fire pumps, stated, in part, that the structure or panel shall be securely mounted in an enclosure which will protect the equipment from falling drops of water striking the enclosure from the downward vertical.

Corrective Actions: The licensee replaced the MDFP controller and enclosure with a cabinet appropriate for the environment to eliminate moisture intrusion. The licensee also provided information sharing to its staff about validating that conditions adverse to quality (CAQs) are addressed via WOs and reinforced the concept that WOs are an extension of the corrective action program to ensure risk is appropriately managed via timely and quality correction of CAQs.

Corrective Action References:

QID 501000027914; Received Multiple Unexpected Alarms QID 501000027900; Water Intrusion and Short Damage QIM 501000028580; Plans to Repair 121 MD Fire Pump QIM 501000028169; Water Dripping On 121 MDFP PNL, Storms

Performance Assessment:

Performance Deficiency: The failure to implement a corrective action program that promptly corrected a condition adverse to quality was a performance deficiency. Specifically, after identifying that the MDFP enclosure was permitting water intrusion, which was degrading the 480-volt internal controller components, the licensee failed to take corrective actions that protected the controller from water intrusion.

Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the resulting water intrusion caused a fault in the MDFP controller and loss of the MDFP for over 4 months. The inspectors also compared the finding with the examples listed in IMC 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues. Example 4.f was found to be similar in that a failure to correct a condition adverse to quality resulted in a loss of function for a component.

Significance: The inspectors assessed the significance of the finding using Appendix F, Fire Protection and Post - Fire Safe Shutdown SDP. The inspectors applied Appendix F, 1, Fire Protection Significance Determination Process Worksheet, and determined that the finding impacted the fire water supply. The inspectors answered Yes to question 1.3.1-A, Based on the criteria in Attachment 2, is the finding assigned a Low degradation rating? Specifically, the inspectors reviewed Appendix F, Attachment 2, Degradation Rating Guide, and concluded that the loss of the MDFP did not result in a non-functional system and represented a low degradation rating. The inspectors found that the licensee retained the diesel-driven fire pump and a screen wash pump that could also supply the fire suppression system. Therefore, the inspectors determined the finding was of very low safety significance (Green).

Cross-Cutting Aspect: Not Present Performance. No cross-cutting aspect was assigned to this finding because the inspectors determined the finding did not reflect present licensee performance. Specifically, the inspectors believe that the latest opportunity for the licensee to assign corrective actions would have been the May 2017 timeframe when they assigned actions to clean and inspect the enclosure after observing the rusted enclosure internals.

Enforcement:

Violation: License condition 2.C(4) of the Prairie Island Nuclear Generating Plant, Unit 1 and Unit 2 Renewed Facility Operating Licenses, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program that comply with Title 10 of the Code of Federal Regulations (10 CFR) 50.48(a) and 10 CFR 50.48(c),

National Fire Protection Association (NFPA) Standard NFPA 805, as specified in the licensees amendment request dated September 28, 2012, as supplemented, and as approved in the Safety Evaluation dated August 8, 2017. Section 3.5.3 of NFPA 805, states, in part, fire pumps, designed and installed in accordance with NFPA 20, Standard for the Installation of Stationary Pumps for Fire Protection, shall be provided to ensure that 100 percent of the required flow rate and pressure are available assuming failure of the largest pump or pump power source.

NFPA 20, 1969, Chapter 500, Electric Drive Controllers, Section 513, Item (c), states, in part, that the structure or panel shall be securely mounted in an enclosure which will protect the equipment from falling drops of water striking the enclosure from the downward vertical.

Contrary to the above, from August 8, 2018, to October 4, 2019, the licensee failed to provide a fire pump designed and installed in accordance with NFPA 20. Specifically, the licensee failed to provide an enclosure for the MDFP controller that protected the equipment from falling drops of water striking the enclosure from the downward vertical.

Enforcement Action: This violation is being treated as an NCV, consistent with Section 2.3.2 of the Enforcement Policy.

