IR 05000282/2018001: Difference between revisions
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| number = ML18129A181 | | number = ML18129A181 | ||
| issue date = 05/09/2018 | | issue date = 05/09/2018 | ||
| title = | | title = NRC Integrated Inspection Report 05000282/2018001 and 05000306/2018001 | ||
| author name = Riemer K | | author name = Riemer K | ||
| author affiliation = NRC/RGN-III/DRP/B2 | | author affiliation = NRC/RGN-III/DRP/B2 | ||
| addressee name = Sharp S | | addressee name = Sharp S | ||
Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION May 9, 2018 | ||
==SUBJECT:== | |||
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2NRC INTEGRATED INSPECTION REPORT 05000282/2018001 AND 05000306/2018001 | |||
==Dear Mr. Sharp:== | |||
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Prairie Island Nuclear Generating Plant, Units 1 and 2. On April 12, 2018, 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. | |||
Based on the results of this inspection, the NRC inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy. | |||
If you contest the violation or significance of the NCV, 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 the Prairie Island Nuclear Generating Plant. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding. | |||
Sincerely, | |||
/RA/ | |||
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects/Safety Docket Nos. 50-282; 50-306; 72-010 License Nos. DPR-42; DPR-60; SNM-2506 Enclosure: | |||
IR 05000282/2018001; 05000306/2018001 cc: Distribution via LISTSERV | |||
/ | =SUMMARY= | ||
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensee performance by conducting an integrated quarterly inspection at Prairie Island Nuclear Generating Plant, Units 1 and 2 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. Additional tracking items are summarized in the table below. One Licensee-identified NCV and one minor violation are documented in report section 71153. | |||
List of Findings and Violations None. | |||
- | Additional Tracking Items Type Issue Number Title Report Status Section LER 05000306/2017002-00 Reactor Coolant System 71153 Closed Shutdown Communication Live Vent Through Wall Defect LER 05000306/2017003-00 Both Containment Spray 71153 Closed Pump Control Switches in Pull-Out in Mode 4 LER 05000282/2018001-00 121 Motor Driven Cooling 71153 Closed Water Pump Auto Start due to Smoking Packing on 11 Cooling Water Pump URI 05000282/2017008-01 Questions Regarding the 71111.17T Closed Manual Override of the Automatic-Closure Function of Component Cooling System Valves URI 05000306/2018001-01 Questions Regarding 71111.15 Open Corrective Action Program, | ||
Use of Operating Experience, and Qualification of the 21 125 VDC Battery due to Cell Lid Cracking URI 05000282/2018001-02 Questions Regarding the 71111.18 Open Corrective Action and Aging Management Programs Following the Discovery of 122 Diesel Driven Cooling Water (DDCL) Pump Fuel Oil Storage Tank (FOST) Vent Piping Degradation | |||
TABLE OF CONTENTS | |||
=PLANT STATUS= | |||
** | ==INSPECTION SCOPES== | ||
* | ............................................................................................................ | ||
==REACTOR SAFETY== | |||
.................................................................................................................. | |||
==RADIATION SAFETY== | |||
................................................................................................................ | |||
==OTHER ACTIVITIES== | |||
BASELINE | |||
==INSPECTION RESULTS== | |||
.......................................................................................................... | |||
==EXIT MEETINGS AND DEBRIEFS== | |||
........................................................................................ 13 THIRD PARTY REVIEWS ...................................................................................................... 14 | |||
=DOCUMENTS REVIEWED= | |||
..................................................................................................... 14 | |||
PLANT STATUS | |||
Units 1 and 2 operated at full power for the entirety of the inspection period, with the exception | |||
of brief down-power maneuvers to accomplish planned surveillance testing or troubleshooting | |||
activities. | |||
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 plant status activities described in | |||
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem | |||
Identification and Resolution. 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 | |||
71111.01Adverse Weather Protection | |||
Impending Severe Weather (1 Sample) | |||
The inspectors evaluated readiness for impending adverse weather conditions for Cold | |||
Weather on January 4, 2018 (D5 and D6 emergency diesel generator (EDG) building). | |||
71111.04Equipment Alignment | |||
Partial Walkdown (3 Samples) | |||
The inspectors evaluated system configurations during partial walkdowns of the following | |||
