IR 05000282/2021011

Biennial Problem Identification and Resolution Inspection Report 05000282/2021011 and 05000306/2021011

ML21155A065
Person / Time
Site:	Prairie Island
Issue date:	06/03/2021
From:	Hironori Peterson Region 3 Branch 3
To:	Domingos C Northern States Power Company, Minnesota
References
IR 2021011
Download: ML21155A065 (16)

Text

June 3, 2021

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT - BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000282/2021011 AND 05000306/2021011

Dear Mr. Domingos:

On April 30, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed a problem identification and resolution inspection at your Prairie Island Nuclear Generating Plant and discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspection team reviewed the stations corrective action program and the stations implementation of the program to evaluate its effectiveness in identifying, prioritizing, evaluating, and correcting problems, and to confirm that the station was complying with NRC regulations and licensee standards for corrective action programs. Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

The team also evaluated the stations processes for use of industry and NRC operating experience information and the effectiveness of the stations audits and self-assessments.

Based on the samples reviewed, the team determined that your staffs performance in each of these areas adequately supported nuclear safety.

Finally, the team reviewed the stations programs to establish and maintain a safety-conscious work environment, and interviewed station personnel to evaluate the effectiveness of these programs. Based on the teams observations and the results of these interviews the team found no evidence of challenges to your organizations safety-conscious work environment. Your employees appeared willing to raise nuclear safety concerns through at least one of the several means available.

No findings or violations of more than minor significance were identified during this inspection. 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,

/RA/

Hironori Peterson, Chief Branch 3 Division of Reactor Projects Docket Nos. 05000282 and 05000306 License Nos. DPR-42 and DPR-60

Enclosure:

As stated

Inspection Report

Docket Numbers: 05000282 and 05000306 License Numbers: DPR-42 and DPR-60 Report Numbers: 05000282/2021011 and 05000306/2021011 Enterprise Identifier: I-2021-011-0037 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant Location: Welch, MN Inspection Dates: April 11, 2021 to April 30, 2021 Inspectors: A. Anderson, Physical Security Inspector B. Jose, Senior Reactor Inspector J. Park, Reactor Inspector K. Pusateri, Resident Inspector N. Shah, Project Engineer Approved By: Hironori Peterson, Chief Branch 3 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a biennial problem identification and resolution inspection at Prairie Island Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.

List of Findings and Violations

No findings or violations of more than minor significance were identified.

Additional Tracking Items

None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

Starting on March 20, 2020, in response to the National Emergency declared by the President of the United States on the public health risks of the Coronavirus Disease (COVID-19), regional inspectors were directed to begin telework. During this time regional baseline inspections were evaluated to determine if all or portions of the objectives and requirements stated in the IP could be performed remotely. In some cases, portions of an IP were completed remotely and on-site.

The inspection documented below was determined that the objectives and requirements stated in the IP could be completed remotely.

OTHER ACTIVITIES - BASELINE

71152B - Problem Identification and Resolution Biennial Team Inspection (IP Section 02.04)

(1) The inspectors performed a biennial assessment of the licensees corrective action program (CAP), use of operating experience, self-assessments and audits, and safety-conscious work environment.

• CAP Effectiveness: The inspectors assessed the CAPs effectiveness in identifying, prioritizing, evaluating, and correcting problems. The inspectors also conducted a five-year review of the Unit 1 and 2 emergency diesel generators (EDGs).

• Operating Experience, Self-Assessments and Audits: The inspectors assessed the effectiveness of the stations processes for use of operating experience, audits and self-assessments.

• Safety-Conscious Work Environment: The inspectors assessed the effectiveness of the stations programs to establish and maintain a safety-conscious work environment.

INSPECTION RESULTS

Assessment 71152B Review of Corrective Action Program Based on the samples reviewed, the team determined that the licensee's performance in each of these areas adequately supported nuclear safety.

