ML092680208
| ML092680208 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 09/25/2009 |
| From: | Jack Giessner Reactor Projects Region 3 Branch 4 |
| To: | Schimmel M Northern States Power Co |
| References | |
| EA-06-178 IR-09-009 | |
| Download: ML092680208 (37) | |
See also: IR 05000282/2009009
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE ROAD, SUITE 210
LISLE, IL 60532-4352
September 25, 2009
Mr. Mark A. Schimmel
Site Vice President
Prairie Island Nuclear Generating Plant
Northern States Power Company, Minnesota
1717 Wakonade Drive East
Welch, MN 55089
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2, NRC
BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION
REPORT 05000282/2009009; 05000306/2009009
Dear Mr. Schimmel:
On August 13, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial
team inspection of problem identification and resolution at your Prairie Island Nuclear
Generating Plant, Units 1 and 2. The inspection team also reviewed a sample of corrective
actions taken for Prairie Island in response to requirements of a confirmatory order issued to
Nuclear Management Company, LLC on January 3, 2007. The enclosed inspection report
documents the inspection findings which were discussed on August 7, 2009, with Mr. M. Wadley
and members of your staff; an exit was held on August 13, 2009, with Mr. D. Koehl and other
staff members.
This inspection was an examination of activities conducted under your license as they
relate to the identification and resolution of problems, compliance with the Commission=s
rules and regulations, and with the conditions of your operating license. Within these areas,
the inspection involved selected examination of procedures and representative records,
observations of activities, and interviews with personnel.
The inspection team concluded that on the basis of the sample selected for review, in general,
problems were properly identified, evaluated, and corrected.
Based on the results of this inspection, three NRC-identified findings of very low safety
significance were identified. These findings involved violations of NRC requirements. However,
because of their very low safety significance, and because the issues were entered into your
corrective action program, the NRC is treating the issues as Non-Cited Violations (NCVs) in
accordance with Section VI.A.1 of the NRC Enforcement Policy.
M. Schimmel
-2-
If you contest the subject or severity of these NCVs, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory
Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001; and the Resident Inspector Office at the Prairie Island Nuclear Generating Plant.
In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the
Prairie Island Nuclear Generating Plant. The information that you provide will be considered in
accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
John B. Giessner, Chief
Branch 4
Division of Reactor Projects
Docket Nos. 50-282; 50-306;72-010
License Nos. DPR-42; DPR-60; SNM-2506
Enclosure:
Inspection Report 05000282/2009009; 05000306/2009009
w/Attachment: Supplemental Information
cc w/encl:
D. Koehl, Chief Nuclear Officer
G. Salamon, Regulatory Affairs Manager
P. Glass, Assistant General Counsel
Nuclear Asset Manager
J. Stine, State Liaison Officer, Minnesota Department of Health
Tribal Council, Prairie Island Indian Community
Administrator, Goodhue County Courthouse
Commissioner, Minnesota Department
of Commerce
Manager, Environmental Protection Division
Office of the Attorney General of Minnesota
Emergency Preparedness Coordinator, Dakota
County Law Enforcement Center
M. Schimmel
-2-
If you contest the subject or severity of these NCVs, 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 a copy to the Regional Administrator, U.S. Nuclear Regulatory
Commission - Region III, 2443 Warrenville Road, Suite 210, Lisle, IL 60532-4352; the
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC
20555-0001; and the Resident Inspector Office at the Prairie Island Nuclear Generating Plant.
In addition, if you disagree with the characterization of any finding 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 Regional Administrator, Region III, and the NRC Resident Inspector at the
Prairie Island Nuclear Generating Plant. The information that you provide will be considered in
accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the
Public Electronic Reading Room).
Sincerely,
/RA/
John B. Giessner, Chief
Branch 4
Division of Reactor Projects
Docket Nos. 50-282; 50-306;72-010
License Nos. DPR-42; DPR-60; SNM-2506
Enclosure:
Inspection Report 05000282/2009009; 05000306/2009009
w/Attachment: Supplemental Information
cc w/encl:
D. Koehl, Chief Nuclear Officer
G. Salamon, Regulatory Affairs Manager
P. Glass, Assistant General Counsel
Nuclear Asset Manager
J. Stine, State Liaison Officer, Minnesota Department of Health
Tribal Council, Prairie Island Indian Community
Administrator, Goodhue County Courthouse
Commissioner, Minnesota Department
of Commerce
Manager, Environmental Protection Division
Office of the Attorney General of Minnesota
Emergency Preparedness Coordinator, Dakota
County Law Enforcement Center
DOCUMENT NAME: G:\\Prai\\Prai Is 2009 009 PI&R.doc
Publicly Available
Non-Publicly Available
Sensitive
Non-Sensitive
To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE
RIII
RIII
NAME
RLerch:dtp
JGiessnerRL
for
DATE
09/24/09
09/25/09
OFFICIAL RECORD COPY
Letter to M. Schimmel from J. Giessner dated September 25, 2009
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2, NRC
BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION
REPORT 05000282/2009009; 05000306/2009009
DISTRIBUTION:
Susan Bagley
RidsNrrPMPrairieIsland
RidsNrrDorlLpl3-1 Resource
RidsNrrDirsIrib Resource
Cynthia Pederson
Jeannie Choe
DRPIII
DRSIII
Patricia Buckley
ROPreports Resource
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Docket Nos:
50-282; 50-306;72-010
License Nos:
Report No:
05000282/2009009; 05000306/2009009
Licensee:
Northern States Power Company, Minnesota
Facility:
Prairie Island Nuclear Generating Plant, Units 1 and 2
Location:
Welch, MN
Dates:
July 20 through August 13, 2009
Inspectors:
R. Lerch, Project Engineer, Team Leader
K. Stoedter, Senior Resident Inspector, Prairie Island
S. Thomas, Senior Resident Inspector, Monticello
D. Betancourt, Reactor Engineer
R. Winter, Engineering Inspector
M. Phalen, Senior Radiation Protection Inspector
Approved by:
J. Giessner, Chief
Branch 4
Division of Reactor Projects
Enclosure
TABLE OF CONTENTS
Summary of Findings .................................................................................................................. 1
Report Details ............................................................................................................................. 4
4.
OTHER ACTIVITIES .................................................................................. 4
4OA2
Biennial Problem Identification and Resolution (71152B) ........................... 4
4OA6
Management Meetings ............................................................................ 18
SUPPLEMENTAL INFORMATION ............................................................................................. 1
KEY POINTS OF CONTACT .................................................................................................. 1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ........................................................ 2
LIST OF DOCUMENTS REVIEWED ....................................................................................... 3
LIST OF ACRONYMS USED ................................................................................................ 13
1
Enclosure
SUMMARY OF FINDINGS
IR 05000282;05000306/2009-009; 07/20/2009 - 08/13/2009; Prairie Island Nuclear Plant,
Routine Biennial Problem Identification and Resolution Inspection.
This inspection was performed by four NRC regional inspectors and the Prairie Island senior
resident inspector with a 1 week assist by the Monticello senior resident inspector. Three Green
findings were identified by the inspectors. The findings were considered Non-Cited Violations of
NRC regulations. The significance of most findings is indicated by their color (Green, White,
Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination
Process (SDP). Findings for which the SDP does not apply may be Green or be assigned a
severity level after NRC management review. The NRCs program for overseeing the safe
operation of commercial nuclear power reactors is described in NUREG-1649, Reactor
Oversight Process, Revision 4, dated December 2006.
Problem Identification and Resolution
On the basis of the information reviewed, the team concluded that the corrective action (CA)
program at Prairie Island was functional, but implementation was lacking in rigor resulting in
inconsistent and undesirable results. In general, the licensee had a low threshold for identifying
problems (issue reports called CAPs) and entering them in the CA program; however, some
significant issues went unrecognized and therefore CAPs were not issued for these. Most items
entered into the CA program were screened and prioritized in a timely manner using established
criteria; however, inspectors observed inconsistency and lack of rigor in the screening process.
Most issues, including operating experience, were properly evaluated commensurate with their
safety significance; and corrective actions were generally implemented in a timely manner,
commensurate with the safety significance. However, the inspectors identified significant
examples of issues with evaluation and corrective action shortcomings that resulted in
inspection findings. The backlog of corrective actions was large and growing. Audits and self-
assessments were determined to be performed at an appropriate level to identify deficiencies,
but the station was not taking full advantage of the processes and results. On the basis of
interviews conducted during the inspection, and a review of the employee concerns program,
workers at the site were willing to enter safety concerns into the CA program.
Inspectors continued to have concerns with the performance of the corrective action program.
The last biennial problem identification and resolution inspection in 2007 was critical of program
implementation and weaknesses were recognized by the licensee. An improvement effort was
initiated. At the time of this inspection, inspectors concluded that performance had declined and
another improvement plan was in progress. The current improvement program was not yet fully
implemented and effective.
A.