URI Unexpected Opening of the Battery Charger Output Breaker URI 05000282,05000306/2021010-01 71111.21N.05

Description:

As a result of the evaluation of Information Notice (IN) 2017-06 dated August 13, 2018, the licensee obtained vendor information in regard to the response characteristics of the 21 Battery Charger. This information displayed the expected response of the battery charger to a fault experienced downstream of the charger. Contrary to past licensee assumptions that the charger would interrupt current flow when current levels were greater than or equal to 315 Amps, information from the vendor showed that the battery charger would actually supply up to 6000 Amps during the first 10 milliseconds of the fault event rather than interrupting the current flow when the current was 315 Amps or more. Current levels in excess of 315 Amps could potentially cause the breaker downstream of the battery charger to inadvertently open.

The licensee did not recognize the potential for the downstream breaker to open until it was identified by the inspectors.

This tripping of the downstream breaker was different than what was provided in Assumption 6.2.1 of Prairie Island calculation ENG-EE-012, 125VDC [volts direct current]

Coordination Study, which states, It is assumed that the battery charger output breakers will not operate for external faults. Additionally, this calculation was used for the plants fire protection safe shutdown analysis. The assumption that the battery charger output breakers would not operate and the battery chargers would remain available was used in the plant specific fire protection Probabilistic Safety Assessment (PSA) which supports the National Fire Protection Association (NFPA) 805 performance-based analysis for Prairie Island fire areas. Subsequent to the inspection, the licensee discovered that under certain fire scenarios, the battery charger could be lost due to tripping from a downstream fault event.

The Prairie Island PSA (also referred to as the probabilistic risk assessment (PRA)) credits the battery charger to provide DC power for the long-term plant response to these fire scenarios. Contrary to the plant PSA, the battery charger may not be available during certain plant fire scenarios.

The Operating License for Prairie Island Nuclear Plant states that the licensee shall implement and maintain in effect all provisions of the fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c). Code of Federal Regulations allows compliance with NFPA 805, 2001 edition, in replacement of complying with 10 CFR 50.48(b). NFPA 805, Section 2.4.3.3 states, in part, that, the PSA data shall be based on the as-built and as-operated and maintained plant, and reflect the operating experience at the plant.

Contrary to this, the fire protection PRA data at Prairie Island Nuclear Plant did not reflect the operating experience for the plant. Specifically, although the licensee evaluated the operating experience in IN 2017-06, the availability of the battery chargers was not assessed for output breaker trips that could occur due to the new information contained in IN 2017-06. This resulted in changes to the PRA to include the decreased probability of the battery charger being available in certain fire areas.

This issue has been categorized as low safety significance, and therefore as a minor violation, because, although there is an increased probability for the battery chargers to be unavailable during a fire event, the licensee had procedural guidance already in place that would provide a portable charger in the event that the battery charger was unavailable. This action was not credited and therefore was not included in the PRA, and when added, the PRA numbers from the loss of the battery chargers and the addition of the use of the temporary battery chargers tended to offset each other. The licensee entered this issue into their corrective action program as CAP 501000051933.

Additionally, this unresolved item (URI) closure and resulting minor violation was discussed with Nuclear Reactor Regulation (NRR), the Authority Having Jurisdiction (AHJ), and agreement was reached on its categorization and disposition.

Licensee-Identified Non-Cited Violation 71111.21N.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Prairie Island Nuclear Generating Plant, Technical Specification (TS) 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.l recommended Plant Fire Protection Program as administrative procedure.

Licensee procedure, F5 Appendix K, "Fire Protection Systems Functional Requirements" Revision 32, states, in part, this procedure implements the Fire Protection Program as defined in procedure H77, Fire Protection Program and item 2.C(4) of the operating license condition.

Licensee procedure, F5 Appendix K, "Fire Protection Systems Functional Requirements,"

4, Non Power Operation (NPO) Administrative Controls, states, in part, procedures 1C4.1, 2C4.1, 1C4.2, 2C4.2, 1C1.3-M5, 2C1.3-M5 include steps to implement compensatory measures in accordance with this procedure. When directed in those procedures to implement NPOs Administrative Controls in accordance with this attachment, an hourly fire watch SHALL be implemented in the following fire areas depending on the Unit that is in a refueling outage/shutdown: Unit 2 - Fire Areas 8, 22, 29, 30, 31, 32, 33, 36, 41A, 41B, 58, 59, 66, 71, 80, 81, 97, and 98.