Effectiveness of Problem Identification Overall, the station was effective at identifying issues at a low threshold and properly entering them into the CAP as required by station procedures. The team determined that the station was effective at identifying negative trends that could potentially impact nuclear safety. The inspectors interviewed personnel, reviewed documents, walked down portions of the plant, and assessed licensee problem identification.

The team identified that in January 2021, the licensee had missed an opportunity to identify a condition adverse to quality (CAQ) after several safety-related components were affected by ongoing leakage from the A cooling water supply strainers. Several issues were written (CAP items 501000048188, -46948, and -48109) documenting the leakage, but none addressed the wetting of nearby safety-related components. Ironically, barriers had been set up to prevent further wetting, even though no CAP item was written. After the inspectors raised this concern, CAP item 501000049622 was issued by the licensee to address the wetted equipment. The licensee determined that the affected equipment was operable and the inspectors identified no immediate safety concerns.

Effectiveness of Prioritization and Evaluation of Issues:

ln-depth reviews of a risk-informed sampling of CAP items, work orders (WOs), and cause evaluations were completed. Issue identification and screening was generally good, based on a review of CAP documents and observations of CAP screening, Protective Action Review Board, Plant Operating Review Committee and Plant Health Committee meetings. For these meetings, the inspectors observed that the meeting logistics (quorum, etc.) were enforced and that attendees were prepared and asked good questions. The inspectors observed that the issues were generally being appropriately prioritized and evaluated for resolution, and that the corrective actions (CAs) were implemented to mitigate the risk of issues occurring that could affect overall system operability and/or reliability.

The inspectors noted that while issue evaluations were generally sound, there were several examples where additional research was needed to understand the technical basis and final resolution, primarily due to a lack of clear documentation. This issue had previously been identified in past NRC inspections and licensee self-assessments, most recently in the April 2021 licensee self-assessment conducted in preparation for this inspection. The inspectors noted that the licensee had documented this issue in the CAP and was taking corrective actions.

The inspectors also identified several examples where CAP program requirements as stated in FP-PA-ARP-01, "CAP Process," had not been followed; however, these examples did not result in an inappropriate handling of CAQs or other significant CAP issue. These examples included:

• CAP item 50100023754, "Ground Resistors undersized for EDGs" had four recommendations which were not made into actions under the CAP nor was there any discussion on how they were being addressed. One of these recommendations was later cancelled based on the risk, even though this risk assessment was not documented. The licensee documented this issue as CAP item 501000050714;

• CAP item 500000303858, which was associated with root cause evaluation 501000035531, "Repetitive Corrosion Induced Failures, was to perform a Snapshot assessment; however, this assessment was not completed. The licensee documented this issue as CAP item 501000050482;

• Three CAs for CAP item 501000036932, which was associated with a root cause evaluation for an undersized beaker being installed on one of the EDGs, were inappropriately closed to actions taken, instead of remaining open until the actions were verified completed.

The licensee documented this issue as CAP item 501000050896; and

• CAP item 501000049074 D2 LO STRNR Leak; did not follow the administrative requirements of FP-OP-ACM-01 Adverse Condition Monitoring Plan Process to track an instance of Adverse Condition Monitoring (ACM). The licensee documented this issue as CAP item 501000051144.

As with the documentation issues previously discussed, the inspectors noted that this was also a continuing issue identified in April 2021, and earlier licensee self-assessments, for which CAs had been taken.

Effectiveness of Corrective Actions:

The team concluded that the licensee was generally effective in developing CAs that were appropriately focused to correct the identified problem and to address the root and contributing causes for significant issues in order to preclude repetition. The licensee generally completed CAs in a timely manner and in accordance with procedural requirements commensurate with the safety significance of the issue. For NRC identified issues, the team determined that the licensee generally assigned CAs that were effective and timely.