NRC-Identified and Self-Revealed Findings
Cornerstone: Initiating Events
Green. The inspectors identified a finding of very low significance and non-cited
violation (NCV) of Technical Specification 5.4.1.a for the licensee failing to obtain a
temporary or permanent procedure change, as required by their Procedure Use and
Adherence procedure, prior to implementing a procedure when it was determined that
they could not complete a required swap of two heater drain pumps using the applicable
2
Enclosure
section of the appropriate operating procedure. Once identified, the licensee took
actions to correct the issue and entered the issue into their corrective action program.
The inspectors determined the finding to be more than minor because if left uncorrected,
this finding had the potential to lead to a more significant safety concern. The inspectors
evaluated the finding using Inspection Manual Chapter (IMC) 0609, Appendix A,
Attachment 1, Significance Determination of Reactor Inspection Findings for At-Power
Situations, using the Phase 1 Worksheet for the Initiating Events Cornerstone. Since
the finding did not contribute to both the likelihood of a reactor trip and the likelihood that
mitigation equipment or functions will not be available, the inspectors concluded that the
finding was of very low safety significance. The inspectors determined that the
performance deficiency affected the cross-cutting area of Human Performance, having
work practices components, and involving aspects associated with personnel following
procedures. (H.4(b)). (Section 40A2.a(1))
Cornerstone: Mitigating Systems
Green. The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, for the failure to promptly correct a
condition adverse to quality regarding the expired qualification of safety-related molded
case circuit breakers. Specifically, the licensee failed to evaluate extending the service
life of safety-related molded case circuit breakers beyond the 20 year life expectancy, a
condition adverse to quality. The licensee entered this issue into its corrective action
program.
The finding was more than minor in accordance with IMC 0612, Appendix B, Issue
Screening, dated December 4, 2008, because the finding was associated with the
Mitigating Systems Cornerstone attribute of equipment performance and affected the
cornerstone objective to ensure the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences (i.e., core damage).
Specifically, an unqualified safety-related molded case circuit breaker could lead to
higher trip times and potential unavailability of safety-related components associated
with the bus when a circuit fault is present. The finding screened as of very low safety
significance because the finding was a qualification deficiency confirmed not to have
resulted in loss of operability or functionality in service. This finding had a cross-cutting
aspect in the area of Problem Identification and Resolution, operating experience,
because the licensee failed to implement maintenance information through changes to
station processes and procedures to address the qualification of the breakers from
Vendor Technical Bulletin 06-2 (P.2(b)). (Section 40A2.b.4))
Cornerstone: Emergency Preparedness
Green. The inspectors identified a finding of very low safety significance and a
Non-Cited Violation of 10 CFR 50.54(q), associated with 10 CFR 50.47(b)(8), for
failing to maintain the portion of the emergency plan in effect regarding the adequate
maintenance of the Technical Support Center (TSC) emergency facility. Specifically, the
implementation of procedure steps in Surveillance Procedure (SP) 1689, TSC
Ventilation System Operability Check, on January 25, 2009, resulted in the licensees
failure to test the TSC ventilation system in its as-found condition. As a result, the TSC
ventilation system and an emergency preparedness planning standard were
unknowingly degraded between July 26, 2008, and January 25, 2009. Corrective
3
Enclosure
actions for this issue included ensuring that the TSC ventilation system was
appropriately tested in July 2009 and revising SP 1689 to ensure that the TSC
ventilation system was appropriately tested in the future.
This finding was more than minor because it was associated with the attribute of
meeting the planning standards of 10 CFR 50.47(b). In addition, the finding affected
the cornerstone objective of ensuring that the licensee was capable of implementing
adequate measures to protect the health and safety of the public in the event of a
radiological emergency. The inspectors used Section 4.8 of the Emergency
Preparedness Significance Determination Process and concluded that this finding
was of very low safety significance, because the associated emergency preparedness
planning standard was not lost. The finding was determined to be cross-cutting in the
area of Human Performance, Resources because procedure SP 1689 was not complete
and accurate (H.2(c)). (Section 40A2.a(2))
B.
Licensee-Identified Violations
No violations of significance were identified.
4
Enclosure
REPORT DETAILS
4.
OTHER ACTIVITIES
4OA2 Biennial Problem Identification and Resolution (71152B)
The activities documented in Sections a. through d. constituted one biennial sample of
problem identification and resolution as defined in IP 71152.
a.
Assessment of the Corrective Action Program Effectiveness
Inspection Scope
The inspectors reviewed the licensees Corrective Action (CA) program implementing
procedures, interviewed personnel and attended CA program meetings to assess the
implementation of the CA program by site personnel.
The inspectors reviewed risk and safety significant issues in the licensees CA
program since the last NRC Problem Identification and Resolution (PI&R) inspection
in October 2007. The selection of issues ensured an adequate review of issues across
NRC cornerstones. The inspectors used issues identified through NRC generic
communications, department self assessments, licensee audits, operating experience
reports, and NRC documented findings as sources to select issues. Additionally, the
inspectors reviewed issue reports called CAPs, generated as a result of facility
personnels performance in daily plant activities. In addition, the inspectors reviewed
CAPs and a selection of completed investigations from the licensees various
investigation methods, which included root causes, apparent causes, equipment
apparent causes, and common cause investigations.
A 5 year review of emergency diesel generator (EDG) crankcase pressure issues
was also undertaken to assess the licensee staffs efforts in monitoring for system
degradation due to aging aspects. The inspectors also performed a partial system
walkdowns of the EDGs.
During the reviews, the inspectors evaluated the licensee staffs actions to comply with
the facilitys corrective action program and 10 CFR Part 50, Appendix B requirements.
Specifically, the inspectors evaluated if licensee personnel were identifying plant issues
at the proper threshold, entering the plant issues into the stations CA program in a
timely manner, and assigning the appropriate prioritization for resolution of the issues.
The inspectors also evaluated whether the licensee staff assigned the appropriate
investigation method to ensure the proper determination of root, apparent, and
contributing causes. The inspectors also evaluated the timeliness and effectiveness of
corrective actions for selected issue reports, completed investigations, and NRC
findings, including Non-Cited Violations.
5
Enclosure
Assessment
(1) Effectiveness of Problem Identification
In general, problem identification was adequate and at the right threshold. The sample
of issues reviewed by inspectors that were entered into the CA program indicated a low
threshold, with a steady generation of CAPs on a monthly basis. CAP generation
numbers appeared representative of a good problem identification ethic. Other safety
conscious work environment (SCWE) indications such as surveys and interviews
indicated willingness to identify issues and capture them in the CAP. However, there
were several previous NRC findings that demonstrated elements of failure to identify an
issue through generating a CAP. Examples included not recognizing wooden tables
used in an area of safety-related equipment as a fire load; operators proceeding with use
of non-aligned procedures which resulted in an unplanned automatic start of a diesel fire
pump; and use of inadequate procedures for feedwater heater drain pump swaps (see
the finding below). Other examples included performance indicator data for several
NRC performance indicators which were not accurately reported. This was also a repeat
issue. Inspectors at the CAP screening meeting observed problem descriptions that
were inadequate for screening and evaluating the issues, but went unchallenged by the
committee. Other issues were raised, but were not addressed by members. Specific
examples included ownership of equipment specifications for security equipment, and a
request for an operability evaluation for some uncontrolled acetone used in the plant.
The inspectors concluded that improved standards and expectations, and increased
accountability, were required for effective performance of the screening committee.
Findings
Failure to Follow Procedures for Heater Drain Pump Swaps
Introduction: The inspectors identified a finding of very low significance and a Non-Cited
Violation (NCV) of Technical Specification 5.4.1.a for failure to obtaining a temporary or
permanent procedure change, as required by the Procedure Use and Adherence
procedure, prior to implementing a procedure when it was determined that a swap of two
heater drain pumps could not be completed using the applicable section of the operating
procedure.
Description: On June 2, 2009, the operating crew was tasked with changing the heater
drain pump line-up utilizing operating procedure 2C28.4, Unit 2 Heater Drains. The
normal heater drain pump configuration for full power operations consists of two of the
three heater drain pumps operating, with one heater drain pump secured. The actual
evolution to be performed consisted of changing the heater drain tank pump
configuration of the operating heater drain pumps from pumps 22 and 23 to pumps 21
and 23. The evolution was to be conducted per section 5.3 (swapping heater drain
pumps) of operating procedure 2C28.4.
Shortly after commencing section 5.3, due to a pre-existing equipment deficiency
associated with the 23 heater drain pump speed control, the operating crew
discovered that they could not place the pump speed selector switch in Auto (as
required by step 5.3.5). Licensee procedure FP-G-DOC-03, revision 5, Procedure
Use and Adherence, step 3.3.6 required the following:
6
Enclosure
Stop work activity if a procedure deficiency is identified and activities cannot
proceed per the procedure. The procedure deficiency SHALL be corrected by
initiation of a temporary or permanent procedure change in accordance with
FP-G-DOC-04, Procedure Processing, prior to proceeding.
Instead of stopping when confronted with a procedural deficiency, the operating crew
decided to use multiple individual sections in the 2C28.4 procedure to accomplish the
heater drain tank pump swap. This decision resulted in several additional pump starts
and stops in a system which has the potential to directly impact reactivity. After
completing the evolution, the operating crew entered the issue into the corrective action
program and a condition evaluation was performed. The condition evaluation
determined that the procedure deficiency was a human performance error trap and that
the additional pump manipulations that were required to perform the heater drain pump
swap was an operator challenge. Even after it was determined to be a human
performance error trap and an operator challenge, nothing was done to address the
procedure deficiency, until after inspectors questioned the licensee, approximately
2 months later.