systems/trains: | |||
(1) 21 cooling water (CL) system during the week of January 8, 2018; | |||
(2) 12 and 22 DDCL ventilation system on January 19, 2018; and | |||
(3) Offsite power sources with 345 kV Bus 2 out of service during the week of | |||
March 5, 2018. | |||
Complete Walkdown (1 Sample) | |||
The inspectors evaluated system configurations during a complete walkdown of the Unit 2 | |||
safety injection system during the weeks of January 22 and 29, 2018. | |||
71111.05AQFire Protection Annual/Quarterly | |||
Quarterly Inspection (4 Samples) | |||
The inspectors evaluated fire protection program implementation in the following selected | |||
areas: | |||
(1) Fire Area 41A, Screenhouse, Elevation 695; | |||
(2) Fire Area 18, Relay and Cable Spreading Room, Elevation 715; | |||
(3) Fire Detection Zone 11, Fire Areas 20 & 81; Bus 15 & 16 Switchgear Rooms, | |||
Elevation 715; and | |||
(4) Fire Zone 97, D5/D6 EDG Building. | |||
71111.06Flood Protection Measures | |||
Internal Flooding (1 Sample) | |||
The inspectors evaluated internal flooding mitigation protections in the Unit 1 containment | |||
spray pump room during the week of February 5, 2018. | |||
71111.11QLicensed Operator Requalification Program and Licensed Operator Performance | |||
Operator Performance (1 Sample) | |||
The inspectors observed and evaluated a Unit 1 reduction in power to approximately 40 percent | |||
for main turbine testing and main condenser inspections during the week of March 12, 2018. | |||
Operator Requalification (1 Sample) | |||
The inspectors observed and evaluated simulator requalification training on March 16, 2018. | |||
71111.12Maintenance Effectiveness | |||
Routine Maintenance Effectiveness (2 Samples) | |||
The inspectors evaluated the effectiveness of routine maintenance activities associated | |||
with the following equipment and/or safety significant functions: | |||
(1) Unit 1 and 2 4.16kV AC electrical systems; and | |||
(2) Unit 2 component cooling water system. | |||
71111.13Maintenance Risk Assessments and Emergent Work Control (4 Samples) | |||
The inspectors evaluated the risk assessments for the following planned and emergent | |||
work activities: | |||
(1) D2 EDG exciter pushbutton failure, lockout, and troubleshooting activities on | |||
January 29, 2018; | |||
(2) Unit 2 containment sump A in-leakage on February 20, 2018; | |||
(3) D6 EDG return to service issues during the week of February 26, 2018; and | |||
(4) Work week 1811 unplanned Technical Specification (TS) Limiting Conditions for | |||
Operation (LCOs) (screenhouse safeguards exhaust fan & Bus 122 room cooling fan | |||
motors) during the week of March 19, 2018. | |||
71111.15Operability Determinations and Functionality Assessments (5 Samples) | |||
The inspectors evaluated operability determinations for the following action requests | |||
(ARs): | |||
(1) AR 501000004740; 121S and 122N Relay Room Motor Amp Past Operability Evaluation | |||
on January 2, 2018; | |||
(2) AR 501000009553; NRC Question On 21 Battery Lids on February 20, 2018; | |||
(3) AR 501000008489; Relay 1X32215 Contacts Sticky on February 21, 2018; | |||
(4) AR 501000007896; Safeguard Strainer Room Screenhouse Seismic Evaluation on | |||
February 26, 2018; and | |||
(5) AR 501000009528; D1 Turbocharger Outlet Bellows Leak on March 21, 2018. | |||
71111.17TEvaluations of Changes, Tests and Experiments (No Sample) | |||
The inspectors performed a review of Unresolved Item (URI) 5000282/2017008-01, | |||
Questions Regarding the Manual Override of the Automatic-Closure Function of | |||
Component Cooling System Valves. This review did not constitute an inspection sample. | |||
71111.18Plant Modifications (1 Sample) | |||
The inspectors evaluated a permanent modification associated with: | |||
(1) AR 501000005894; Hole in 122 DDCL Pump Oil Storage Tank Vent. | |||
71111.19Post Maintenance Testing (5 Samples) | |||
The inspectors evaluated the following post maintenance tests: | |||
(1) 22 steam generator steam flow and level indication circuit card replacement on | |||
January 22, 2018; | |||
(2) 122N relay room and B event monitoring room unit cooler motor replacement on | |||
January 31, 2018; | |||
(3) Testing of D2 EDG following exciter stop pushbutton replacement on February 1, 2018; | |||
(4) Testing of MV-32129, 22 residual heat removal component cooling water inlet valve on | |||
January 31, 2018; and | |||
(5) Bus 122 room cooler fan motor replacement on March 21, 2018. | |||
71111.22Surveillance Testing | |||
The inspectors evaluated the following surveillance tests: | |||
Routine (2 Samples) | |||
(1) SP 2116; Unit 1 Monthly Power Distribution Map Surveillance Test on January 23, 2018; | |||
and | |||
(2) SP 1073A; Unit 1 Train A Shield Building Ventilation System on February 6, 2018. | |||
In-service (1 Sample) | |||
(1) 22 DDCL Pump Monthly SP on March 23, 2018. | |||
