ML22222A173
| ML22222A173 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 08/11/2022 |
| From: | Hironori Peterson Region 3 Branch 3 |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2022002 | |
| Download: ML22222A173 (21) | |
See also: IR 05000282/2022002
Text
Mr. Christopher P. Domingos
Site Vice President
Prairie Island Nuclear Generating Plant
Northern States Power Company, Minnesota
1717 Wakonade Drive East
Welch, MN 55089-9642
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT - INTEGRATED
INSPECTION REPORT 05000282/2022002 AND 05000306/2022002
Dear Mr. Domingos:
On June 30, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at
Prairie Island Nuclear Generating Plant. On July 22, 2022, the NRC inspectors discussed the
results of this inspection with you and other members of your staff. The results of this
inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding
involved a violation of NRC requirements. We are treating this violation as a non-cited violation
(NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this
inspection report, you should provide a response within 30 days of the date of this inspection
report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional
Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector
at Prairie Island Nuclear Generating Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a
response within 30 days of the date of this inspection report, with the basis for your
disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,
Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the
NRC Resident Inspector at Prairie Island Nuclear Generating Plant.
August 11, 2022
C. Domingos
2
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,
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
Docket Nos. 05000282 and 05000306
License Nos. DPR-42 and DPR-60
Enclosure:
As stated
cc w/ encl: Distribution via LISTSERV
Signed by Peterson, Hironori
on 08/11/22
SUNSI Review
Non-Sensitive
Sensitive
Publicly Available
Non-Publicly Available
OFFICE
RIII
RIII
NAME
NShah:sw
HPeterson
DATE
08/11/2022
08/11/2022
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
Inspection Report
Docket Numbers:
05000282 and 05000306
License Numbers:
Report Numbers:
05000282/2022002 and 05000306/2022002
Enterprise Identifier:
I-2022-002-0054
Licensee:
Northern States Power Company
Facility:
Prairie Island Nuclear Generating Plant
Location:
Welch, Minnesota
Inspection Dates:
April 01, 2022, to June 30, 2022
Inspectors:
S. Bell, Health Physicist
K. Pusateri, Resident Inspector
D. Tesar, Senior Resident Inspector
Approved By:
Hironori Peterson, Chief
Branch 3
Division of Reactor Projects
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees
performance by conducting an integrated inspection at Prairie Island Nuclear Generating Plant,
in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the
NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer
to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Complete Required Inservice Testing Prior to Restoring Equipment to Operation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000282,05000306/2022002-01
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a Green finding and associated non-cited violation of Title 10 of the
Code of Federal Regulations (10 CFR) Part 50.55a, "Codes and Standards" for the failure to
meet the inservice testing requirements set forth in the American Society of Mechanical
Engineers (ASME) Operations and Maintenance (O&M) Code and Addenda for failure to
complete required testing prior to returning equipment to operation following maintenance on
the 22 diesel driven cooling water pump (DDCLP).
Additional Tracking Items
None.