However, the inspectors noted that there was no clear basis for documenting the risk basis for due date extension. Attachment 8 of CAP procedure FP-PA-ARP-01, "CAP Process,"

required that "an assessment of the risk associated with extending the Activity," be documented as part of the due date extension; however, this procedure did not describe how this requirement should be met. The inspectors identified several examples where the risk assessment was lacking, in that it could not be determined how the assessor concluded that there was no risk. For example, CAP 501000023754 re: an issue with emergency diesel generator grounding resistors had "none" under the risk justification for the due date extension without any further detail. After additional information was provided by the engineering staff, the inspectors were subsequently able to conclude that the justification was supported. The inspectors were concerned with how management approval of the due dates was considered, absent a clearly documented risk basis, and how any future justifications could be properly evaluated, absent the previous documented risk assessment. Although the inspectors were able to determine that the risk assessment was appropriate for the items reviewed, this lack of documentation was a concern as discussed. The licensee documented this concern as CAP item 501000050871.

No violations or findings were identified.

Assessment 71152B The inspectors performed an expanded 5-year review of the Units 1 and 2 EDGs; specifically, by performing system walk-downs and evaluating condition reports, engineering changes, and WOs. Overall, the inspectors determined that the licensee was effectively managing issues associated with this system.

No violations or findings were identified.

Assessment 71152B The inspectors reviewed operating experience (OpE) captured in the CAP and sampled OpE from NRC, industry, vendors, and third-party groups. Overall, for the samples selected, the OpE was appropriately screened and evaluated for applicability, and was effectively used by the station. It was also noted that it was properly considered as a potential precursor in issue evaluations, and during interviews and observations of daily plant meetings, the inspectors concluded that it was seen as a useful learning tool and being used appropriately in daily plant activities.

Nuclear Oversight audits and department self-assessments were generally of good quality, thorough and critical with identified issues being properly dispositioned in the CAP. The audits and assessments were performed in accordance with licensee procedures. Of note, the inspectors observed that the overall conclusions of the licensees self-assessment of the CAP program done prior to this NRC inspection, was consistent with the inspectors observations.

No violations or findings were identified.

Assessment 71152B The inspectors observed various station meetings, including those in which new CAP items were reviewed, and interviewed a representative cross-section of station personnel.

Additionally, the inspectors interviewed the Employee Concerns Program Coordinator, reviewed recent case logs and case files and inquired about the program during interviews with station personnel.

Overall, there is a strong safety culture at the site. Workers felt encouraged to identify issues and felt encouraged to use the CAP. Generally, there was a feeling that issues would be evaluated and corrected. Generally, workers felt that that station management had taken reasonable measures to ensure that focus remained on safe operation and engagement, even given the circumstances due to COVID.

The licensee's 2020 USA safety culture survey identified a potential issue with Knowledge Transfer at the site affecting several departments, including maintenance and engineering.

This issue was captured in the CAP and several actions were underway to address this. The team did not have any issue with the actions proposed, but it is too early to assess their effectiveness.

No violations or findings were identified.

EXIT MEETINGS AND DEBRIEFS

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

• On April 30, 2021, the inspectors presented the biennial problem identification and resolution inspection results to you and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71152B Corrective Action 500000309985 Modify FP-S-FSIP-17: Security Program to Evaluate Need 12/23/2020