Analysis: The inspectors determined that the failure of the licensee to implement their
Procedure Use and Adherence procedure when confronted with an operating procedure
that could not be performed, as written, constituted a performance deficiency warranting
significance evaluation in accordance with Inspection Manual Chapter (IMC) 0612,
Appendix B, Issue Disposition Screening. The inspectors determined the performance
deficiency to be more than minor, because if left uncorrected, the issue had the potential
to lead to a more significant safety concern. The inspectors evaluated the finding using
IMC 0609, Appendix A, Attachment 1, Significance Determination of Reactor Inspection
Findings for At-Power Situations, using the Phase 1 Worksheet for the Initiating Events
Cornerstone. Since the finding did not contribute to both the likelihood of a reactor trip
and the likelihood that mitigation equipment or functions will not be available, the
inspectors concluded that the finding was of very low safety significance (GREEN). The
inspectors determined that the performance deficiency affected the cross-cutting area of
Human Performance, having work practices components, and involving aspects
associated with personnel following procedures. (H.4(b))
Enforcement: Technical Specification 5.4.1.a requires that written procedures shall
be established, implemented, and maintained covering applicable procedures
recommended in Regulatory Guide 1.33, Revision 2, Appendix A, February 1978.
The Administrative Procedures section of Regulatory Guide 1.33 specifically mentions
procedures for Procedure Adherence and Temporary Change Method." FP-G-DOC-03,
revision 5, Procedure Use and Adherence, step 3.3.6 requires, in part that the licensee
stops the work activity if a procedure deficiency is identified and activities cannot
proceed per the procedure and that the procedure deficiency SHALL be corrected
by initiation of a temporary or permanent procedure change in accordance with
FP-G-DOC-04, Procedure Processing, prior to proceeding. Contrary to this
requirement, on June 2, 2009, the licensee did not obtain a temporary or permanent
procedure change prior to proceeding when it was determined that they could not
complete a required swap of two heater drain pumps on Unit 2 using the applicable
section of the appropriate operating procedure. Because this violation was of very low
safety significance and it was entered into the licensees corrective action program
(CAP 1192435), it is being treated as an NCV, consistent with Section VI.A.1 of the
NRC Enforcement Policy. (NCV 05000306/2009009-01)
7
Enclosure
(2) Effectiveness of Prioritization and Evaluation of Issues
Assessment
The inspectors determined that the overall performance in prioritization and evaluation of
issues was acceptable, but marginal. Some corrective actions are years old and
completion priority is not linked to potential safety significance. For example, a final
White finding for the inadequate design of the component cooling water system (second
quarter 2009) was initially discovered by the licensee in completing a corrective action
which was over 3 years old. The issues in the CA program were being prioritized by
significance (root cause, apparent cause, common cause, fix) and by due dates. This
made it difficult to prioritize most routine issues assigned only due dates. The licensee
was applying a safety related (condition adverse to quality (CAQ)) versus non-safety
related (not a condition adverse to quality (NCAQ)) screening criteria to assist with
prioritization. Inspectors noted that this approach did not address the risk to plant
operations and was not always accurately applied, although all issues were addressed.
In addition, several issues in the inspection period occurred which had been identified
earlier, but were not corrected in time to prevent recurrence. These issues included:
Technical Support Center (TSC) dampers, underground cable failures (for which
corrective actions had been identified but not completed), and insulation on auxiliary
feedwater piping which was an issue in a previous outage.
While most evaluations were good, some evaluation weaknesses observed by
inspectors could be characterized as addressing the symptoms rather than the causes.
Several other issues had been identified in the inspection period where questioning by
inspectors resulted in significant changes to the evaluations and ultimately NRC findings.
Specifically, inspectors questioned evaluations on employee respirator qualifications, a
control room chill water pump mission time, and an event concerning a release of
hydrazine and others. Most weaknesses identified by inspectors could be generally
attributed to a lack of rigor in the analysis.
Observations
Operator Burdens
Corrective actions for operator burdens have not been adequately prioritized or effective
in maintaining operator burdens at a minimized level. The inspectors evaluated how the
licensee was handling selected long-term equipment issues and operator burdens and
the licensees efforts to reduce the numbers of each. A general assessment of key
areas is as follows:
5 of the top 10 equipment issues have been on the list for between 3 and
6 years;
there are currently in excess of 70 work request stickers in the control room;
5 of the 7 Operator Workarounds are in excess of 2 years old;
There are currently approximately 81 Operator Burdens. These burdens consist of
7 operator workarounds; 22 operator challenges; 38 control room deficiencies; and
14 long term installed clearances. The overall number of Operator Burdens also could
include temporary modifications which impact operations, but the inspector did not
evaluate this component and their number is not reflected in the 81 Operator Burdens.
8
Enclosure
The licensee has significantly exceeded their Operator Burden performance indicator
goal (<37) for at least the past 8 months.
Based on an increasing trend in the numbers of Operator Burdens over the past
2 months, the licensee has not successfully implemented corrective actions to reduce
and manage the number of existing Operator Burdens. Some observations associated
with specific Operator Burdens are as follows:
There is an operator workaround associated with each of the main turbine turning
gears failing to engage in automatic [schedule dates for repair are 12/7/2009 for
11, and 5/10/2010 for 21]. Since the failure of the 11 turning gear to engage
following the July 2008 reactor trip forced the licensee to break condenser
vacuum and significantly impacted the trip response and recovery, the inspectors
questioned the priority placed on remedying these deficiencies.
There is an Operator Challenge associated with each of the Instrument Air (IA)
Compressors (121/122/123) aftercooler cooling water control valve having to be
manually bypassed, due to the control valves being obsolete and non-functional.
For each compressor, the operators are tasked with maintaining the cooling
water pressure in a band higher than 60 psig, but less than the system relief
pressure of 75 psig. Exacerbating this condition is the fact that some of the
piping is experiencing periodic silting, which also impacts the ability to maintain
the appropriate pressure band to the IA compressors. The inspectors were
informed that the aftercooler cooling water control valves would not be repaired
since a major instrument air modification was being planned. Since the IA
system has some risk significance, the inspectors questioned the decision to live
with this operator challenge until the IA modification was completed (currently
scheduled for July 2010).
There was an Operator Challenge associated with the operation of heater drain
pumps. A finding associated with this issue in Section 40A2.a(1).
Foxboro H-Line Modules
Another long term equipment issue evaluated by the inspectors was associated with the
Foxboro H-Line modules which are used in reactor protection, reactor control, and
balance of plant applications. These components were first identified in 1985 for
replacement to be completed by 1995. Instead of replacement, they were reclassified as
run to failure. Since that time, the licensee has considered several options to address
the obsolescence of these modules. During July 2008, a plant trip occurred as a result
of the failure of one of these modules, coincident with reactor protection system (RPS)
testing. In summary, the licensee continues to be at risk for a plant trip during their
monthly RPS testing. No long term corrective action to address the obsolete Foxboro
modules has been implemented. The licensee currently has funded a project designed
to replace the obsolete modules.
9
Enclosure
Findings
Inadequate Technical Support Center Ventilation System Testing
Introduction: The inspectors identified a Non-Cited Violation (NCV) of
10 CFR 50.47(b)(8) having a very low safety significance (Green) for failing to maintain
the portion of the emergency plan in effect regarding the adequate maintenance of the
TSC emergency facility. Specifically, the implementation of procedure steps in
Surveillance Procedure (SP) 1689, TSC Ventilation System Operability Check, on
January 25, 2009, resulted in the licensees failure to test the TSC ventilation system in
its as-found condition. As a result, the TSC ventilation system and an emergency
preparedness planning standard were unknowingly degraded between July 26, 2008
and January 25, 2009.
Description: The Prairie Island TSC is a two story structure within the turbine building.
The upper floor is the TSC proper and the lower floor is an overflow area that is used as
the work control center during normal operation. The TSC ventilation system consists of
separate upper and lower trains that, in the normal mode, draws in outside air through
two large dampers, blows the air through an air handler for heating or cooling, and then
recirculates the air through the structure and back to the air handlers through return
ducts. When switched to the emergency mode, which is required during TSC activation,
the normal outside air dampers would close, and a smaller outside air damper would
modulate open to supply air through particulate and charcoal filters to the air handlers.
In addition, some of the air in the return ducts would also be directed through the filters.
The air handler fans remain on to recirculate the air.
As part of this inspection, the inspectors reviewed the corrective actions associated with
Non-Cited Violation 05000282/2008002-01; 05000306/2008002-01. During this review,
the inspectors identified that operations personnel were verifying the position of four
manual TSC ventilation system dampers as discussed in SP 1689, TSC Ventilation
System Operability Check. If any of the dampers were found in an unexpected position,
SP 1689 allowed the dampers to be repositioned prior to performing the system
operability test. Based upon the information discussed above, the inspectors were
concerned that the licensee was potentially pre-conditioning the TSC ventilation system.