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PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in
effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with
their attached revision histories are located on the public website at http://www.nrc.gov/reading-
rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared
complete when the IP requirements most appropriate to the inspection activity were met
consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection
Program - Operations Phase. The inspectors performed activities described in IMC 2515,
Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of
IPs. The inspectors reviewed selected procedures and records, observed activities, and
interviewed personnel to assess licensee performance and compliance with Commission rules
and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated that flood protection barriers, mitigation plans, procedures,
and equipment are consistent with the licensees design requirements and risk
analysis assumptions for coping with external flooding on May 3, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1)
Unit 1 B train safety injection system on April 22, 2022
(2)
122 control room ventilation returned to service on May 26, 2022
(3)
instrument air system walkdown on May 26, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a
walkdown and performing a review to verify program compliance, equipment functionality,
material condition, and operational readiness of the following fire areas:
(1)
Fire Zone 43, bus 111 and 121 switchgear rooms on April 4, 2022
(2)
Fire Zone 19, Unit 1 auxiliary building, elevation 715' on April 7, 2022
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(3)
Fire Zone 26, bus 112 and train A event monitoring rooms, elevation 735' on
April 22, 2022
(4)
Fire Zone 96, transformer 2RX on May 3, 2022
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
(1)
Observed licensed operator requalification scenarios on May 3, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the
following planned and emergent work activities to ensure configuration changes and
appropriate work controls were addressed:
(1)
2RY transformer work on April 25, 2022
(2)
12 electro-hydraulic oil pump leak (potential Initiating Event) on May 2, 2022
(3)
Unit 2 turbine oil cooler 2CL-27-4 on April 25, 2022
(4)
SP 2857, "4kV Bus 21/22 Undervoltage and Underfrequency Relay Test (Omicron),"
on May 24, 2022
(5)
12 CFCU inoperability not MRFF on May 5, 2022
(6)
Work Week 2219 SI pump risk on May 10, 2022
(7)
CAP 501000063397 11, "Condensate Storage Tank Leaking," on May 27, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the
following operability determinations and functionality assessments:
(1)
SP 2284, "CV-31733 Closing Time Outside of REF," on April 13, 2022
(2)
AR 501000062700, "122 Control Room Air Handler," on May 2, 2022
(3)
12 CFCU unplanned inoperability on May 5, 2022
(4)
Work Order 700097233, "D5 Ruskin Damper Positioner Replacement," on
June 6, 2022
(5)
22 DDCLP comprehensive test not performed on April 5, 2022
(6)
D5 rack differential detector CAP 501000064219
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
5
(1)
122 safeguards traveling screen T-MOD on May 11, 2022
(2)
11 condensate storage tank leak repairs on May 27, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system
operability and/or functionality:
(1)
Post-maintenance testing (PMT) of MV-32033 on April 28, 2022
(2)
11 charging pump PMT on May 25, 2022
(3)
PMT of circuit breaker 112E-2 on June 1, 2022
(4)
WO 700097233, "D5 Ruskin Damper Positioner Replacement," on June 6, 2022
(5)
22 charging pump PMT on June 8, 2022
(6)
22 CC pump work window and PMT on June 29, 2022
(7)
SP 2089B, "RHR Pump and Suction Valve Quarterly Test," on June 20, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability
and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
(1)
SP 1110B, "Train B Cooling Water Header Isolation Valves Quarterly Test," on
April 28, 2022
(2)
SP 2334, "D5 Emergency Diesel Generator 24 Hour Load Test," on May 1, 2022
(3)
SP 2295, "D5 Diesel Generator 6-Month Fast Start Test," on May 1, 2022
(4)
SP 2088A, "21 SI Pump Quarterly Test," on May 10, 2022
(5)
SP 2307, "D6 DG 6 Month Fast Start Test," on May 23, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
(1)
SP 2857, "4kV Bus 21/22 Undervoltage and Underfrequency Relay Test (Omicron),"
on May 26, 2022
Containment Isolation Valve Testing (IP Section 03.01)
SP 2284, "RCDT Vent Header Containment Isolation Valves Quarterly Test," on
April 13, 2022
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RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Partial)
(1)
(Partial)
The inspectors evaluated how the licensee identifies the magnitude and extent of
alpha radiation levels and the concentrations and quantities of radioactive materials
and how the licensee assesses radiological hazards.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation
systems:
(1)
Radioactive waste building ventilation system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
(1)
Temporary HEPA ventilation system on the decontamination booth 695' auxiliary
building
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
(1)
The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
(1)
The inspectors evaluated the licensees use and maintenance of self-contained
breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated licensee performance as it pertains to radioactive source
term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
(1)
The inspectors evaluated how the licensee processes, stores, and uses external
dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
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(1)
Two internal dose assessments dated October 19, 2021
(2)
One internal dose assessment dated April 23, 2020
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
(1)
Declared pregnant worker records dated April 1, 2020
(2)
Declared pregnant worker records dated March 5, 2020
(3)
Declared pregnant worker records dated September 23, 2021
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
(1)
Turbine building sump effluent compositor and associated sampling lines
(2)
1R19 and 2R19 steam generator blowdown effluent monitors and sample lines
(3)
1R18 liquid waste discharge monitor and associated sample lines
(4)
Unit 1 auxiliary building ventilation system including the 1R30 and 1R37
effluent monitors
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
(1)
The inspectors evaluated environmental monitoring equipment and observed
collection of environmental samples (air samples, water samples and TLD locations).
