IR 05000282/2025010
| ML25182A120 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 07/01/2025 |
| From: | Dariusz Szwarc NRC/RGN-III/DORS/RPB3 |
| To: | Paulhardt W Northern States Power Company, Minnesota |
| References | |
| IR 2025010 | |
| Download: ML25182A120 (1) | |
Text
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000282/2025010 AND 05000306/2025010
Dear Werner Paulhardt:
On May 22, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed a Problem Identification and Resolution inspection at your Prairie Island Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspection team reviewed the stations Problem Identification and Resolution program to confirm that the station was complying with NRC regulations and licensee standards.
Based on the samples reviewed, the team determined that your program complies with NRC regulations and applicable industry standards such that the Reactor Oversight Process can continue to be implemented.
The team also evaluated the stations effectiveness in identifying, prioritizing, evaluating, and correcting problems, reviewed licensee audits and self-assessments, and its use of industry and NRC operating experience information. The results of these evaluations are in the enclosure.
Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, the team found no evidence of challenges to your organizations safety-conscious work environment.
Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.
No findings or violations of more than minor significance were identified during this inspection.
July 1, 2025 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, Dariusz Szwarc, 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 cc w/ encl: Distribution via LISTSERV Signed by Szwarc, Dariusz on 07/01/25
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial Problem Identification and Resolution inspection at Prairie Island Nuclear Generating Plant, in accordance with the Reactor Oversight Process.
The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
No findings or violations of more than minor significance were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs)in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES - BASELINE
71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 03.04)
- (1) The inspectors performed a biennial assessment of the effectiveness of the licensees Problem Identification and Resolution program, use of operating experience, self-assessments and audits, and safety-conscious work environment.
1. Problem Identification and Resolution Effectiveness: The inspectors assessed
the effectiveness of the licensees Problem Identification and Resolution program in identifying, prioritizing, evaluating, and correcting problems.
The inspectors also conducted a 5-year review of Unit 1 and Unit 2 reactor protection system. The corrective actions for the following non-cited violations (NCVs), minor violations, and findings (FIN) were evaluated as part of the assessment: FIN 2023003-01, NCV 2023003-02, NCV 2023010-01, NCV 2023011-01, NCV 2024001-01. FIN 2024001-02, NCV 2024004-01, NCV 2024004-02, NCV 2024004-03, NCV 2024010-01, NCV 2024010-02, NCV 2024010-03, NCV 2024010-04, NCV 2024010-05, NCV 2024010-06, NCV 2024010-07, NCV 2024402-01, and NCV 2024402-02.
2. Operating Experience: The inspectors assessed the effectiveness of the
licensees processes for use of operating experience.
3. Self-Assessments and Audits: The inspectors assessed the effectiveness
of the licensees identification and correction of problems identified through audits and self-assessments.
4. Safety Conscious Work Environment: The inspectors assessed the
effectiveness of the stations programs to establish and maintain a safety-conscious work environment.
INSPECTION RESULTS
Assessment 71152B Corrective Action Program Effectiveness Overall, the team concluded that the licensee had established a low threshold for entering deficiencies into the corrective action program (CAP), that issues were generally being appropriately prioritized and evaluated for resolution, and that corrective actions (CAs) were generally completed in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue.
Effectiveness of Problem Identification The team concluded that the station was generally effective at identifying issues at a low threshold and was properly entering them into the CAP as required by station procedures.
During interviews, workers were familiar with how to enter issues into the CAP and stated that they were encouraged to use it to document issues. During plant walkdowns, the team observed that issues were being identified in the field and that they were being properly addressed in the CAP. The team determined that the station was generally effective at identifying negative trends that could potentially impact nuclear safety. For the areas reviewed, the team did not identify any issues of more than minor significance in problem identification.
Effectiveness of Prioritization and Evaluation of Issues The team performed in-depth reviews of a risk-informed sampling of conditions adverse to quality (CAQ), work orders, cause, root cause, and condition evaluations. The inspectors noted that generally, issues were properly screened with most either classified as CAQ or non-conditions adverse to quality (Non-CAQ) items.
The team also performed a selective review of issues identified by the NRC that were documented either as observations or for which findings or other enforcement was issued.