71114.06Drill Evaluation | |||
Drill/Training Evolution (1 Sample) | |||
On January 25, 2018, the inspectors evaluated a simulator training session with Drill & | |||
Exercise Performance (DEP) opportunities. | |||
RADIATION SAFETY | |||
71124.03In-Plant Airborne Radioactivity Control and Mitigation | |||
Engineering Controls (1 Sample) | |||
The inspectors evaluated airborne controls and monitoring. | |||
Use of Respiratory Protection Devices (1 Sample) | |||
The inspectors evaluated respiratory protection. | |||
71124.04Occupational Dose Assessment | |||
Source Term Characterization (1 Sample) | |||
The inspectors evaluated the licensees source term characterization. | |||
External Dosimetry (1 Sample) | |||
The inspectors evaluated the licensees external dosimetry program. | |||
Internal Dosimetry (1 Sample) | |||
The inspectors evaluated the licensees internal dosimetry program. | |||
Special Dosimetric Situations (1 Sample) | |||
The inspectors evaluated the licensees performance for special dosimetric situations. | |||
OTHER ACTIVITIESBASELINE | |||
71151Performance Indicator Verification (8 Samples) | |||
The inspectors verified licensee performance indicators submittals listed below: | |||
(1) IE01: Unplanned Scrams per 7000 Critical Hours-2 Samples (01/01/2017-12/31/2017); | |||
(2) IE03: Unplanned Power Changes per 7000 Critical Hours-2 Samples (01/01/2017- | |||
2/31/2017); | |||
(3) IE04: Unplanned Scrams with Complications (USwC)-2 Samples (01/01/2017- | |||
2/31/2017); and | |||
(4) MS05: Safety System Functional Failures (SSFFs)-2 Samples (01/01/2017- | |||
2/31/2017). | |||
71152AProblem Identification and Resolution | |||
Annual Follow-Up of Selected Issues (1 Sample) | |||
The inspectors reviewed the licensees implementation of its corrective action program | |||
related to the following issue: | |||
(1) Apparent Cause Evaluation 500000283593; Adverse Trend in Technical Rigor. | |||
71153Follow-Up of Events and Notices of Enforcement Discretion Events | |||
Licensee Event Reports (3 Samples) | |||
The inspectors evaluated the following licensee event reports which can be accessed at | |||
https://lersearch.inl.gov/LERSearchCriteria.aspx: | |||
(1) Licensee Event Report (LER) 5000306/2017002-00: Reactor Coolant System | |||
Shutdown Communication Live Vent Through Wall Defect; | |||
(2) LER 5000306/2017003-00: Both Containment Spray Pump Control Switches in Pull-out | |||
in Mode 4; and | |||
(3) LER 5000282/2018001-00: 121 Motor Driven Cooling Water Pump Auto Start due to | |||
Smoking Packing on 11 Cooling Water Pump. | |||
INSPECTION RESULTS | |||
71111.15Operability Determinations and Functionality Assessments | |||
Unresolved Item Questions Regarding Corrective Action 71111.15 | |||
(Open) Program, Use of Operating Experience, and Operability | |||
Qualification of the 21 125 VDC Battery due to Determinations and | |||
Cell Lid Cracking Functionality | |||
URI 5000306/2018001-01 Assessments | |||
Description: | |||
During the week of February 12, 2018, the inspectors performed a walkdown of | |||
the 21 125 VDC battery. The inspectors noted that the majority of the 58 battery cells that | |||
made up the 21 battery system had various degrees of cracks on the cell lids, including some | |||
with cracks that were completely through the lid. During a cursory review of the corrective | |||
action program, vendor information, and station testing and maintenance procedures, the | |||
inspectors noted that all cracks identified since 2009 would not be addressed until the next | |||
planned cell replacement (originally slated for the fall of 2017 Unit 2 refueling outage). | |||
On February 22, 2018, the inspectors presented the following questions to the licensee: | |||
* Did the cracking (especially those going through the lid) affect the qualification of | |||
the 21 battery? The cracks could allow entry of foreign material and/or prevent the cell | |||
flame arrestors from performing their function; | |||
* Was there sufficient identification and tracking of battery lid cracks to monitor for | |||
changes over time? Since 21 battery cell lid cracks had been identified on various | |||
cells beginning in 2009, and the resolution was to replace the cells in 2017, there | |||
didnt appear to be monitoring of the cracks in the interim; and | |||
* Had the licensee interfaced with the vendor and verified that all the vendor | |||
recommendations were properly dispositioned? Similarly, was the site aware of | |||
applicable industry operating experience regarding battery lid cracking? | |||
The inspectors noted that the batteries had passed all required TS surveillance tests, so there | |||
was no immediate safety concern. | |||
The licensee responses on March 2 included a copy of a letter from the battery vendor to a | |||
different facility with recommendations to seal the cracks with epoxy to ensure flame arrestor | |||