Documents for Additional Training Evolutions for Strategy Changes

500001184867 Adverse Trend in 11 Battery Jar/Cover Leakage 06/08/2009

500001192499 Nuclear Safety Advisory Letter RAOC Technical 08/06/2009

Specification Actions

500001227543 MS Snubbers Overloaded - Torsional Acceleration 04/16/2010

500001238619 12" MS Piping Added to High Energy Line 06/23/2010

500001494324 Potential Operable but Non-Conforming D5/D6 Fuel Oil 09/23/2015

Day Tank

500001553539 Issues with the Results Obtained for New Battery 03/30/2017

Calculations

5010000023859 Unit 1 EDG Unavailability Question 05/28/2019

501000007086 Main Steam Valve Maintenance Has AFW MSPI Impact 01/10/2018

501000007811 D2 Lockout During Slow Start Test 01/29/2018

501000011209 Battery 21 Has Misaligned Separator Plate 04/25/2018

501000012189 Identification of Latent OE Trend 05/20/2018

501000012293 Residual Heat Removal Flood Barriers Compensatory 12/03/2018

Measures

501000016536 Unacceptable Void Found in 2RH-11 02/04/2020

501000022183 Fuel Oil Leak on 2EG-9-53 Increased Rate 01/20/2019

501000022281 FW SYS Hanger Snubber Leaking 1-FWH-40B 01/23/2019

501000023141 EEQ DBAI; Motor Operated Valve (MOV) Grease Grading 03/07/2019

Criteria in Procedure D70.1

501000023875 2019 Problem Identification and Resolution Non-CAQ 03/20/2019

Items for Rescreening

501000023915 2019 NRC Ultimate Heat Sink Auxiliary Feedwater Room 03/06/2019

UC DP Testing

501000023925 ACE; 2019 NRC Ultimate Heat Sink (UHS) Inspection: 04/05/2019

Auxiliary Feedwater Room Cooler Heat Exchanger

Differential Pressure Testing

501000024755 Apparent Cause Evaluation (ACE); Breaker 221B-27 A 06/21/2019

Phase Will Not Close

Inspection Type Designation Description or Title Revision or

Procedure Date

501000025116 ACE; 121 Motor Driven Cooling Water Pump (MDCLP) as 05/30/2019

Found Condition - Motor Vibration High

501000025908 1Q2019 Violation - 12 DDCLP Jacket Water 04/19/2019

501000026390 CL Piping Vulnerability - MIC 04/26/2019

501000026633 11 FW Pump Outboard Oil Leak 05/01/2019

501000027914 Received Multiple Unexpected Alarms 05/29/2019

501000028820 NRC Inspector Observations WC System 06/21/2019

501000028971 Potential U1 RCS Flow Anomaly 05/25/2019

501000029823 CV-31209 Failed PMT 07/20/2019

501000030520 ACE; Potential Diaphragm Degraded on MV-32410 09/16/2019

501000031008 Missing Recommended Actions in LMP 08/21/2019

501000031076 ACE; 2019 AFI ER.1, Equipment Reliability - Emergency 10/15/2019

Diesel Generators (EDGs)