Issue evaluations were generally sound and of good quality. Most issues were screened as low significance and were assigned a cause evaluation (CSE) or equipment cause evaluation (ECE) (the lowest level of review); more significant issues were assigned CSEs and reviewed for extent of condition and extent of cause or, if highly significant, a root cause evaluation was assigned. The inspectors verified that the assigned evaluations were consistent with the significance of the issue as defined in the licensees process. For the areas reviewed, the team did not identify any issues of more than minor significance in prioritization and evaluation of issues.
Effectiveness of Corrective Actions The team concluded that the licensee was generally effective in developing CAs that were appropriately focused to correct the identified problem and to address the root and contributing causes for significant CAQ to preclude repetition. The licensee generally completed CAs in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue. For NRC-identified issues, the team determined that the licensee generally assigned CAs that were effective and timely. The inspectors also did a selective review of CAs that were still open at least 2 years after the issue was identified to verify that it was appropriate for these items to remain open, and that the licensee was managing them correctly.
Based on the samples reviewed, the team determined that the licensee was generally effective in corrective action implementation. Problems identified using a root cause or other cause methodologies were resolved in accordance with CAP requirements. For the areas reviewed, the team did not identify any issues of more than minor significance in corrective actions.
No findings or violations of more than minor significance were identified.
Assessment 71152B Use of Operating Experience The inspectors reviewed operating experience (OpE) captured in the CAP and sampled OpE from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the OpE was appropriately screened and evaluated for applicability, and was effectively used by the station. It was also noted that it was properly considered as a potential precursor in issue evaluations, and during interviews and observations of daily plant meetings the inspectors concluded that it was seen as a useful learning tool and being used appropriately in daily plant activities.
No findings or violations of more than minor significance were identified.
Assessment 71152B Self-Assessments and Audits Nuclear Oversight audits and department self-assessments were generally of good quality, thorough, and critical with identified issues being properly dispositioned in the CAP.
Additionally, audits and assessments were performed in accordance with licensee procedures. Of note, the inspectors observed that the overall conclusions of the licensees self-assessment of the CAP program done prior to this NRC inspection was consistent with the inspectors observations.
No findings or violations of more than minor significance were identified.
Assessment 71152B Safety Conscious Work Environment The team reviewed the stations programs to establish and maintain a safety-conscious work environment and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews, workers at the station expressed freedom to raise and enter safety concerns through any one of the various avenues available to them, and the team encountered no indications of a chilled work environment.
While most workers felt no need to engage the Employee Concerns Program (ECP), workers expressed favorable opinions of the ECP during interviews and none were concerned that there would be negative feedback from engaging with this program. The inspectors noted that there were still issues documented in the program. Through a selective review, the inspectors concluded that these issues were appropriately handled and identified no adverse trends.
No issues of concern were identified.
Assessment 71152B 5-Year Review of Reactor Protection System The inspectors performed an expanded 5-year review of the Units 1 and 2 Reactor Protection System; specifically, by performing system walk-downs and evaluating condition reports, system health reports, maintenance rule assessments, self-assessment reports, engineering changes, and work orders. Overall, the inspectors determined that the licensee was effectively managing issues associated with this system.
No findings or violations of more than minor significance were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On May 22, 2025, the inspectors presented the biennial Problem Identification and Resolution inspection results to Werner Paulhardt and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
500001145695
NRC NCV - CC Piping Adjacent to HELB Loc
7/29/2008
500001227543
MS Snubbers Overloaded - Torsional Accel
04/16/2010
500001528638
Minor Air and Oil Leak on D6 2A Aftercooler
07/18/2016
501000037077
Lube Oil Seepage from Top of D6 Eng 2
01/28/2020
501000054247
PE 0009 Acceptance Criteria Change/Update
07/21/2021
501000065627
Fuel Assemblies Not in TS Compliance
08/17/2022
501000067574
Over-limit High Cubicle-to-Cubicle Res.