This pre-conditioning could result in the failure to demonstrate the continued functionality
of the TSC ventilation system due to the failure to test the system in the as-found
configuration.
The inspectors reviewed the results of TP/SP 1689 performed between March 5, 2008,
and July 31, 2009. The inspectors identified that two of the manual dampers were
re-positioned prior to performing SP 1689 on January 25, 2009. As a result, the
inspectors were concerned that the TSC may have been non-functional for
approximately 6 months during the timeframe mentioned above. The inspectors
determined that the TSC was currently functional due to the successful completion of
SP 1689 (without any damper adjustments) on July 31, 2009.
The inspectors discussed this issue with operations and engineering personnel. The
licensee conducted a functionality review and determined that the TSC ventilation
system was functional but degraded from July 26, 2008 through January 25, 2009 due to
the failure to test the TSC ventilation system in its as-found configuration. The licensee
10
Enclosure
also implemented a procedure change request to remove the procedure steps that
allowed the dampers to be repositioned prior to performing SP 1689.
Analysis: The inspectors concluded that the failure to test the TSC ventilation system in
a manner that supported emergency response activities was a performance deficiency
because it could result in the failure to maintain TSC habitability, and a failure to ensure
adequate protection of emergency response personnel from airborne contamination
during an actual emergency.
The inspectors concluded that the finding did not have actual safety consequences
because there were no events that resulted in a radioactive release between July 2008
and January 2009. The finding did not affect the NRCs ability to perform its regulatory
function and was not willful. The inspectors applied the Significance Determination
Process (SDP) to the finding and determined it was associated with a failure to meet a
regulatory requirement in the emergency preparedness cornerstone. The finding was
more than minor because it was associated with the attribute of meeting the planning
standards of 10 CFR 50.47(b) and affected the cornerstone objective of ensuring that
the licensee was capable of implementing adequate measures to protect the health and
safety of the public in the event of a radiological emergency.
In accordance with the SDP Phase 1 Screening Worksheet of Inspection Manual
Chapter (IMC) 0609, the inspectors applied Appendix B, Emergency Preparedness
Significance Determination Process, and determined that Section 4.8 applied. The TSC
function was degraded for a period of longer than 7 days from the time of discovery as
defined in the emergency preparedness SDP. Although not specifically discussed in
Section 4.8 of the SDP, a finding involving a degraded planning standard was one color
lower in significance than a finding involving a loss of the planning standard. Since a
loss of the TSC for more than 7 days from the time of discovery would have been a
White finding under Section 4.8, a degraded TSC was determined to be a Green finding.
This was supported by the flow chart on Sheet 1 of Section 4.8 by answering yes to the
planning standard problem decision point, no to the risk significant planning standard
problem decision point, no to the planning standard functional failure decision point,
and thus arriving at the Green result box. This finding was also related to the
cross-cutting area of Human Performance, Resources because procedure SP 1689
was not complete and accurate (H.2(c)).
Enforcement: Part 50.54(q) of 10 CFR required that licensees follow and maintain in
effect emergency plans which meet the standards in 10 CFR 50.47(b). Part 50.47(b)(8)
of 10 CFR required that adequate emergency facilities and equipment to support the
emergency response be provided and maintained. Prairie Island Nuclear Generating
Plant Emergency Plan, Revision 40, Section 7.1.1, required that the TSC have a
shielding and ventilation cleanup system to provide habitability under accident
conditions. Contrary to the above, the licensee failed to maintain the portion of their
emergency plan in effect regarding the adequate maintenance of the TSC emergency
facility. Specifically, the implementation of procedure steps in SP 1689 on January 25,
2009, resulted in the licensees failure to test the TSC ventilation system in its as-found
condition. As a result, the TSC ventilation system and an emergency preparedness
planning standard were unknowingly degraded between July 26, 2008 and January 25,
2009. The licensee entered this issue into their corrective action system as
CAP 1192415. The licensee also initiated a procedure change request to ensure that
the TSC ventilation system was tested in its as-found configuration in the future.
11
Enclosure
Because this violation was of very low safety significance and was entered into
the licensees corrective action program, this violation is being treated as a
Non-Cited Violation consistent with Section VI.A of the NRC Enforcement Policy
(NCV 05000282/2009009-02; 05000306/2009009-02). Corrective actions for this
issue consisted of ensuring that the TSC ventilation system was appropriately tested
in July 2009 and revising SP 1689 to ensure that the TSC ventilation system was
appropriately tested in the future.
(3) Effectiveness of Corrective Actions
While the majority of issues were effectively resolved, a significant number of repetitive
issues were reviewed by inspectors during the inspection period. A lack of consistent
effectiveness was evident in repeated issues with very high radiation area keys, security
weapons controls, check valve SI-9 5, and roll-up door compensatory actions.
Additionally, many long term issues lingered. Issues considered by inspectors to be
lacking resolution included the turbine turning gears on both units, operator burdens,
Foxboro controller issues, TSC dampers, and air compressor aftercooler cooling water
control valves.
Work load appeared to be a factor in corrective action effectiveness by impacting the
timeliness of the implementation of actions. The station had backlogs in corrective
actions as well as work requests, engineering requests and other work items. Backlogs
existed at the time of the last PI&R and have not improved. Some backlogs have
increased.
Observations
Five Year Historical Review - D5/D6 Emergency Diesel Generator Crankcase Pressure
Issues
In the late 1990s the licensee began experiencing high crankcase pressure conditions
on the D5 and D6 emergency diesel generators during routine surveillance testing.
This condition has resulted in the entry into numerous unplanned limiting conditions
for operation and a Unit 2 shutdown. During this inspection, the inspectors reviewed
a sampling of corrective action program documents regarding this issue that were
generated between the years 2004 and 2009. The inspectors also discussed this issue
with operations, engineering, and management personnel. The corrective action
documents indicated that the elevated crankcase pressure condition was caused by the
reduction in diesel fuel oil sulfur content. Based upon this information, the licensee had
pursued two courses of action to resolve the crankcase pressure condition. The first
course of action involved modifying the engine crankcase breather system. The second
course of action involved increasing the sulfur content of the diesel fuel oil. In 2009, the
licensee began introducing an additive to the diesel fuel oil to increase the sulfur content.
The licensee referred to this action as fuel oil doping. Although the fuel oil doping had
resulted in a reduction in engine crankcase pressure for the D5 and D6 emergency
diesel generators, the licensee was continuing to monitor engine performance. The
licensee planned to make a decision regarding the need for the breather system
modification after obtaining additional engine performance data.
12
Enclosure
Findings
No findings of significance were identified.
b.
Assessment of the Use of Operating Experience
1) Inspection Scope
The inspectors reviewed the licensees implementation of the facilitys Operating
Experience (OE) program. Specifically, the inspectors reviewed implementing operating
experience program procedures, attended CA program meetings to observe the use of
OE information, reviewed completed evaluations of OE issues and events, and reviewed
selected monthly assessments of the OE composite performance indicators. The
inspectors review was to determine whether the licensee was effectively integrating OE
experience into the performance of daily activities, whether evaluations of issues were
proper and conducted by qualified personnel, whether the licensees program was
sufficient to prevent future occurrences of previous industry events, and whether the
licensee effectively used the information in developing departmental assessments and
facility audits. The inspectors also assessed if corrective actions, as a result of OE
experience, were identified and effectively implemented.
2) Assessment
The inspectors determined that the overall performance of the operating experience
program was acceptable, but that a negative trend in the use of Operating Experience
needs to be promptly addressed. The licensee utilized a program that was structured
and established reasonable objectives. The licensee used its screening meetings to
select relevant OE and direct them to the appropriate department. The inspectors did
identify, by reviewing the Operating Experience procedure, that the licensee had
committed to assess its program every 2 years, but the licensee had not performed a
self-assessment since 2005. This information was provided to the licensee and is being
addressed by the licensees corrective action program. Two key observations and a
finding, discussed below, indicate the licensee is not being proactive in its use of OE.
Nuclear Oversight (NOS) performed independent assessments of the site. They
appeared to identify some negative trends. Additionally, the evaluations of external OE
and NRC generic communications the inspectors reviewed seemed to appropriately
address some issues identified in the OE. However, the NRC, not the site, identified the
trend that OE was not being effectively used at the site.
3) Observations
Tracking of Vendor Manual Changes
It was noted during this inspection that vendor manual changes were difficult to track
through the corrective action program. The inspector reviewed the Vendor Manual
Procedure to evaluate the process by which the vendor manual changes are
incorporated into the appropriate procedures, and also interviewed the Vendor
Information Coordinator (VIC) to further understand the process. The procedure guided
the VIC to use the corrective action program to process changes to procedures, but the
inspector was not able to find any open vendor manual changes. The VIC noted that the
person assigned the action would know it, but the inspector noted that for every one else
13
Enclosure
it is difficult to find. The inspector concluded there was a vulnerability in the tracking
system since there is a potential to not complete the changes by the due date. In
addition, the staff may not know what changes are being processed through the
corrective action program. One NRC identified and several licensee identified instances
were found in which vendor manual changes had not being incorporated into
procedures. The VIC noted that an action had been recently implemented to add a
method to track the vendor manual changes, and it was entered into the licensees
corrective action program.