501000031220 Snubber PI-335 Failed As-Found Test 08/26/2019

501000031991 MOVs to Be Rescoped to GL Program 09/16/2019

501000033223 2MS-15-2 Bonnet Sealing Area Degraded 10/13/2019

501000033230 MSSV RS-21-18 Failed as Found Testing 10/12/2019

501000033699 SV-37465 Venting Continuously Post SI Test 10/22/2019

501000034170 SP 1151B Unsat, Stroke Time CV-31654 10/30/2019

501000034334 Fuel Oil Leak at 2EG-9-13 Valve Stem 01/11/2019

501000034334 D5 Fuel Oil Leak at 2EG-9-13 Valve Stem

501000035150 12 MD AFW Pump Did Not Start 11/26/2019

501000035213 Hole Found in 3" Fuel Oil Supply Line 12/02/2019

501000035531 Repetitive Corrosion Induced Failures 12/10/2019

501000036932 Breaker 26-16 Found Wrong Frame Size 01/24/2020

501000036932 Root Cause Evaluation (RCE); Breaker Removed from 01/24/2020

Bus 26, Cubicle 26-16 Was Found to Be a 1200 Ampere

Breaker Instead of 2000 Ampere

501000037118 CV-31654 Opening Outside of Reference 01/28/2020

501000037475 Cognitive Trend of MIC Comp Beyond RSL 02/07/2020

501000037993 22 CC PMP Outboard Bearing Oil Leak 02/22/2020

501000038254 2019 AF-2 Off Track 02/29/2021

501000038356 LR Fuel Oil Buried Pipe Inspection Challenge 03/04/2020

Inspection Type Designation Description or Title Revision or

Procedure Date

501000038616 Corrective Action Due Date Extension Not in Accordance 04/29/2020

with FP-PA-ARP-01

501000039650 22 CC HX Temp CV Failed to Control Temp 04/14/2020

501000039958 PMT UNSAT Due to Leak 04/23/2020

501000040752 5 DPM Water Drip from 11 TDAFWP CV Stem 05/16/2020

501000041444 Visible Degradation to Auxiliary Feedwater Piping 08/19/2020

501000041819 CV-39409 Stroked Outside the Limit 06/25/2020

501000041863 Ctrl Rod Lifetime Ext Assumptions 05/25/2020

501000041973 Roof Leak in 121 CR Chiller Room 06/30/2020

501000043602 U1 Flux Rate Reactor Trip 08/26/2020

501000043786 2020 Problem Identification and Resolution Focused Area 09/02/2020

Self-Assessment: A/B Corrective Action Extension

Review

501000044071 PI&R Focused Area Self-Assessment: Adverse Condition 09/11/2020

Monitoring Plan Trending

501000046312 Fire Extinguisher in D4 Room Degraded 11/03/2020

501000046590 ACE - Players Did Not Respond as Expected - Limited 11/19/2020

Scope Drill; Drill Performance

501000049074 D2 Lube Oil Strainer Leak 03/03/2021

501000049074 D2 Lube Oil Strainer Cover Leakage

501000050432 Security Zones 5 and 6 04/16/2021

501000050460 Security Force Member Annual Physical - Human 04/16/2021

Performance

501000050529 Critical CC Check Valves - No PMs 04/16/2021

50100022183 Prompt Operability for D6 Fuel Oil Leakage

50100023754 Ground/Resistors Undersized for Emergency Diesel 03/01/2019

Generators

50100031909 D5/D6 Fuel Sulfur Additive Nearly Depleted 09/16/2019

50100042597 NSCA General Observation Continuous Learning CL.4 07/24/2020

50130583 ACE; Fuse Blown During CV-31621 Work 09/17/2019

606000000560 10CFR50.65(a)(3) Periodic Assessment 04/01/2020

606000000952 Self-Assessment in Preparation for License Renewal 09/12/2019

Phase 4 Inspection

Inspection Type Designation Description or Title Revision or

Procedure Date

606000001078 Focused Self-Assessment: Problem Identification and 04/30/2021

Resolution at Prairie Island Nuclear Generating Plant

609000001541 Training Revision Request 06/11/2019

60EER1547051 IER L3-16-24 Emergency Diesel Generator

610000000498 ICES 437352 Diesel Generator Air Receiver

610000000632 Westinghouse TB-19-2 Control Rod Drive 05/02/2019

610000001185 OE IRIS 486479; Ultrasonic Inspection on Palisades 03/16/2021

Reactor Vessel Head

610000001211 Operating Experience; Applicability Review of License 03/03/2021

Renewal Interim Staff Guidance 2012-02

61000000691 452168 Diesel Oil Transfer Pump Breaker Failure 06/26/2019