OTHER ACTIVITIES - BASELINE
71151 - Performance Indicator Verification
The inspectors verified licensee performance indicators submittals listed below:
BI02: RCS Leak Rate Sample (IP Section 02.11) (1 Sample)
(1)
Unit 1 (April 1, 2021, through March 31, 2022)
Unit 2 (April 1, 2021, through March 31, 2022)
71152A - Annual Follow-up Problem Identification and Resolution
Annual Follow-up of Selected Issues (Section 03.03) (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issues:
(1)
The inspectors reviewed the completed corrective actions associated with voids in the
residual heat removal (RHR) system in the Mitigating Systems Cornerstone. The
8
inspectors determined if the corrective actions had been completed as documented in
the CAP.
71152S - Semiannual Trend Problem Identification and Resolution
Semiannual Trend Review (Section 03.02) (1 Sample)
(1)
The inspectors reviewed the licensees CAP for potential adverse trends in
Operability Determinations that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Failure to Complete Required Inservice Testing Prior to Restoring Equipment to Operation
Cornerstone
Significance
Cross-Cutting
Aspect
Report
Section
Mitigating
Systems
Green
NCV 05000282,05000306/2022002-01
Open/Closed
[H.14] -
Conservative
Bias
The inspectors identified a Green finding and associated non-cited violation of Title 10 of the
Code of Federal Regulations (10 CFR) Part 50.55a, "Codes and Standards" for the failure to
meet the inservice testing requirements set forth in the American Society of Mechanical
Engineers (ASME) Operations and Maintenance (O&M) Code and Addenda for failure to
complete required testing prior to returning equipment to operation following maintenance on
the 22 diesel driven cooling water pump (DDCLP).
Description:
On Saturday, March 26, 2022, the licensee performed routine maintenance on the
22 DDCLP. Upon completion of the maintenance, the licensee performed post maintenance
testing (PMT) as specified in the work order (WO) by completing the quarterly portion of
SP 1106B, "22 Diesel Cooling Water Pump Monthly Test," [performed at 9000 gpm] and
declared the 22 DDCLP as operable.
On Monday, March 28, 2022, the Inservice Testing (IST) Engineer initiated
CAP 501000061742, "Comp Not Performed After 22 DDCLP Maint," which identified the
following:
1) During the maintenance, the pump was uncoupled [diesel engine uncoupled from right
angle drive] as well as other minor maintenance activities.
2) Per the ASME OM Code Subsection ISTB-3310, "Effect of Pump Replacement, Repair,
and Maintenance on Reference Values," "When a reference value or set of values may have
been affected by repair, replacement, or routine servicing of a pump, a new reference value
or set of values shall be determined in accordance with ISTB-3300, or the previous value
reconfirmed by a comprehensive or Group A test run before declaring the pump operable."
3) IST [group] was also not given a review of the WO prior to maintenance.
Subsequently, station personnel reviewed the CAP initiated by the IST Engineer and made
the determination through their Operability process to return the DDCLP to operation based
upon the data obtained from the quarterly surveillance test performed as the PMT on
March 26, 2022.
9
The inspectors, on March 29, questioned whether it was appropriate to return the DDCLP to
service, given that there was a reasonable potential for the reference values to have changed
due to the maintenance performed. Therefore, the conservative action should have been to
verify the applicable reference values for the pump prior to returning it to service.
