IR 05000282/2023010
| ML23229A178 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 08/17/2023 |
| From: | Jamie Benjamin NRC/RGN-III/DORS/EB1 |
| To: | Conboy T Northern States Power Company, Minnesota |
| References | |
| IR 2023010 | |
| Download: ML23229A178 (1) | |
Text
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - NRC INSPECTION REPORT 05000282/2023010 AND 05000306/2023010
Dear Thomas Conboy:
On August 3, 2023, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at 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.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation 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.
August 17, 2023 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, Jamie C. Benjamin, Chief Engineering Branch 1 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:
05000282/2023010 and 05000306/2023010
Enterprise Identifier:
I-2023-010-0044
Licensee:
Northern States Power Company
Facility:
Prairie Island Nuclear Generating Plant
Location:
Welch, MN
Inspection Dates:
June 12, 2023 to June 30, 2023
Inspectors:
M. Domke, Reactor Inspector
K. Fay, Reactor Inspector
Approved By:
Jamie C. Benjamin, Chief
Engineering Branch 1
Division of Operating Reactor Safety
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a NRC 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 Retain Commercial Grade Survey and Source Surveillance Records Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2023010-01 Open/Closed
[H.7] -
Documentation 71111.21N.03 The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR50 Appendix B, Criterion XVII when the licensee failed to retain commercial grade survey and source surveillance records for the life of the basic component.
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.
REACTOR SAFETY
71111.21N.03 - Commercial Grade Dedication Commercial Grade Dedication (Section 03.01)
The inspectors reviewed the implementation of the licensees processes for dedicating commercial-grade items/services as basic components and/or for procuring safety-related structures, systems, and components for the following samples:
- (2) MID 6555103-2, Pin, Cotter, 1/8 in., 1.5 in. Stainless Steel, Release Spindle Nut
- (3) MID KMT116-2, Compound, Sealing, Adhesive, 10.1 oz., Tube/Caulker
- (4) MID KOL11G-2, Lubricant Oil, 55 gal. drum
- (5) MID KNP2FF-2, Connector, Terminal, 20 to 14 AWG to 12 AWG
- (6) MID 160-1115-2, Nut, Manway Primary and Secondary
- (7) MID 6588539-2, Coolant, Antifreeze, Ethylene Glycol, Liquid concentrate
- (8) MID KES117-2, Splice, Conductor, 20 to 14AWG, 20 to 12 AWG
- (9) MID 6620354-2, Hose, Flexible Braided, 1/4 in., 316 Stainless Steel
- (11) MID KSL12T-2, Tee, Tube, 3/8 in., Compression, 2600 lb., Brass
INSPECTION RESULTS
Failure to Retain Commercial Grade Survey and Source Surveillance Records Cornerstone Significance Cross-Cutting Aspect Report Section Mitigating Systems Green NCV 05000282,05000306/2023010-01 Open/Closed
[H.7] -
Documentation 71111.21N.03 The inspectors identified a Green finding and associated Non-Cited Violation (NCV) of 10 CFR50 Appendix B, Criterion XVII when the licensee failed to retain commercial grade survey and source surveillance records for the life of the basic component.
Description:
On June 12, 2023, inspectors verifying critical characteristics for commercial grade surveys requested documentation describing conditional approvals to determine what conditions were associated with commercial grade surveys for selected component samples. Commercial grade surveys are activities conducted by the purchaser or its agent to verify that a supplier of commercial grade items controls, through quality activities, the critical characteristics of specifically designated commercial grade items, as a method to accept those items for safety-related use. On June 14, 2023, the licensee informed inspectors that conditional approvals associated with commercial grade surveys greater than 3 years were unavailable due to document retention policies at the facility. Inspectors later learned the same document retention requirements of 3 years were applied to commercial grade surveys, e.g., dedication method 2. Components installed in the plant over 3 years ago did not have documentation supporting their safety-related pedigree. In addition to conditional approvals for surveys and the commercial grade surveys themselves, source surveillance reports developed from implementing commercial grade dedication method 3 were not retained beyond 3 years.
According to the Updated Final Safety Analyses Report at Prairie Island, nuclear plant operational and support activities are conducted under the Northern States Power Minnesota (NSPM) Quality Assurance Topical Report (QATR), designated NSPM-1. NSPM-1 is the top-level policy document that establishes the manner in which quality is to be achieved and presents NSPM's overall philosophy regarding achievement and assurance of quality.