Contrary to the above, between October 6 - 8, 2019, while Unit 2 was in a refueling outage, the licensee failed to implement a written procedure covering a procedure recommended in Regulatory Guide 1.33, Appendix A, February 1978. Specifically, the licensee failed to perform hourly fire watches in fire areas 29, 30, 33, 36, 41A, 71, 80, 97 and 98. As required by procedure F5 Appendix K, "Fire Protection Systems Functional Requirements" Revision 32, Attachment 4, when directed by procedure 2C1.3-M5.

Significance/Severity: Green. The inspectors evaluated the significance of this issue using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 2, "Initiating Events Screening Questions" and answered No to the Section 10, External Events Initiators question.

Corrective Action References: QIM 501000032916, FP Admin Controls Not Implemented Licensee-Identified Non-Cited Violation 71111.21N.05 This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Prairie Island Nuclear Generating Plant, Technical Specification (TS) 5.4.1.a requires, in part, that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide 1.33, Appendix A, February 1978. Regulatory Guide 1.33, Appendix A, Section 1.l recommended Plant Fire Protection Program as administrative procedure.

Licensee procedure, F5 Appendix K, "Fire Protection Systems Functional Requirements" Revisions 27-38, states, in part, this procedure implements the Fire Protection Program as defined in procedure H77, Fire Protection Program and item 2.C(4) of the operating license condition.

Licensee procedure, F5 Appendix K, "Fire Protection Systems Functional Requirements" Revision 38, Attachment 4, Non Power Operation (NPO) Administrative Controls, states, in part, procedures 1C4.1, 2C4.1, 1C4.2, 2C4.2, 1C1.3-M5, 2C1.3-M5 include steps to implement compensatory measures in accordance with this procedure. When directed in those procedures to implement NPOs Administrative Controls in accordance with this attachment, an hourly fire watch SHALL be implemented in the following fire areas depending on the Unit that is in a refueling outage/shutdown: Unit 1 - Fire Areas 1, 8 (only U1 el 715),20, 29, 30, 31, 32, 33, 35, 36, 41A, 41B, 58, 59, and 80; Unit 2 - Fire Areas 8 (only U2 el 715), 20, 29, 30, 31, 32, 33, 36, 41A, 41B, 58, 59, 66, 71, 80, 97, and 98.

Contrary to the above, from September 30, 2019, to present, the licensee failed to maintain a written procedure covering a procedure recommended in Regulatory Guide 1.33, Appendix A, February 1978. Specifically, for licensee procedure F5 Appendix K, "Fire Protection Systems Functional Requirements," Attachment 4, Revisions 27 through 38, which implement the fire protection program, the licensee failed to list fire areas 2, 4, 34, 60 and 75 as requiring an hourly fire watch. The licensee determined that these fire areas were required by licensee calculation GEN-PI-097, Post Fire Non-Power Operations Report, Revisions 0-2, but were removed from F5 Appendix K, "Fire Protection Systems Functional Requirements,"

4 without adequate justification or evaluation.

Significance/Severity: Green. The inspectors evaluated the significance of this issue using Inspection Manual Chapter 0609, Appendix G, Attachment 1, Shutdown Operations Significance Determination Process Phase 1 Initial Screening and Characterization of Findings, Exhibit 2, "Initiating Events Screening Questions" and answered No to the Section 10, External Events Initiators question.

Corrective Action References: QIM 501000061192; NPO Controls Not IAW GEN-PI-097

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On May 11, 2022, the inspectors presented the triennial fire protection inspection results to Harlan Hansen, Plant Manager and other members of the licensee staff.

On May 11, 2022, the inspectors presented the Re-Exit Meeting for the triennial fire protection inspection results to Stewart Yuen and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