Title 10 CFR 50.55(a)(1)(iv) incorporates by reference the ASME Operation and Maintenance
Code (O&M Code). O&M Code subsection ISTB-3000 "General Testing Requirements,"
specifies the inservice testing requirements which are to be completed in accordance with
(IAW) Table ISTB-3000-1. The IST required data applicable to the 22 DDCLP per
Table ISTB-3000-1 are, differential pressure, flow rate, and vibration measurements.
ISTB-3540, "Vibration" - ISTB-3540(b) specifies further requirements in that, "Vibration
measurements shall be taken on the upper motor bearing housing in three approximately
orthogonal directions, one of which is the axial direction."
By letter L-PI-14-015 dated April 09, 2014, Prairie Island Nuclear Generating Plant (PINGP)
submitted Relief Request RR-03 seeking relief from code requirement ISTB-3540(b) which
required that vibration measurements be taken on the upper motor-bearing housing in three
approximately orthogonal directions, one of which must be in the axial direction. In lieu of this
code requirement, PINGP proposed as an alternative to take vibration measurements on the
right-angle drive in three orthogonal directions, one of which being in the axial direction, as
well as one additional vibration measurement to be taken on each of the diesel engines. The
NRC approved this relief request by response dated December 5, 2014 (ML14329A185).
As indicated in the CAP, ISTB-3310, "Effects of Pump Replacement, Repair, and
Maintenance on Reference Values," requires that:
ISTB-3312, "When a reference value or set of reference values may have been affected by
repair or routine maintenance, other than that covered under ISTB-3311, the following shall
be performed before declaring the pump operable:
(a) A group A or comprehensive test shall be performed and
(1) the previous reference values reconfirmed or
(2) a new reference value, or set of reference values, shall be determined in accordance
with ISTB-3300."
The Inspectors identified that because the diesel engine and right-angle drive were
uncoupled and re-coupled during the maintenance, and that each of these components are
locations for IST vibration data collection, that the potential existed that "a reference value or
set of reference values may have been affected" by the maintenance activity. One of the
purposes of performing the comprehensive test is to ensure that no unintended flaws or
consequences were introduced during the performance of the maintenance. Therefore, the
inspectors determined that the requirements of ISTB-3312(a)(1) (Subsection ISTB-3310)
would apply to this maintenance activity, and a comprehensive test was required to have
been performed prior to restoring the pump to operation.
In addition, licensee procedure H10.1 "ASME Inservice Testing Program" Section 5.6,
"Establishing a New Reference Value for Pump Testing", quotes ASME OM Code, ISTB-3310
"When a reference value or set of values may have been affected by repair, replacement, or
routine servicing of a pump, a new reference value or set of values shall be determined in
accordance with ISTB-3300, or the previous value reconfirmed by a comprehensive or Group
A test run before declaring the pump operable." Step 5.6.4 further requires that "The
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minimum USAR flow required for accident mitigation [10,400 gpm] shall be the limiting
acceptance criteria for operability. If the flow is less than the USAR requirement, then the
pump shall be declared inoperable, and the appropriate LCO condition entered."
Subsequently, on Wednesday March 31, 2022, the licensee took actions to perform the IST
comprehensive pump test per the applicable portions of SP 1106B, "22 Diesel Cooling Water
Pump Monthly Test." The results of this test indicated that the vibration data was like what
was seen prior to the maintenance.
Corrective Actions: CAP 501000061742, "Comp Not Performed After 22 DDCLP Maint"
Performance Assessment:
Performance Deficiency: The licensee's failure to perform inservice testing IAW regulatory
requirements in 10 CFR 50.55a, O&M Code Section 3310, and in accordance with their
prescribed procedure (H10.1, "Inservice Testing") prior to returning the equipment to
operation was a Performance Deficiency.