NSPM-1 responds to and intends to satisfy the requirements of Appendix B of 10 CFR Part 50.
Record retention times are provided in NSPM-1 by cited regulatory guide RG1.28 revision 3, 1985, Quality Assurance Program Requirements, but instead of using ASME NQA-1 1983a as described by RG 1.28 revision 3, NSPM uses NQA-1 1994. NQA-1 1994 Basic Requirement 7, Control of Purchased Items and Services, requires procurement of items and services to be controlled to assure conformance with specified requirements.
NQA-1 Supplement 7S-1, Supplementary Requirements for Control of Purchased Items and Services, provides amplified requirements for control of purchased items and services.
Section 5.2 under Supplement 7S-1,requires activities performed to verify conformance to procurement documents to be recorded. Source surveillances and inspections, audits, receiving inspections, non-conformances, dispositions, waivers, and corrective actions shall be documented according to Section 5.2. The record life is further prescribed in NQA-1 1994 Supplement 17S-1, Supplementary Requirements for Quality Assurance Records, Section 2.7.1, lifetime records. Lifetime records are those that meet one or more of the following criteria:
- (a) those which would be of significant value in demonstrating capability for safe operation;
- (b) those which would be of significant value in maintaining, reworking, repairing, replacing, or modifying an item;
- (c) those which would be of significant value in determining the cause of an accident or malfunction of an item;
- (d) those which provide required baseline data for in-service inspections. Lifetime records are required to be maintained by or for the plant owner for the life of the particular item while it is installed in the plant or stored for future use.
On June 27, 2023, the licensee initiated quality issue no. 501000074880 to assure procurement documents are appropriately retained and to align documentation and retention of source surveillance records between procedures for receipt of quality items, FP-SC-RSI-02 and for dedication of commercial grade items, FP-SC-PE-01.
On June 28, 2023 the licensee initiated quality issue no. 501000074923 to acknowledge objective evidence for the fulfillment of critical characteristics could not be provided for components installed in safety-related applications for components commercially-dedicated by method 2 and installed greater than 3 years.
Corrective Actions: QIM 501000074943, 6/28/2023, CGD Objective Evidence QIM 501000074880, 6/27/2023, FP-SC-PE-01 and FP-SC-RSI-02 Alignment
Performance Assessment:
Performance Deficiency: The licensee failed to maintain quality assurance records for purchased equipment that conformed to the procurement documents in accordance with 10 CFR 50, Appendix B, Criterion XVII, Quality Assurance Records. Specifically, equipment qualification documentation provided by commercial grade surveys were not maintained as required by NQA-1-1994 as lifetime records and instead destroyed after 3 years.
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. Inspection manual chapter (IMC) 0612 Appendix E provides examples of minor issues, and this finding most closely relates to example 1.a. when the licensee failed to document and evaluate test results in accordance with regulatory requirements. The example for more-than-minor describes the performance deficiency affected the mitigating systems cornerstone attributes of equipment performance and procedure quality and adversely impacted the cornerstone objective. The example shows when a significant number of records associated with equipment are missing that reasonable assurance for operability is called into question. Inspectors discussed with licensee staff their operability process and associated equipment reviews and evaluations regarding this performance deficiency and understand the licensee position that presumption of operability as updated by NEI 18-03 was not lost and requirements for entering the operability determination process did not appear to be satisfied.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The finding was routed through the process described in IMC 0609 Appendix A, Exhibit 2, Part A, Mitigating SSCs and PRA Functionality. All six questions were answered "no," therefore, the finding screens to green.
Cross-Cutting Aspect: H.7 - Documentation: The organization creates and maintains complete, accurate and up-to-date documentation. Record retention for commercial grade surveys and surveillances showing critical characteristics had been satisfied for the life of the basic components were not created upon receipt inspection due to lack of procedure guidance to retain those documents.
Enforcement:
Violation: 10 CFR 50 Appendix B, Criterion XVII requires, in part, sufficient records to furnish evidence of activities affecting quality. Records shall include closely-related data such as qualifications of equipment. Records are required to be identifiable and retrievable. Contrary to the above, the licensee failed to retain commercial grade surveys and source surveillances for life of commercially-dedicated basic components.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On June 30, 2023, the inspectors presented the Exit Meeting inspection results to Thomas Conboy and other members of the licensee staff.