Untimely Implementation of Operating Experience
During the inspection period the inspectors reviewed a previously identified
trend regarding the untimely implementation of OE (see NRC inspection report
05000282/2009003; 05000306/2009003). The trend had five new examples of untimely
operating experience that led to operational challenges and equipment failures. For
example, actions from the lessons learned on long standing issues for Unit 1 cavity
leakage were still open and had not been implemented. In addition, several OE sources
for flooding and high energy line breaks were not effective in identifying potential issues
at the site until brought to the attention by the NRC. Through the review of various OE
evaluations, the inspectors agreed with the identified trend that there is a weakness
related to the implementation of OE that could lead to additional equipment failures or
failure to identify an adverse condition. A condition report was initiated to address the
trend of untimely implementation of corrective actions, but it was too soon to see if the
actions taken have been effective.
Additionally, during this inspection the inspector identified another example of
untimely implementation of OE in that a number of safety-related breakers were
past their qualified life, as mentioned in the OE Evaluation of a Technical Bulletin
from Westinghouse. The condition had not been addressed or corrected. This
issue is discussed in the findings section.
4) Findings
Failure to Qualify Safety-Related Molded Case Circuit Breakers
Introduction: The inspectors identified a Non-Cited Violation (NCV) of 10 CFR Part 50,
Appendix B, Criterion XVI, Corrective Actions, for the failure to promptly correct a
condition adverse to quality regarding the expired qualification of safety-related molded
case circuit breakers.
Description: On August 3, 2009, the inspectors identified that the licensee had deferred
the preventive maintenance for five safety-related HFB Molded Case Circuit Breakers
(MCCBs) beyond 125 percent of the required 5 year frequency. The inspectors
questioned the reason for the deferral, and also requested that the licensee provide the
life expectancy of the MCCBs, as well as the duration that these breakers had been in
service. The licensee stated that the deferral was due to unanticipated complications
encountered in the engineering change process associated with the selection of an
acceptable replacement model, as well as parts availability. It was also stated that there
was no indication of any age-related degradation in the operation of the breakers. The
licensee also stated that, per Westinghouse Technical Bulletin-06-02 (TB-06-02), dated
March 10, 2006, the life expectancy for these breakers was 20 years due to the type of
14
Enclosure
grease and oil used in them, which were found to be limiting factors for continued
operability within published specifications. At the time the bulletin was received, the
breakers in question had been in service for 23 years. At the time of this inspection,
those breakers had been in service for 26 years.
The licensee had entered the 2006 bulletin into their corrective action program as
AR 01019169. The licensees evaluation of the bulletin determined that a total of
89 MCCBs of the affected style (both safety and non-safety related) were in use at
Prairie Island at the time. As a result, the licensee developed a corrective action to
replace the safety-related MCCBs every 15 years going forward; however, they failed
to evaluate the acceptability of operation of the currently installed MCCBs that were
beyond their 20 year life expectancy. The licensee also failed to extend the qualified life
by meeting the requirements of TB-06-2 by using a combination of preventive
maintenance and aging management.
As of August 06, 2009, the licensee had 13 safety-related MCCBs that were older than
20 years for which the licensee had not performed an evaluation to provide reasonable
assurance that these circuit breakers could perform their safety function until
replacement. Some examples of the affected breakers include: BKR-112G-1 to the
Shield Building Gas Radiation Monitor, BKRG-12 121 to the Control Room Chilled Water
Pump and BKRG-122G-15 to the Control Room Air Handler and Fan.
On August 9, 2009 the licensee performed an operability determination and
determined that the HFB breakers were operable, but non-conforming, based on
acceptable performance history of the breakers during past preventive maintenance
and no in-service failures. Based on discussion with Westinghouse, the licensee tested
three MCCBs (10 percent of the population) to support that the breakers had not been
affected by binding or sluggish operation. The three MCCBs were selected based on
the length of time since their last test. The results showed trip times in the appropriate
range. The licensee stated that they plan to test the rest of the breakers before the next
refueling outage in October 2009.
Analysis: The inspectors determined that the failure to promptly correct a condition
adverse to quality regarding the expired qualification of safety-related molded case
circuit breakers was a performance deficiency. Specifically, the licensee failed to
evaluate extending the service for safety-related molded case circuit breakers beyond
the 20 year life expectancy, a condition adverse to quality. The finding was determined
to be more than minor in accordance with IMC 0612, Appendix B, Issue Screening,
dated December 4, 2008, because the finding was associated with the Mitigating
Systems Cornerstone attribute of equipment performance and affected the cornerstone
objective to ensure the availability, reliability, and capability of systems that respond to
initiating events to prevent undesirable consequences (i.e., core damage). Specifically,
an unqualified safety-related molded case circuit breaker could lead to higher trip times
and potential unavailability of safety-related components associated with the bus when a
circuit fault is present.
The inspectors determined the finding could be evaluated using the SDP in accordance
with IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 -
Initial Screening and Characterization of Findings, Table 3b for the Mitigating System
Cornerstone. Although the molded case circuit breakers associated with this
performance deficiency affected systems and components in the Mitigating System,
15
Enclosure
Occupational Radiation Safety and the Containment Barrier Cornerstones, the number
of mitigating systems affected was significantly higher than the systems associated with
the Containment Barrier and Occupational Radiation Safety Cornerstones and was used
to evaluate the significance of the finding. The finding screened as of very low safety
significance (Green) because the finding was a qualification deficiency confirmed not to
result in loss of operability or functionality.
This finding had a cross-cutting aspect in the area of Problem Identification and
Resolution, operating experience, because the licensee failed to implement maintenance
information through changes to station processes and procedures to address the
qualification of the breakers from Vendor Technical Bulletin 06-2 (P.2(b)).
Enforcement: 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires,
in part, that measures be established to assure that conditions adverse to quality, such
as failures, malfunctions, deficiencies, deviations, defective material and equipment, and
nonconformance are promptly identified and corrected. Contrary to the above, from
March 10, 2006 to August 9, 2009, the licensee failed to promptly correct a condition
adverse to quality regarding the expired qualification of safety-related molded case
circuit breakers. Specifically, although the bulletin was in their corrective action program
as AR0119169, the licensee failed to evaluate extending the service for safety-related
molded case circuit breakers beyond the 20 year life expectancy. Because this violation
was of very low safety significance and was entered into the licensees corrective action
program as AR 1192430, this violation is being treated as an NCV, consistent with
Section VI.A.1of the NRC Enforcement Policy (NCV 05000282/2009009-03; 05000306/2009009-03). Corrective actions included conducting an operability
determination and setting a program in place to test the remaining breakers.
c.
Assessment of Self-Assessments and Audits
1)
Inspection Scope
The inspectors assessed the licensee=s ability to identify and enter issues into the station
CAP, prioritize and evaluate issues, and implement effective corrective actions, through
efforts from departmental and nuclear oversight (NOS) assessments. The inspectors
assessed the licensee=s ability to properly capture the documented deficiencies from
assessments into CAP items. The inspectors reviewed the focused self-assessment
performed on the corrective action program early in 2009.
2) Assessment
While the licensee has programs and processes in place to conduct meaningful
assessments and audits, full benefits of these programs were not realized due to their
limited application and ineffective corrective actions. Organizational self assessments
were limited to assessments conducted prior to audits by external organizations. While
problem identification was reasonable and many issues were resolved, the program was
driven by external schedules that may not address station weaknesses. Backlogs of
other work products were a limiting factor in assigning resources to perform self
assessments. Also, the station was not responding rigorously to issues identified by
NOS (see the observations below) such that some NOS identified issues were not
corrected before NRC inspectors identified and evaluated them.
16
Enclosure
The site performed a 2009 PI&R self-assessment of the CA program and determined,
although several areas needed improvement, the station was adequately implementing
the CA program. The assessment documented issues in the major areas of cause
analysis, safety culture, effectiveness of performance indicators, management oversight,
timely and effective execution of corrective actions and completion dates based on the
significance of issues. The CAP overall effort was hindered by having no simple
mechanism to identify ineffective corrective actions. Although the causes were generally
found, most apparent cause evaluations tended to be short and did not always examine
the issue in sufficient depth to resolve the issue fully. Backlog in the work products
including the CA program work products remained high. The site did not consistently set
due dates for corrective actions that are commensurate with the significance of issues,
leading to having repeat issues.
Generally, the assessment identified issues that were consistent with the conclusions of
the inspectors. The inspectors held discussions with the NOS Manager regarding NOS
activities with respect to the station=s performance in CA program. The inspectors
concluded that although the station has had improvement programs and effort toward
CA program improvement since the last PI&R, recognizable improvement in most areas
was lacking.
3) Observations
Nuclear Oversight Assessments
The inspectors considered the quality of the NOS assessments to be adequate.
However, the inspectors were concerned that several NOS identified issues have
remained open and unresolved for an extended period of time. Specifically, the first
quarter 2009 NOS Assessment Report identified that the stations radiation protection
program had been assessed as below expectations since the fourth quarter of 2006.