Screening: The inspectors determined the performance deficiency was more than minor
because it was associated with the Equipment Performance attribute of the Mitigating
Systems cornerstone and adversely affected the cornerstone objective to ensure the
availability, reliability, and capability of systems that respond to initiating events to prevent
undesirable consequences. The inspectors reviewed Inspection Manual Chapter 0612
App E, "Examples of Minor Issues", and determined that this issue was most closely related
to example 2.b. Specifically, the Licensee failed to complete the required in-service testing
prior to returning the equipment to operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609
Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The
violation was determined to be of very low safety significance and screened to Green
because inspectors answered all screening questions as "no". Although the DDCLP was
inoperable based on failure to perform the comprehensive inservice testing, the subsequent
performance of the test resulted in pump data like pre-maintenance and therefore the risk
associated with pump operation and functionality resulted in very low risk. This was also in
part due to crediting the 121-motor driven cooling water pump as being available from a
Probabilistic Risk Analysis perspective.
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices
that emphasize prudent choices over those that are simply allowable. A proposed action is
determined to be safe to proceed, rather than unsafe in order to stop. The licensee failed to
use conservative decision-making following initiation of a CAP which identified that the O&M
Code required performance of the comprehensive test prior to restoring the equipment to
operable status. The licensee only performed the quarterly surveillance test to return the
pump to operation. Following the CAP initiation, the licensee incorrectly declared the
equipment operable and considered it available to perform its specified safety function.
Enforcement:
Violation: Title 10 CFR 50.55(a)(1)(iv) requires, in part, "When a reference value or set of
values may have been affected by repair, replacement, or routine servicing of a pump, a new
reference value or set of values shall be determined in accordance with ISTB-3300, or the
previous value reconfirmed by a comprehensive or Group A test run before declaring the
11
pump operable."
Contrary to the above, on March 28, 2022, the licensee returned the 22 DDCLP to operation
following maintenance without completing the comprehensive pump test run.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with
Section 2.3.2 of the Enforcement Policy.
Observation: Annual Review of Residual Heat Removal Voids Found After 2R32
Refueling Outage
Inspectors selected Unit 2 residual heat removal (RHR) voiding long term actions for this
annual follow-up sample to evaluate the timely disposition of this operability issue and ensure
that corrective actions are commensurate with the safety significance. Inspectors reviewed
the corrective action program (CAP) documents associated with a series of voids found
following the 2R32 refueling outage. The significance of the voids was that in some cases
the size of particular voids found exceeded the operability limits listed in procedure H64, Gas
Accumulation Management Program. The licensee was able to perform Operability
Evaluations to determine that the voids were acceptable to maintain reasonable assurance
of Operability.
The licensee determined this potential gaseous intrusion mechanism was related to chemical
additions to the RHR system while it was aligned in Shutdown Cooling Mode.
The licensee created actions in the CAP to revise procedures to minimize the amount of gas
left in the system following Shutdown Cooling Mode. The licensee created corrective actions
to perform more void inspections during subsequent outages and to have engineering ensure
both RHR pumps operate prior to plant heat-up after an outage.
Inspectors noted that corrective actions associated with changing the fill and vent procedures
following an outage were closed to the procedure change requests (PCRs) but then those
PCRs were subsequently cancelled. The licensee as part of their normal review process,
plans to review the PCRs and add justification for the cancellation.
Since all actions are not completed and the licensee has not gone through another refueling
outage, the inspectors cannot yet assess the adequacy and effectiveness of all the corrective
actions.
The licensee-initiated CAP 501000064413 which created a tracking action for completion of
the PCRs. The CAP has not been closed by the licensee so there is an opportunity to assess
the effectiveness of all the corrective actions prior to the next RFO and CAP closure.
No findings or violations were identified during the review.