Hydraulic CALC D1/D2 DG Room Sprinkler Systems

10/07/1970

Fixed Load Calculation Report

03/28/2022

GEN-PI-096

Nuclear Safety Capability Assessment Analysis for

Compliance with NFPA 805

PRA-PI-SY-

SVCS

Safeguards Ventilation System Notebook

5.4

V.SMN.10.019

Evaluation of Aux Bldg 695' Heatup Without HVAC

Calculations

V.SMN.19.002

Best Estimate GOTHIC Analysis for SE Areas

500000317966

IN 2017-06 Battery Charger Fault Current Could Trip DC

Output Breaker

2/22/2022

500001310409

Replace CPNL 70392, For 121 MD Fire Pump

10/28/2011

501000030499

CHG PMP DISCH VLV BA LEAK

08/08/2019

501000032790

Gap Establishing CTMNT Hourly Fire Watch

10/06/2019

501000032896

Non-Compliant Hot Work Area Work Stopped

10/08/2019

501000039844

Boric Acid Buildup 12 Chg Pmp Casing

05/16/2020

501000044228

SP 1196 Issues

09/17/2020

501000044681

NOS: No Combustible Control Permit

09/25/2020

501000046022

Increased Leakage 122 DDFP, 15 DPM

10/30/2020

501000046328

NOS: Combustible Control Housekeeping

11/11/2020

501000046467

NOS: Expired Combustible Control Permit

11/18/2020

501000047363

SP 1053 Pressure and Flow Not Attained

2/26/2020

501000047364

2 DDFP Strainer Constant Backwash

2/26/2020

501000050937

2 DD Fire Pump Failed to Start

04/24/2021

501000051005

2 DDFP "B" Batt < Required Voltage

04/24/2021

501000055318

2 DD Fire Pump Shut Down

08/20/2021

501000058339

FSA - ISS: Combustible Control

11/16/2021

501000060079

Combustible Issues Identified

01/26/2022

501000060250

Combustible and Housekeeping Issues

01/31/2022

Corrective Action

Documents

501000061578

WO 94024 DDFP "B" Battery

03/24/2022

501000060780

Referenced FP Eval No Longer Applicable

2/21/2022

71111.21N.05

Corrective Action

Documents

501000061598

H77 Includes Incorrect Reference

03/24/2022

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

501000061624

Draft Document Included in RFI List

03/24/2022

501000061761

21 MDFP Strainer Corrosion/Leakage

03/29/2022

501000061764

SAP Cable Destination Information

03/30/2022

501000061784

Incorrect Info Added to CAP 501000044228

03/20/2022

501000061808

Work Order Information

04/01/2022

501000061823

GEN-PI-096 Reference Update

03/31/2022

501000061908

Missing Step Signoff on SP 1053

04/04/2022

501000061924

Missed Fire Watch

04/05/2022

501000061948

Inspection Response over 24 Hours

04/04/2022

501000061994

H77.3 Clarification

04/05/2022

501000062046

Update References in H77

04/07/2022

501000062142

H77 Appendix F S-2 Item 18

04/11/2022

501000062146

PRA Calc Editorial Error

04/12/2022

501000062245

NFPA Code Compliance Change in Draft

04/13/2022

501000062251

PRA Evaluation Not Applicable

04/13/2022

501000062256

Inaccessible External Surfaces Review

04/13/2022

501000062304

External Surfaces Program Documentation

04/15/2022

501000062326

Inspection Response over 24 Hours

04/15/2022

Resulting from

Inspection

501000062327

Silting Issues with Fire Pumps

04/15/2022

NF-38501

Architectural Mezzanine FLR Plan @ EL. 715

NF-39218

Flow Diagram Main Auxiliary Steam & Steam Dump

NF-39222

Flow Diagram Feedwater & Aux Feedwater Unit 1

NF-39228-1

Flow Diagram Fire Protection & Screen Wash Sys Unit 1

& Unit 2

NF-40002-3

Single Line - Metering and Relaying Safeguard and

Normal 4.16 kV Switchgear Feeder Unit 1 & 2

NF-40018-3

230V AC Circuit Diagram Distribution Panels 119/134/135

NF-40021

480V Distribution Diagram Unit 1 Normal Buses

NF-40022-1

Circuit Diagram 4kV and 480V Safeguard Buses

NF-40036

480V Circuit Diagram Motor Control Center 1K, 1KA

Drawings

XH-1106-2502

Sprinkler Systems WPS-16 and DA-4 Unit 2 Plan

A

Engineering

Changes

FPCE 18-017

Loss of Control Room Cooling and 121 Portable 480 Volt

Diesel Generator Maintenance

Inspection

Procedure

Type

Designation

Description or Title

Revision or

Date

FPCE 19-007

NFPA 805 Modification Reduction

FPCE-19-005

Post Fire Nuclear Safety Capability Assessment Report

Fire Area Health Report

03/29/2022