The stations corrective actions program had been assessed by NOS as performing
below expectations for over 3 1/2 years. The site has one White finding in the public
radiation cornerstone from the first quarter 2009. In discussions with the NOS staff, it
was identified that although there were processes in place to escalate specific and
discrete issues, a similar process for programmatic issues was just recently
implemented. This change in the NOS program was designed to increase the focus
on resolving long-standing programmatic issues through accountability of the line
organization. Requiring the line organizations that are assessed as below expectations
for two consecutive quarters to develop recovery plans that are reviewed and approved
by the line managers, the site vice president, and the NOS manager, should drive
correction of the actual performance deficiency and facilitate the timely resolution of
issues.
Additionally, further review by NRC inspectors identified that some of the issues
chronically identified by NOS lacked consistent performance deficiency specificity.
For example, while the NOS reports state that the radiation protection program was
performing below expectations, the actual deficiencies described in each report varied.
The first quarter 2009 report identified the radiation protection areas of concern as
human performance events and the key control program. In the third quarter 2008
report, the areas of concern were identified as ALARA planning, personal contamination
events, and the trip ticket program. The escalation process described above is designed
to focus the line organization around solving specific issues, while more clearly defining
17
Enclosure
the systemic concerns that NOS may have with any particular program. Additionally,
there is evidence that the line organization is slow to respond and resolve issues
identified by the NOS organization. Specifically, NOS recognized issues associated with
respirator qualifications, the load sequencer and compensatory measures with the roll up
door, prior to these issues being identified and issued as violations by the NRC.
4) Findings
No findings of significance were identified.
d.
Assessment of Safety Conscious Work Environment (SCWE)
1) Inspection Scope
The inspectors assessed the licensees safety conscious work environment through the
reviews of the facilitys employee concerns program (ECP) implementing procedures,
postings for maintaining employee awareness of the ECP program, literature,
discussions with the ECP coordinator, interviews with personnel from various
departments, and reviews of issue reports. The inspectors reviewed the results from an
August 2008 Safety Culture Survey, and reviewed corrective actions taken in response
to an order issued to Nuclear Management Company LLC dated January 3, 2007.
2) Assessment
The licensee maintains an accessible, functioning ECP program, promotes a safety
conscious work environment to employees, and periodically assesses employee
attitudes though email surveys and a safety culture assessment by an outside team from
the Utilities Service Alliance. Based on the CAPs generated at the plant, discussions
with employees, and survey results, the SCWE at the plant appeared adequate and no
concerns were identified by the inspectors.
3) Observations
Safety Conscious Work Environment
The ECP procedure does not reference 10 CFR 50 Appendix B. Employees raising
concerns through the ECP program may identify a condition adverse to quality, a
condition that must be corrected. The ECP coordinator was aware that conditions
adverse to quality were to be entered into the CA program for correction, and records
indicated that no conditions adverse to quality were identified that had not had a CAP
written.
Confirmatory Order EA-06-178
(Discussed) Corrective Actions for Confirmatory Order for NMC Re: 10 CFR 50.7
Violation (EA 2006-178) Inspectors reviewed the CAPs initiated to address the Order.
The biennial PI&R inspection of 2007 (inspection report 2007006) reviewed SCWE
training material, which had been developed in response to NRC Confirmatory Order
Enforcement Action (EA-06-178). Actions were completed in 2008 addressing a safety
conscious work environment in all organizations of the plant, including the appropriate
headquarters personnel. Corrective actions included periodic training requirements so
18
Enclosure
new employees would be trained and existing employees retrained on a programmed
schedule. Effectiveness reviews were also performed. The inspectors concluded that
the actions appeared thorough and complete such that the issues of the order were
adequately addressed for Prairie Island Nuclear Generating Plant.
4) Findings
No findings of significance were identified.
4OA6 Management Meetings
Exit Meetings Summaries
On August 7, 2009, the inspectors presented some of the inspection results to
M. Wadley (then Vice President), and other members of the licensee staff. The
licensee acknowledged the issues presented. The inspectors confirmed that none
of the potential report input discussed was considered proprietary.
On August 13, inspectors conducted an exit by telephone with licensee
staff and presented the final determination of NCV 05000282/2009009-03; 05000306/2009009-03, Molded Case Circuit Breaker Qualification. In the previous
week, the licensee tested a sample of breakers, confirming the proper functional
capability (see Section 4OA2.b.4, Assessment of the Use of Operating Experience).
ATTACHMENT: SUPPLEMENTAL INFORMATION
1
Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
D. Koehl, Chief Nuclear Officer, Excel Energy *
M. Wadley, Site Vice President +
B. Sawatzke, Director Site Operations +
K. Ryan, Plant Manager +
D. Albarado, Organizational Effectiveness
J. Anderson, Regulatory Affairs Manager +
T. Bacon, Ops Support Manager
B. Boyer, RP Supervisor
M. Brassart. Engineering Supervisor +
H. Butterworth, Operations Support Fleet Director Operations Standards
L. Clewett, Business Support Manager +
M. Davis, Regulatory Compliance Analyst +
C. England, RP/Chemistry Manager Acting
B. Flynn, Safety and Human Performance Manager
S. Ford, Design Engineering Supervisor
D. Hartinger, System Engineering Supervisor
R. Hite, Radiation Protection and Chemistry Manager
M. Hopman, Engineering Supervisor
S. Ingalls, Operations Shift Manager +
B. Kappes, Nuclear Oversight Assessor
D. Kettering, Site Engineering Director +
J. Kivi, Employee Concerns Program Manager
L. Koehl, Communications *
S. Lappegaard, On-line Manager
J. Lash, Operations Manager
G. Lenertz, Maintenance Engineer
L. Lisson, IT
R. Madjerich, Production Planning Manager +
S. Martin, Nuclear Oversight
S. McCall, Engineering Manager, plant and System Engineering
K. Mews, Regulatory Affairs Engineer +
J. Muth, Nuclear Oversight Manager
S. Myers, Design Engineering Manager +
C. Nash, Chemistry General Supervisor
S. Northard, Performance Improvement Manager
S. Oswald, Regulatory Analyst
K. Petersen, Performance Assessment
A. Pullam, Training Supervisor
B. Rogers, Training Supervisor +
M. Schmidt, Maintenance Manager
S. Skoyen, Engineering programs Manager
J. Sternisha, Training Manager
J. Verbout, IT
J. Windschill, Fleet Performance Assessment Manager
2
Attachment
+ August 7 and 13, exits
- August 13, 2009 teleconference exit
Nuclear Regulatory Commission
J. Giessner, Branch Chief, Branch 4 Division of Reactor Projects, Region III
P. Zurawski, Resident Inspector, Prairie Island
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened 05000306/2009009-01
Failure to Follow Procedures for Heater Drain
Pump Swaps05000282/2009009-02; 05000306/2009009-02
Inadequate Technical Support Center (TSC)
Ventilation System Testing 05000282/2009009-03; 05000306/2009009-03
Failure to Qualify Safety-Related Molded Case
Circuit Breakers
Closed 05000306/2009009-01
Failure to Follow Procedures for Heater Drain
Pump Swaps05000282/2009009-02; 05000306/2009009-02
Inadequate Technical Support Center (TSC)
Ventilation System Testing 05000282/2009009-03; 05000306/2009009-03
Failure to Qualify Safety-Related Molded Case
Circuit Breakers
Discussed
EA 2006-178
ORD
Confirmatory Order for NMC 10 CFR 50.7
Violation (EA 2006-178)
3
Attachment
LIST OF DOCUMENTS REVIEWED
The following is a list of documents reviewed during the inspection. Inclusion on this list
does not imply that the NRC inspectors reviewed the documents in their entirety, but
rather, that selected sections of portions of the documents were evaluated as part of the
overall inspection effort. Inclusion of a document on this list does not imply NRC
acceptance of the document or any part of it, unless this is stated in the body of the
inspection report.