Observation: Trend Review of ASME O&M Code Compliance
Inspectors reviewed Operability determinations associated with ASME Code compliance for
trending. Two examples were identified for evaluation as follows:
On October 27, 2021, CAP 501000057742, "SP 2269 Performed UNSAT," was initiated by
the licensee to document the failure of 2SI-6-4 to pass its in-service testing acceptance
criteria. The station performed an Operability Determination (CAP 501000057644,
12
500000316013) and concluded that "Valve 2SI-6-4 is not fully qualified. This is due to not
meeting the leakage criteria established per the IST Code. This condition does not affect the
ability of 2SI-6-4 to perform its specified safety functions...," the licensee concluded that
On October 28, 2021, CAP 501000057820, "Operability Process and Regulatory
Requirements," was initiated by the licensee (and related to CAP 501000057742) to
document in part, that the fleet procedure FP-OP-OL-01 for Operability was updated to
incorporate guidance from NEI 18-03, "Operability Determination." The guidance was not
endorsed by the NRC. The CAP also documented that "the regulatory aspect of how
compliance with 10 CFR 50.55a is maintained still needs to be addressed."
As documented in Inspection Report 2021-004, the NRC identified "... a green finding and
associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR)
Part 50.55a(f)(4) for the failure to meet the in-service testing requirements set forth in the
American Society of Mechanical Engineers (ASME) Operations and Maintenance Code and
Addenda after Check Valve 2SI-6-4 exceeded its ASME Code leakage acceptance criteria..."
On March 28, 2022, CAP 501000061742, "Comp Not Performed After 22 DDCLP
Maintenance," was initiated to document the failure to perform the comprehensive test on the
22 diesel driven cooling water pump (DDCLP) following maintenance in accordance with the
ASME operation and maintenance (O&M) Code requirements.
As documented in this inspection report (2022-002), the NRC identified "... a green finding
and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR)
Part 50.55a, "Codes and Standards" for the failure to meet the in-service testing requirements
set forth in the American Society of Mechanical Engineers (ASME) Operations and
Maintenance (O&M) Code and Addenda for failure to complete required testing prior to
returning equipment to operation following maintenance on the 22 diesel driven cooling water
pump (DDCLP)."
On June 20, 2022, CAP 501000064047, "2SI-6-4 and FP-OP-OL-01," was initiated. This
CAP identified that during the 2022 in-service testing focused self-assessment, "It was
identified that there is currently no procedure guidance in FP-OP-OL-01 or other actions in
place to prevent recurrence." (Allowing the plant to move forward in power ascension without
The inspectors reviewed the above issues and identified differences in the Xcel Energy Fleet
Procedure FP-OP-OL-01, "Operability" and NRC Inspection Manual Chapter 0326
"Operability Determinations" with respect to code compliance and operability. Subsequently,
the Licensee initiated fleet CAP 501000065231, "NRC insight on IMC-0326 v FP-OP-OL-01."
Inspectors reviewed the CAPs and actions listed above and determined that at the time of
review, there were no actions in place to address the differences between licensee
procedures, NRC Inspection Manuals, and compliance with 10 CFR 50.55a Code
Requirements. CAP 501000057820 had an action to provide training which was documented
as complete in January of 2022; however, this action does not appear to have been effective
based upon the events which occurred on March 28, 2022. CAP 501000064047 was initiated
after the inspectors had started their trend review, and this CAP does capture the
observations of the inspectors. Actions being implemented in this CAP may resolve the
identified gaps, however, since the actions had not yet been created, inspectors were unable
to assess their overall adequacy.
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No new findings or violations were identified during this trend review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 22, 2022, the inspectors presented the integrated inspection results to
Mr. C. Domingos, Site Vice President, and other members of the licensee staff.
On June 22, 2022, the inspectors presented the radiation protection baseline inspection
results to Mr. S. Skoyen, Acting Plant Manager, and other members of the licensee staff.