10/22/2022
501000075490
2GT XFMR Arrester Forensic Results
07/21/2023
501000079134
Suspect Test Relay in Safeguards Rack
11/18/2023
501000080543
Timed MV-32038 Twice Due to Dual Light
01/04/2024
501000081782
PICETI 4KV Breaker Testing Discrepancy
2/09/2024
501000082185
2R33 PM 3132-1-22 PUA Performance Issue
2/22/2024
501000082220
PICETI: U1 EDG HELB Comb. Air Quality
2/22/2024
501000082416
PICETI POD Comp Action Late Initiation
03/01/2024
501000082686
MV-32038 Dual Indicaton
03/09/2024
501000083778
Elevation of Fleet CAP
04/05/2024
501000084008
Evaluate Tech Spec Bases LCO 3.7.12
04/11/2024
501000084597
(CSE
2000031268)
SP 1159 Completed Unsat
501000084671
PSR Item Exceeded IST Timing Frequency
04/29/2024
501000084692
IST Inoperable CL Return Valves
04/29/2024
501000084730
SP 1159 Completion not Documented in SAP
04/30/2024
501000085115
MV-32038 High Running Torque
05/08/2024
501000085922
TS 3.7.12 Missing in Fuel Handling Procedure
05/26/2024
501000085931
CAP Closed with Action Not Performed
05/26/2024
501000086170
SP1159 Completed Unsat
06/04/2024
501000086769
SGB xfr Pump Failure
06/18/2024
501000087599
1R-37 OOS Impacts to TS 3.7.12
07/11/2024
501000088496
Inverter Bypassed
08/02/2024
Corrective Action
Documents
501000090213
Inst. Operability Req in ABSV Bases
09/24/2024
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000091950
D1 Speed Switch Calibration
11/03/2024
501000092756
Related to BMI to Flux Thimble Tube Weld Exam
11/26/2024
501000094367
Concern from RA review of 501000082221
01/23/2025
501000094469
PI Findings without RA Closure Review
01/28/2025
501000094507
Upgrade of CAP Severity W/O Adding Action
01/28/2025
501000094516
25 PIR FSA - NCAQs Potentially CAQ
01/28/2025
501000094593
Revised POD Not in Records
01/29/2025
501000094664
PIR FSA -B-level Action Closed Premature
01/31/2025
501000094692
MRFF QIMs not Re-Screened to B-level
01/31/2025
501000094901
PIR Cause Evaluation Quality Issues
2/05/2025
501000095746
PI&R FSA Cancellation Request Notes Lack
03/04/2025
501000095867
PI&R Gap for 23 Inverter
03/06/2025
501000095879
Gap in CV-31279 Dual Lite Indication CAP
03/07/2025
501000095909
Potential Insufficient CAPR
03/07/2025
501000095934
PI&R FSA AFI: C to B Screening Issues
03/07/2025
501000096409
2TISH-5400 D5Eng1 Cyl Ex Temp Scan Fault
03/22/2025
2000017241
Large Oil Filled Power Transformers
2000031893
Procedure Change Request for PE 6034, 20/4.16/4.16KV 2M
TRANSFORMER MAINTENANCE
08/29/2023
2000031981
Procedure Change Request for PE 6041, 2RS
TRANSFORMER MAINTENANCE
08/28/2023
606000002271
71152 Problem Identification and Resolution
600001086013
USA Group Assessment of Work Management Performance
07/18/2023 -
07/20/2023
200001933
Self-Assessment of status of Areas for Improvement (AFIs)
Identified in the 2022 WANO Peer Review
06/052023-
06/09/2023
606000002084
24 Prairie Island Maintenance and Technical Training
Focused Self-Assessment (Objective 2 & 3)
03/18/2024-
03/21/2024
606000002250
Resolution of Further Action Required in L2-IER-21-4,
Improving Plant Reliability - Recommendation 5: Enhance
Risk Elimination Bias in Decision-Making
2/11/2024-
2/18/2024
501000097300
25 PIR : CAP Keyword Use Inconsistent
04/16/2025
Corrective Action
Documents
501000097926
No Tracking Action for WO 700145492
04/24/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
501000097970
Supplemental record needed 501000066967