OPERATING EXPERIENCE
Number
Description or Title
Date or Revision
N/A
OEs discussed during 7/23/09 OE
Screening Meeting
07/23/2009
01019169
Westinghouse TB-06-2 Aging Issues and
Subsequent Operating issues for Breakers
that are at their 20 Year Design/Qualified
Lives
05/14/2006
01114450
OE25538- Emergency Diesel Generator
Starting Air Check Valve Failure
01/07/2008
01114820
NRC in 2007-28: Potential Common
12/11/2007
01125130
SOER 2007-01 Initial Review
06/14/2008
01125290
Potential Trend in SOER implementation
quality
03/15/2008
01129444
Conduct FSA - SOER 99-01 and 01-03
review
07/02/2009
01133930
SOER 96-1 Implementation and
Effectiveness Review
02/20/2009
01133939
SOER 03-1 Implementation and
Effectiveness Review
04/06/2009
01133941
SOER 93-1 Implementation and
Effectiveness Review
02/28/2009
01133942
SOER 96-2 Implementation and
Effectiveness Review
04/06/2009
01133947
SOER 97-1 Implementation and
Effectiveness Review
04/09/2008
01133949
SOER 98-1 Implementation and
Effectiveness Review
02/28/2009
01133954
SOER 87-1 Implementation and
Effectiveness Review
11/22/2008
01133958
SOER 02-4 Implementation and
Effectiveness Review
05/06/2009
01133963
SOER 95-1 Implementation and
Effectiveness Review
12/22/2008
01137327
SOER 07-02, Intake Cooling Blockage
05/15/2008
01141208
Actions not fully implemented for SOER
03-02
02/03/2009
01143220
SOER FSA: Analysis of a Single point
vulnerability
07/03/2008
4
Attachment
OPERATING EXPERIENCE
Number
Description or Title
Date or Revision
01143430
SOER FSA: Sustainability of SOER
actions
09/24/2008
01156119
Part 21 issue with Gaskets
10/19/2008
01169744
SOER 90-2 Implementation and
Effectiveness Review
04/06/2009
01169746
SOER 91-1 Implementation and
Effectiveness Review
04/30/2009
01175087
FBM: Lifting and Rigging and evaluate
SOER 06-01 Actions
03/26/2009
PLANT PROCEDURES
Number
Description or Title
Date or Revision
2C28.4
Unit 2 Heater Drains
Rev. 26
5AWI 3.10.8
Equipment Problem Resolution Process
Rev. 13
5AWI 3.15.5
Rev. 14
DP-NO-IA-01
Internal Assessments
Rev. 04
DP-NO-IA-01
Internal Assessments
Rev. 01
DP-NO-IA-03
Internal Assessment Issue
Characterization and Tracking
Rev. 05
DP-NO-IA-06
Stop Work Order
Rev. 01
DP-NO-IA-07
Internal Assessment: Topic Selection,
Scheduling, and Quarterly Reporting
Rev. 04
FG-PA-CAE-01
Corrective Action Effectiveness Review
Manual
Rev. 06
FG-PA-DRUM-01
Department Roll Up Meeting (DRUM)
Manual - Department Performance
Trending
Rev. 08
FP-EC-ECP-01
Employee Concerns Program
Rev. 03
FP-E-VEN-01
Vendor Manual Control
Rev. 02
FP-G-DOC-03
Procedure Use and Adherence
Rev. 05
FP-OP-OB-01
Operator Burden Program
Rev. 00
FP-PA-ARP-01
Cap Action Request Process
Rev. 22
FP-PA-OE-01
Operating Experience
Rev. 12
FP-PA-SA-01
Focused Self-Assessment Planning,
Conduct and Reporting
Rev. 09
FP-PA-SA-02
Focused Self-Assessment and Formal
Benchmarking Scheduling
Rev. 05
5
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
CR Number
Description or Title
Date or Revision
0831627
D5 Slow Start Surveillance Terminated Due To
High Crankcase Pressure
04/11/2005
0833665
Unexpected Signs of Wear on D5 Engine 1
Cylinder
04/15/2005
0864735
Opportunities are Being Missed to Improve
Equipment Performance via the Corrective
Action Program
07/07/2005
01013473
D6 Experienced High Crankcase Pressure
02/04/2006
01035981
Speed Control Problems with 23 Charging
Pumps Resulted in Flow Variations to Reactor
Coolant System and Charging Line High
Pressure Alarms
06/18/2006
01040613
Inadequate Implementation of Welding
Program
07/20/2006
01055847
Evaluate NRC IN- 2006-22; New Ultra-Low-
Sulfur Fuel Could Adversely Impact Diesel
Engine Performance
10/16/2006
01059041
Manage D5/D6 Enhancements Identified by
Root Cause
11/01/2006
01074017
Vendor Manual XH 52-32 is not up to date
01/26/2007
01082591
Xcel Energy Truck Struck a Tower in Prairie
Island Switchyard
03/16/2007
01088616
Operations Adverse Trend in Human
Performance
07/22/2009
01094238
D5 Engine 2 Elevated Crankcase Pressure
During Post Maintenance Testing
05/28/2007
01095381
D6 Crankcase Breather Imbalance
06/05/2007
01099211
2007 System Trending and Monitoring
Focused Self Assessment
12/16/2007
01106329
SOER 07-1 Reactivity Management
07/23/2009
01109480
EA (SBO) Components with incorrect quality
level
08/31/2007
01111011
MRE 01100534-02 incomplete
09/12/2007
01114156
Root Cause Evaluation; VHRA Key RCE
Inadequate
10/05/2007
01115585
Root Cause Report for D5 Inoperability
(Equipment Root Cause and Organizational
Root Cause)
10/22/2007
01118522
Significant OE Issues
03/12/2008
01070334
NRC Confirmatory Order EA-06-178
01/05/2007
01133384
Excel and NMC EE may not have SCWE
training
04/04/2008
01135591
Contractors not trained on policy on writing
04/24/2008
01119052;
Shackle came apart and hit Crane; Work Not
Stopped
11/26/2007
6
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
CR Number
Description or Title
Date or Revision
01121442
D5 Engine 1 Gen Bearing Vibration above
alarm set point
03/08/2008
01123680
D2 Diesel Generator Lube Oil Cooling Water
Side Leak
01/14/2008
01125087
Shortfalls in SOER 2007-01 Assessment
02/27/2008
01125903
TSC Normal Ventilation Performance
Challenged
02/01/2008
01126006
Vendor Info not included in Maintenance
Procedure
02/04/2008
01127120
MR Unavailability for 11 CL Pump 334.5 Hours
not documented in MR
02/13/2008
01127570
TSC Ventilation Temperature Control
Challenged
02/16/2008
01128432
Evaluate TSC Ventilation Function with
Damper Not Full Closed
02/23/2008
01128817
Adverse Trend in Outage Related Isolations
02/26/2008
01129236
During PM Motor Driven Aux Feedwater Pump
12 and 21 noted MSIP 1001 indicated oil is
Heavy Medium while D18 Lubrication specified
Mobil DTE Light
02/29/2008
01129421
TSC Lower Level HVAC Will Not Control
Temperature
03/01/2008
01129623
Control Room Alarm Diesel Room Vent System
Trouble coming in and out
03/03/2008
01129731
TSC Ventilation System Challenged
03/04/2008
01131494
Ineffective Corrective Actions for TSC
Ventilation
03/18/2008
01132293
Programmatic Issues Regarding TSC
Ventilation
03/25/2008
01132717
Root Cause Report for SI-9-5 Check Valve
Failure
06/30/2009
01132717
Apparent Cause Report for SI-9-5 Check Valve
Failure
05/09/2008
01135172
04/21/2008
01135817
121 MD CLP has a declining pump performance
trend
04/28/2008
01137253
Engineering CAP Backlog Reduction Effort
Needs Goal
05/09/0208
01140557
TSC System Could Not Maintain Required
Vacuum
06/11/2008
01141755
Root Cause Evaluation; Cross-Cutting Aspects
06/23/2008
01142664
Flexible Electrical Conduit Accidently Pinched
resulting in a Small Amount of Oil into the
Transfer Canal
06/30/2008
01143721
Training to comply with Confirmatory Order not
timely
07/10/2008
7
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
CR Number
Description or Title
Date or Revision
01144249
TSC Vent System Issues, Not Operating
Properly
07/15/2008
01146105
Deviation from EPRI guidelines
09/05/2008
01146374
Root Cause Evaluation; Hydrazine Event
Rev. 0
01147180
Secondary Chemistry does not meet EPRI
guidelines
09/16/2008
01147573
RPIP 3005 Procedure compliance issue
09/08/2008
01151789
10 CFR Part 21 Relays installed on D5 and D6
05/29/2009
01152814
Evaluate need for airborne hydrazine and
ammonia testing
10/07/2008
01157554
Hydrazine Concentration falls below spec in 21
11/01/2008
01160372
Root Cause Evaluation; Refuel Cavity Leakage
11/24/2008
01165133
Root Cause Evaluation; Cross-Cutting Themes
01/12/2009
01165257
MREP moved SSC from a(1) - a(2) w/o
revised a(1) Action Plan
01/13/2009
01166375
Production Planning DRUM identified potential
trend in schedule development accuracy for
both online and outage schedules
01/22/2009
01166830
Root Cause Evaluation; Corrective Action
Program
01/26/2009
01167124
Effectiveness Review Determined Corrective
Actions to Prevent Recurrence Were
Ineffective
01/28/2009
01167466
Adverse Trend Identified with Engineering CAP
Self Identification Problem Ratio
01/30/2009
01167806
D6, Engine 1 Crankcase Pressure High
02/02/2009
01169214
Unit 2 Turbine Building Crane Cracking
03/22/2009
01169490
D5 - Response to Monitoring Requirement
from CAP 1115585-11
02/15/2009
01171115
D5 Crankcase Pressure Exceeded 20 mm
Water
02/27/2009
01171319
Unit 2, D6 Engine 1 Crankcase Pressure High
03/01/2009
01173309
ABB Part 21 Notification Deviation
03/17/2009
01175335
Work Order 332186 Strainer Backwash
Replacement had not been through Planning
even though on workweek schedule.