14
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
CY-ENVR-003
Three Day Flood Forecast Reporting
6
Procedures
SP 1293
Inspection of Flood Control Measures
27
Work Orders
0010
SP 1293 Annual Inspection of Flood Contr
06/02/2022
Calculations
M-385-FP-001
Analysis of Record and Engineering Calculations for Cardox
Piping Equivalent Length
2
Drawings
NF-39244
Flow Diagram Instrument Air Piping Unit 1 & 2
98
Procedures
C1.1.35-3
Checklist for Cooling Water System
45
F5 Appendix A
Fire Detection Zone 26, Bus 112 & Train A Event Monitoring
Rooms El. 735'
46
F5 Appendix A
Fire Detection Zone 43
46
F5 Appendix A
Fire Detection Zone 19
46
Fire Plans
F5 Appendix A
Fire Detection Zone 96 Transformer 2RX
46
NFPA No. 12-
1972
Standard of Carbon Dioxide Extinguishing Systems
1972
Miscellaneous
QF0739, NRC
Question
Response, CAP
501000063724
Pertaining to ENG-ME-804 CO2, Concentration in the Relay
and Cable Spreading Room Attachment 10.1 Retrotec Final
Report Cardox Validation Project
0
Engineering
Changes
EC
601000003804
11 CST: Temp Clamp for Thru-Wall Leak
0
Procedures
SP 2857
4KYV Bus 21/22 Undervoltage and Underfrequency Relay
West (Omicron)
1
Work Orders
0010
Replace O-Rings/Seals on Flex Hose Fittings
05/01/2022
Calibration
Records
ENG-ME-804
CO2 Concentration in the Relay Room and Cable Spreading
Room
0
Corrective Action
Documents
501000061742
Comp not Performed after 22 DDCLP Maint
03/29/2022
Engineering
Changes
EC
602000018704
Revise SP 1091 Monthly Containment Fan Coils Units
Surveillance Test
05/06/2022
Miscellaneous
API Standard 650
Welded Steel Tanks for Oil Storage
September
15
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2003
API Standard 653
Tank Inspection, Repair, Alternation, and Reconstruction
September
2003
C1.1.19-4
Containment and Shield Building Penetration Checklist - Unit
2
53
H10.1
ASME Inservice Testing Program
42
H10.1.B
Inservice Testing Program Component Basis Document
6
ASME Code Case OMN-16 - Use of a Pump Curve for
Testing
2
QF0739, NRC
Question
Response Form
06/02/2022
Operability
Evaluations
CV-31733 / SP
2284 / WO 700099357
IST 96 Hour Evaluation
04/13/2022
FP-OP-OL-01
Operability
22
SP 2284
RCDT Vent Header Containment Isolation Valves Quarterly
Test
20
Procedures
TP 1806
122 Control Room Chiller Inspection
18
Drawing NF-
39220
Flow Diagram Condensate System Unit 1
82
Drawings
Drawing XH-74-
56
General Plan 30-29 High Dome Roof
76
GMP GREE-001
CVCS Suction Stabilizer Maintenance
6
GMP SULL-001
SULLAIR Station Air Compressor 1000 Hour Preventative
Maintenance
9
Procedures
PE MCC-G7
MCC Electrical Preventive Maintenance for GE 7700 Line
MCCS
44
PE-121C-16 BKR PM, 2TB LP B CL HDR MV-320
04/28/2022
245-042 SPD Reducer Oil Chang Smpl
06/08/2022
22 CHG PMP CVCS SUCT STABLZR MAINT
03/19/2022
PMT 125 STA AIR COMPR 1000 HR PM
05/25/2022
GMP SULL-001-125 STA AIR CMPR 1000 HR PM
05/28/2022
Work Orders
MD-32421 Insp. and Adjust Ruskin SR MD
05/28/2022
16
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
21 D5 DSL RM OA (MD-32420) RPLC POSNR
06/07/2022
MD-32422 Insp & Adjust Ruskin SR M