6100000913 501000039063 Monticello Nuclear Generating Plant QIM 06/03/2020

Nuclear Oversight: Monticello Programs Audit Technical

Specifications

610000742 Winter Weather Readiness from NERC 09/05/2019

61000588881 Clearance and Tagging Inspection Report 09/30/2019

A-DES-PINGP-2020- Nuclear Oversight Audit on Design Control 04/24/2020

QA500000309575 Evaluate Alternate Breaching Simulations 04/15/2021

QA500000311461 Perform Evaluation on T3 IP 04/15/2021

QIM5010000046590 Players Did Not Respond as Expected During NRC FoF 11/19/2020

Exercise

QIM5010000049332 Human Performance Related Security Loggable Events - 03/09/2021

Perform Common Cause Evaluation

QIM5010000050392, Security Deep Dive on Protected Area Barriers 04/10-

393, 394 12/2021

QIM5010000050463 Security Camera Monitor Malfunction 04/16/2021

QIM5010000050466 AVBS Control Touch Screen 04/16/2021

QIM5010000050481 X-Ray Glass Chipped 04/16/2021

QIM5010000050490 COVID19 Disinfecting Wipes Causing Hand Geometry 04/14/2021

Errors

QIM5010000050498 Thermal Optic Broken Power Switch 04/14/2021

Corrective Action 501000050482 2021PIR: Action Not Performed as Written 04/13/2021

Inspection Type Designation Description or Title Revision or

Procedure Date

Documents 501000050714 CE 500000294364: Recommendations Not Addressed 04/20/2021

Resulting from 501000050871 PI&R Observation: Opportunity for Improvement 04/22/2021

Inspection 501000051144 Administrative Deficiency via FP-OP-ACM-01 04/27/2021

Engineering 601000001465 Prairie Island Security Upgrades - Change Request 04/15/2019

Changes Report

601000001947 Repair Fuel Oil Supply Line for 23 D5

60100001947 Repair Fuel Oil Supply Line for 23 D5 FO 12/02/2019

Miscellaneous Units 1 and 2 4th Quarter Mitigating Systems Performance December

Indicator AC Power Submittal 2020

Emergency Diesel Generator System Health Reports for 02/01/2021

D1, D2 and D5

Procedures FP-OP-OL-01 Operability Revision 22

FP-PA-ARP-01 CAP Process Revision 59

FP-PA-ARP-01 Issue Report/Change Request Form Revision 3

(QF0400)

FP-PA-OE-01 Operating Experience Program Revision 29

FP-PA-PAR-01 Performance Assessment Review Board and Performance Revision 18

Assessment Oversight

FP-PA-RMS-01 Risk Management Screening Revision 2

FP-S-FSIP-16 Security Training Revision 14

FP-STND-MTG. 01 Fleet Meeting Standards - Participation Revision 3

FP-WM-SCH-01 Online Scheduling Process Revisions 23

and 24

NSPM-1 Quality Assurance Topical Report Revision 14

Self- 500000305009 MM Elevation - Snapshot Assessment 04/14/2020

Assessments 500000306242 External Surfaces Corrosion SSA 02/24/2021

606000001079 INPO Mid-Cycle FSA Prairie Island 08/21/2020

60600000869 SNAPSHOT Report: Self-Assessment on 71130.04, 06/17/2020

Equipment Performance, Testing and Maintenance and

71151, Performance Indicator Verification

60600000906 SNAPSHOT Report: Self-Assessment on 71130.02, 01/20-

Access Control 24/2020

60600001360 SNAPSHOT Report: Self-Assessment on 71130.02, 03/29-

Inspection Type Designation Description or Title Revision or

Procedure Date

Access Control and 71151, Performance Indicator 04/11/2021

Verification

A-INSP/TEST- 2020 Nuclear Oversight Audit of PINGP Inspection and 06/01/2020

PINGP-2020-1 Testing

A-MAINT-PINGP- 2019 NOS Maintenance Audit 06/10/2019

2019-1

A-PROG-PINGP- 2019 Nuclear Oversight PINGP Audit of Programs 10/01/2019

2019-1

Nuclear Oversight 2019 NOS Audit of PINGP Security (#A-SEC-PING-2019- 07/15-

(NOS) Audit Report 1) 26/2019

Nuclear Oversight 2020 NOS Audit of Fleet Security and Cyber Security 07/13-

Audit (NOS) Report (A-SEC-FLT-2020-1) 31/2020

Work Orders 700036051 Replace D2 Monal Field Flash dP 01/12/2021

700036053 Replace D1 Shutdown Pushbutton 08/15/2018

13