04/24/2025
501000098383
25 PI&R Need CA to rev RCE and LER
05/06/2025
501000098393
25PIR-PI: B-Level CA not Tracking PCR
05/06/2025
501000098458
05/07/2025
501000098468
25PIR - 501000095401 CSE Issues
05/08/2025
501000098498
25PIR - 501000086071 CSE Issues
05/09/2025
501000098504
25PIR-PI: Actions Closed Inappropriately
05/08/2025
501000098535
Conduit Clamp Fastener Hole Size
05/07/2025
501000098544
Surface Corrosion Noted on Vibe Dampener
05/07/2025
501000098546
Tape Left on Valve Limit Switch
05/07/2025
501000098552
Equipment Staged in Screenhouse
05/07/2025
501000098575
Insulation Degraded on FCU Line
05/07/2025
501000098581
Thread Engagement on Air Manifold
05/07/2025
501000098987
NRC-Identified D5 ENG 1 Coolant Leak
05/19/2025
501000098988
25PIR-PI H77.3 Drawing Error
05/19/2025
501000099048
25PIR-PI: Misalignment QF1805 Form Labels
05/21/2025
501000099086
05/21/2025
501000099097
Flux Rate Trip RCE Activity Modification
05/21/2025
Resulting from
Inspection
501000099116
25PIR-Missing Info in Condition Block
05/22/2025
2000018694
501000082220- PICETI: U1 EDG HELB Comb. Air Quality
Engineering
Evaluations
60800001170
HELB Effects on D1 and D2 Combustion Air
Operating Experience Screening Team Minutes From
04/16/25 to 04/23/25
Various
501000073947
Root Cause Evaluation Report: 2GT Lockout/2GT&
2M Locked Out
501000077958
Cause Evaluation Unit 1 Reactor Trip
10/19/2023
501000082185
Cause Evaluation: 2R33 PM 3132-1-22 PUA Performance
Issue
501000082488
Cause Evaluation: Unit 2 Reactor Trip
501000082686
Maintenance Rule Evaluation for Event on 03/09/2024 -
SP 1139 Cooling Water Valve Stroke Issues
03/21/2024
501000091761
Root Cause Evaluation: Flux Rate Trip During SP 2047
Miscellaneous
608000000896
Bus 15 Contact Resistance Evaluation
10/24/2022
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
610000002481
05/07/2025
ACEMAN
501000082416
OI Not Issued in a Timely Maner
2/28/2024
Procedure
Change Request
2000034960
PINGP 791, Rev 19 [501000082416] [Comp]
06/12/2024
Operability
Evaluations
500000327699
Prompt Operability Determination for CAP 501000082220
related to U1 HELB EDG Combustion Air Questions During
NRC CETI
2C20.8AOP1
Abnormal Operation, Instrument AC Inverters
FP-E-MR-01
Maintenance Rule Process
FP-E-MR-02
MAINTENANCE RULE SCOPING
FP-E-MR-04
Maintenance Rule - (a)(1) Process
FP-E-P21-01
CFR Part 21 Evaluations
FP-PA-ARP-01
CAP Process
FP-PA-ARP-03
Management of Change (MOC) Process
FP-PA-CSE-01
Cause Evaluation Manual
FP-PA-OE-01
Operating Experience Program
FP-PA-PA-01
Performance Analytic Trending Process
FP-R-LIC-04
CFR 21 Reports
PE 6033
2GT TRANSFORMER MAINTENANCE
PE 6034
20/4.16/4.16KV, 2M TRANSFORMER MAINTENANCE
PE 6035
161/4.16 KV 1R, TRANSFORMER MAINTENANCE
PE 6036
34.5/4.16 KV 2RX, TRANSFORMER MAINTENANCE
PE 6037
34.5/4.16 KV, 2RY TRANSFORMER MAINTENANCE
PE 6038
CT11 TRANSFORMER MAINTENANCE
PE 6039
CT12 TRANSFORMER MAINTENANCE
PE 6041
2RS TRANSFORMER MAINTENANCE
PE 6048
1GT TRANSFORMER MAINTENANCE
Procedures
SP 1951
SPENT FUEL POOL ASSEMBLY VERIFICATION
2000016617
24 Perform a SSA on Prairie Island FME Perofrmance
08/17/2024
Self-Assessments
606000002271
Self-Assessment for 2025 71152 Problem Identification
and Resolution
01/21/2025
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
700029798
PE-B15-3 Bus 15 Relay Test Trip
03/16/2023
Work Orders
700146117
Troubleshoot Flux Rate trip in NIS
10/29/2024