03/27/2009
01175917
Potential Inadequate Resolution of SOER 02-
04 issues
03/31/2009
01176383
MR Unavailability Data Collection for July 2009
04/02/2009
01176851
April 2009 Documentation of Engine Crank
Case Pressure During Monthly Run
04/05/2009
01180912
RHR procedures are not adequate in Modes 3
and 4
05/05/2009
01181122
Cant Procedurally Swap HDT Pumps
8
Attachment
CORRECTIVE ACTION PROGRAM DOCUMENTS REVIEWED
CR Number
Description or Title
Date or Revision
01181967
U2 Condensate oxygen above EPRI diagnostic
parameter
07/08/2009
01181983
U2 Unplanned Secondary Action Level 1
05/26/2009
01183067
Ineffective Resolution of OE 15095
05/24/2009
01183142
Trend in ineffective Resolution of OE items
05/26/2009
01184607
Self Assessment Programmatic Weaknesses
06/05/2009
01184643
U2 Entered AL 1 for FW Hydrazine Less than
8X Cond O2
07/20/2009
01187837
Adverse Trend in Governing and Oversight of
PARB
10/30/2009
01190271
Revise to use the CAP process to review and
disposition vendor information
07/21/2009
01191042
Post Maintenance Testing for TSC Ventilation
System Did Not Meet Acceptance Criteria
07/27/2009
01191165
SP 1689 TSC Vent System Operability Test
Failed Acceptance Criteria
07/28/2009
01192415
Functionality Review for TSC Ventilation
System
08/06/2009
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
Nuclear Safety Culture Assessment
August 2009
NOS Observation
Report
Corrective Action Program
12/20/2007
NOS Observation
Report
Corrective Action Program
02/29/2008
NOS Observation
Report
Operating Experience and Self
Assessment
01/06/2009
NOS Observation
Report
CAP Assessment
02/29/2008
NOS Observation
Report
Security
09/02/2008
Nuclear Oversight
4th Quarter 2007 Assessment Report
02/08/2008
Nuclear Oversight
1st Quarter 2008 Assessment Report
05/23/2008
Nuclear Oversight
2nd Quarter 2008 Assessment Report
08/13/2008
Nuclear Oversight
3rd Quarter 2008 Assessment Report
11/14/2008
Nuclear Oversight
4th Quarter 2008 Assessment Report
02/20/2009
Nuclear Oversight
1st Quarter 2009 Assessment Report
06/03/2009
01088616
Snap Shot Report: Procedure Use and
Adherence
09/24/2008
01116150
Operations Training
10/26/2007
01121615
Radiation Program Annual Review
12/18/2007
01124352
Training DRUM
01/21/2008
01124941
HRA/LHRA/VHRA Controls
01/25/2008
9
Attachment
AUDITS, ASSESSMENTS AND SELF-ASSESSMENTS
Number
Description or Title
Date or Revision
01128817
Snapshot Report: Worker Protective
Tagging
06/15/2009
01129439
03/01/2008
01129444
03/01/2008
01129451
Focused Self-Assessment MOV - Motor
Operated Valve Program
08/22/2008
01129453
Focused Self-Assessment Fire
Protection Appendix R;
08/29/2008
01129453
Focused Self-Assessment TDAFW
95001 Inspection Preparation
06/05/2009
01129460
Outage Readiness
03/01/2008
01129463
Safety Culture
03/01/2008
01141307
Emergency Preparedness NEI Forum
06/18/2008
01143359
Training
07/07/2008
01146374
Hydrazine Issue
04/16/2009
01149046
08/29/2008
01118231
FTFSA-08-02
02/15/2008
01121596
Focused Self Assessment on 50.59
Program
12/18/2007
01129439
Emergency Preparedness Exercise
Inspection and Performance Indicator
Verification
09/22/2008
01141307
Informal Benchmarking of Emergency
Preparedness
01/19/2009
01155350
Snapshot Report: Security Training
10/07/2008
01158973
10/21/2008
01158973
Focused Self Assessment of Emergency
Preparedness
12/18/2008
01160507
Snapshot Report: Procedures and Work
Instructions
4/30/2009
01169735
Snapshot Report: Worker Protective
Tagging
07/02/2009
01174895
Training
03/25/2009
01174995
Radiation Protection / Chemistry
Organization
03/26/2009
01175030
Focused Self Assessment of Pre-NRC
Emergency Preparedness Routine
Inspection
06/08/2009
01175071
Focused Self Assessment on System
Trending and Monitoring
07/26/2007
01175930
03/31/2009
01185859
Snapshot Self Assessment on OE
06/17/2009
01189843
DRUM Security
07/17/2009
10
Attachment
MISCELLANEOUS
Number
Description or Title
Date or Revision
01192324
Procedure Change Request for SP 1689
08/04/2009
D86
Protection of Pre, Absolute, and Charcoal
Ventilation Filters from Contamination
Rev. 07
Equivalency Evaluation
Rev. 00
Equipment
Performance
Period Report U2C24
03/30/2009
Health and Status
Report
07/02/2009
Health and Status
Report
CT External Circulating Water
07/02/2009
Health and Status
Report
D5 Diesel Generator
07/02/2009
Health and Status
Report
4.16 kV Electrical
07/02/2009
Health and Status
Report
07/02/2009
Health and Status
Report
Reactor Protection
07/02/2009
Health and Status
Report
SA Station and Instrument Air
07/02/2009
Health and Status
Report
ZH Safeguards Chilled Water
07/02/2009
IN- 2006-22
New Ultra-Low-Sulfur Fuel Could
Adversely Impact Diesel Engine
Performance
10/12/2006
Maintenance Rule
a(1) Action Plan
Station Air
06/25/2009
Maintenance Rule
a(1) Action Plan
08/21/2008
Maintenance Rule
a(1) Action Plan
EA System 4,160 VAC
11/22/2007
Maintenance Rule
a(1) Action Plan
D5 Diesel Generator
04/21/2009
Maintenance Rule
a(1) Action Plan
RP System F delta Controller
02/10/2009
Maintenance Rule
a(1) Action Plan
Safeguards Chilled Water System 2H
04/16/2009
N/A
NOS Operating Experience Assessment
2008
SA037271
Operating Experience Program
2005
SWI GSE-27
Conduct of System Engineering
Rev. 08
TP 1689
TSC Ventilation System Operability Check
Rev. 17
11
Attachment
MISCELLANEOUS
Number
Description or Title
Date or Revision
Replace Variable Frequency
03/10/2008
Perform SP 1689 - TSC Ventilation
System Operability Check
01/28/2009
Perform SP 1689 - TSC Ventilation
System Operability Check
07/28/2009
Perform SP 1689 - TSC Ventilation
System Operability Check
07/8/2009
Perform SP 1689 - TSC Ventilation
System Operability Check
07/31/2009
Mark TSC Ventilation Damper Position
CAP Screen Team Meeting Package
08/04/2009
Leadership Alignment Meeting Package
08/04/2009
Management Review Meeting Package;
Rev.01
July 2009
Operator Burden List
08/04/2009
Prairie Island Top Ten Equipment Issue
List
Undated
Reactor Protection Health and Status
Report
07/02/2009
Station and Instrument Air Health and
Status Report
07/02/2009
Team Notes
03/10/2009
CAPs Written as a Result of the Inspection
Number
Description or Title
Date or Rev
1190255
Repeat Task Instruction Found in PMQR
07/21/2009
1190416
SAR 01141307 Did Not Contain Share
Point Attachment
07/22/2009
1190448
Initial NRC Submittal Incorrectly CT as MR
at (1)
07/22/2009
1190547
OE Program Requirements Not Followed
07/22/2009
1190598
B Level CAP 011882867 Has no ACE or
Deviation Listed
07/23/2009
1190625
NRC Feedback on AR Screening
Performance
07/23/2009
1191839
Updates to PMs Not Initiated for Vendor
Documents Change
07/31/2009
1192375
Perform PRA Review of Operator Work
Around
08/05/2009
1192387
Improper Place-keeping During SP 1689
TSC Vent Oper Check
08/05/2009
1192415
SP 1689 TSC Ventilation Operability Ck
Promotes Preconditioning
08/05/2009
12
Attachment
1192430
Safety Related Westinghouse HFB
Breakers Past 20 Year Life
08/05/2009
1192435
Need TCE for Swapping Heater Drain
Tank Pumps
08/05/2009
1192456
Improperly Set to Retire
08/06/2009
13
Attachment
LIST OF ACRONYMS USED
Alternating Current
Agencywide Document Access Management System
As-Low-As-Is-Reasonably-Achievable
CA
Corrective Action
CFR
Code of Federal Regulations
Direct Current
Diesel Generator
Division of Reactor Projects
Electric Power Research Institute
Final Safety Analysis Report
IMC
Inspection Manual Chapter
IP
Inspection Procedure
kV
Kilovolt
Limited Liability Corporation
Motor-Operated Valve
Non-Cited Violation
NEI
Nuclear Energy Institute
NOS
Nuclear Oversight
NRC
U.S. Nuclear Regulatory Commission
Publicly Available Records
Performance Indicator
Problem Identification and Resolution
Planned or Preventative Maintenance
Reactor Feed Pump
Radiation Protection
Radiation Protection Specialist
Station Blackout
Significance Determination Process
Systems, Structures, and Components