On August 3, 2023, the inspectors presented the Re-exit meeting inspection results to Tim Johnson and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000069858
23 CGD FSA: CGD Industry Experience
01/12/2023
501000069864
23 CGD FSA: CGD Form Enhancements
01/12/2023
605000001590
07/18/2020
Corrective Action
Documents
605000001591
07/18/2020
501000071553
Flexitallic Gasket Found Defective
03/23/2023
501000074142
Incorrect Legacy Material ID
05/31/2023
501000074153
Legacy PO Not Located
06/02/2023
501000074163
MID Shelf Life Requirement Incorrect
06/02/2023
501000074510
Mislabeled Drawer in Warehouse
06/14/2023
501000074520
CAP 501000047963 Actions Not Timely
06/15/2023
501000074537
Missing Oct Warehouse Temp Readings
06/16/2023
501000074563
No Records for Warehouse Monthly PM
06/16/2023
501000074564
CGD-2006-013-03 Material Acceptance Criteria
06/16/2023
501000074718
Incomplete Information Provided to NRC
06/22/2023
501000074771
Legacy POs Lack Required Language
06/23/2023
501000074880
FP-SC-PE-01 and FP-SC-RSI-02 Alignment
06/27/2023
501000074923
CGD Objective Evidence
06/28/2023
Corrective Action
Documents
Resulting from
Inspection
501000074937
NRC CGD Inspection Debrief Observations
06/29/2023
Engineering
Changes
00SG02
Steam Generator Replacement Project
04/12/2004
2015-011
D5 and D6 Fleet Charge Antifreeze and Coolant, CID's
6588539 and 6596703
CGD-2006-001
CGD-2006-0013
Burndy Uninsulated Copper Compression Connectors
(Supersedes PINGP CGE-Pl-0009)
CGD-2006-0013
Burndy Uninsulated Copper Compression Connectors
(Supersedes PINGP CGE-Pl-0009)
CGD-2008-006
Swagelok Flexible Hoses
CGD-2009-005
Silicone RTV 108 (108C) -Supersedes CGE-PI-0003
CGD-2009-007
Industrial and Engine Oils (Supersedes CGE-PI-0027)
71111.21N.03
Engineering
Evaluations
CGD-2013-011
Swagelok Valves (Supersedes CGE-PI-0113)
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CGD-2013-013
Swagelok Fittings -Brass and Carbon Steel (Supersedes
CGE-PI-0112 for Brass)
CGICF01
EPRI CGI Joint Utility Task Group Commercial Grade
Item Evaluation for Compression Fittings
00020809
Purchase Order for Cotter Pin
00029778
Purchase Order for Splice
4000002332
Purchase Order Lubricant: INDL Oil, 55 GAL DRM
4000006830
Purchase Order for Coolant, Antifreeze
4000007219
Purchase order for Flexible Hose
4000008310
Purchase Order for Ball Valve
4000012335
Purchase Order Plug Valve
4000012734
Purchase Order for Adapter: Tube, Brass
4000016022
Purchase Order for Compound, Sealing Silicone Rubber
Adhesive
4000021138
Purchase Order for Terminal Connector
NP-5652
Guideline for the Utilization of Commercial Grade Items in
Nuclear Safety-Related Applications (NCIG-07)
NQA-1 1994
Quality Assurance Requirements for Nuclear Facility
Applications
07/29/1994
NSPM-1
Quality Assurance Topical Report
Miscellaneous
PS 3549 SQ
Purchase Order Unit 1 Replacement Steam Generator
03/02/2004
FP-NO-SAS-01
Supplier Qualification and Maintenance of the Qualified
Suppliers List
FP-NO-SAS-03
Performance of Commercial Grade Surveys
FP-NO-SAS-06
Source Surveillance
FP-OP-OL-01
Operability
FP-SC-PE-01
Dedication of Commercial Grade Items and Services
FP-SC-RSI-01
Receiving
FP-SC-RSI-02
Quality Receipt
Procedures
FP-SC-RSI-03
Overage, Shortage, Damaged and Discrepant (OSD&D)
Report
16