06/16/2022
MD-32422 Insp &n Adjust Ruskin SR M
06/16/2022
SP 1110B
Train B Turbine Cooling Water Header Isolation Valves
Quarterly Test
7
SP 2088A
Train A Safety Injection Quarterly Test
37
SP 2284
RCDT Vent Header Containment Isolation Valves Quarterly
Test
20
SP 2295
D5 Diesel Generator 6 Month Fast Start Test
57
SP 2307
D6 Diesel Generator 6 Month Fast Start Test
51
SP 2334
D5 Diesel Generator 24 Hour Load Test
24
Procedures
SP 2857
4kV Bus 21/22 Undervoltage and Underfrequency Relay
Test (Omicron)
1
SP2334 - D5 DG 24 Hour Load Test
03/04/2022
SP 111OB TRN B CL HDR ISOL VLVS TEST
04/28/2022
SP 2857 Bus 21/22 Undervolt Omicron
05/23/2022
SP2295 D5 DG 6MO Fast Start Test
05/01/2022
SP2284 RCDT VENT HDR CTMT ISOL VLVS QTR
04/12/2022
SP 2284 RCDT Vent HDR CTMT Isolation Valves Qtr
03/23/2022
Work Orders
SP2307 D6 DG Fast Start Test
05/23/2022
Corrective Action
Documents
Resulting from
Inspection
501000062752
Alpha Analysis
05/03/2022
Engineering
Evaluations
Prairie Island Plant Alpha Characterization Study
11/26/2021
Radiation
Surveys
2R32 Refueling Outage Radiation Surveys
Various
ALARA Plans
2R32 Refuel Work Radiation Protection Job Plan
09/28/2021
Four Quantitative Respirator Mask Fit Tests
05/02/2022
Miscellaneous
Respiratory Protection Qualification Records for Day Shift
Reactor Operators and Senior Reactor Operators for May 4,
2022.
Various
17
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Annual SCBA Tests for units LAD090896 and LAD090890
07/13/2021
43525-0
Breathing Air Tests December 2021
12/09/2021
Miscellaneous
4433895-0 and
433653-1
Breathing Air Checks for November 2021
11/15/2021
FP-RP-RPP-02
Respirator Fit Testing and Portacount Fit Tester Operation
1
Procedures
RPIP 1604
Breathing Air Test
17
Self-Assessments
Undated
Work Orders
7000680170020
12 Shield Building Ventilation Filter Removal Efficiency Test
08/18/2020
501000047700
Improper Area TLD Changeout
01/23/2021
Corrective Action
Documents
501000050416
Dose Discrepancies for Period 2, 2020
04/16/2021
17-005
Technical Basis Document Passive Monitoring Capability
Testing
11/05/2019
606000001052
2019 Prairie Island Isotopic Mix Evaluation
Undated
Engineering
Evaluations
606000001454
2021 Prairie Island Isotopic Mix Evaluation
Undated
Three Declared Pregnant Worker Records
Various
2021 Annual Area TLD Trending
02/21/2022
Period 2 (July - December) 2021 Dosimetry Data
Undated
Mirion Technologies Inc., Oak Ridge TN, NVLAP
Accreditation for 07/01/2021 through 06/30/2022
Miscellaneous
Period 2 (July through December 2021). 2021 Dose
Discrepancy Reports
Various
FP-RP-DR-01
Dosimetry Program
15
Procedures
FP-RP-IDA-01
Internal Dose Assessment
4
Radiation Work
Permits (RWPs)
220059
Dose Restricted Individuals
0
H4
Offsite Dose Calculation Manual
32
Procedures
RPIP 4721
REMP Air Sampling
22
Miscellaneous
602000018696
Adverse Condition Monitoring Plan for Unit 2 RHR Discharge
Voids
01/06/2022
18
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Operability
Evaluations
50100000316297
Prompt Operability Determination for Unit 2 Train A RHR
Piping
0