functionality and to preclude entry of foreign material. The responses also included an email | |||
communication between the site and the vendor verifying that the recommendations applied | |||
to Prairie Island. | |||
The inspectors reviewed the responses to the above questions and concluded that they did | |||
not support the basis for full qualification of the 21 battery. Specifically, the vendor | |||
recommendation was not in the licensees corrective action program and it was unclear if it | |||
would be added. Additionally, there was a recognition of deficiencies in existing visual | |||
inspection practices (conducted as part of monthly and quarterly surveillance tests), but no | |||
stated action to resolve them. The inspectors concluded that the licensee should perform a | |||
formal evaluation of the 21 battery to determine its qualification. | |||
On March 14, the inspectors raised this issue in a meeting with the licensee. Following the | |||
meeting, the licensee initiated AR 50100009552, declared the 21 battery operable-but- | |||
degraded, and initiated a prompt operability determination (POD). The POD was completed | |||
on March 21, and concluded that the 21 battery was operable and fully qualified. The | |||
licensee also initiated a maintenance action to seal the cracks as referenced in the vendor | |||
recommendation letter, but strictly for personnel safety reasons. | |||
Subsequently, the inspectors again voiced concerns with the qualification of the 21 battery. | |||
The licensee stated that the POD was being revised and would likely conclude that | |||
the 21 battery was not fully qualified (i.e. degraded or non-conforming) due to the lid cracks | |||
and that changes to the visual inspections and application of epoxy sealant would serve as | |||
compensatory measures. On March 31, the POD revision was completed; however, the | |||
revised POD again concluded that the 21 battery was operable and fully qualified based, in | |||
part, on newly identified vendor testing that demonstrated no impact on specified safety | |||
function. The POD did not provide specifics on how existing visual inspections were adequate | |||
to prevent foreign material intrusion and detect new or worsened cracks or otherwise provide | |||
sufficient justification to support the conclusion that it was fully qualified. Additionally, the | |||
POD no longer referenced the vendor recommendations to seal the cracks. | |||
At the end of the inspection period, the inspectors determined that more information was | |||
needed to determine whether performance deficiencies existed associated with the licensees | |||
identification and evaluation of battery lid cracking since 2009 and to date; whether the | |||
operability process had been properly followed; and whether the station had appropriately | |||
dispositioned vendor and operating experience information regarding battery lid cracking. | |||
Prior to the exit meeting being held for the inspection period, the licensee documented two | |||
additional ARs to perform individual cell inspections and identify cracks needing | |||
repair (501000010411), and to re-consider the conclusions of the revised POD considering | |||
Prairie Island USAR Section 8.5.7 that stated, in part, Battery Maintenance and | |||
surveillance testing is performed in accordance with the recommendations of the | |||
manufacturers (501000010554). | |||
Planned Closure Actions: To resolve this item, the inspectors will review the final POD, any | |||
planned actions to revise the visual inspection procedures and maintenance practices, any | |||
planned actions to perform epoxy repairs per the vendor recommendations, and any | |||
evaluations regarding programmatic (operability, corrective action program, operating | |||
experience) and human performance aspects surrounding the issue (before and after | |||
questioning by the inspectors on February 22, 2018). | |||
Corrective Action Program References: ARs 501000009553, 501000010411, | |||
and 501000010554. | |||
71111.17TEvaluations of Changes, Tests, and Experiments | |||
Unresolved Item Questions Regarding the Manual Override of the 71111.17T | |||
(Closed) Automatic-Closure Function of Component Evaluations of | |||
Cooling System Valves Changes, Tests, and | |||
URI 5000252/2017008-01 Experiments | |||
Description: | |||
The inspectors identified an unresolved item regarding manual override of the auto-closure | |||
function of component cooling water system valves. Specifically, the inspectors noted that the | |||
system was not protected from tornado generated missiles when valves | |||
CV-39153 & CV-39154 are opened per procedure to support system alignments. The | |||
inspectors initially determined that further review was needed to determine if Technical | |||
Specifications are met if/when CV-39153 & CV-39154 are maintained open. | |||
Corrective Action Reference: AR 501000001642; 2017 50.59 Potential PD Evaluation 1133; | |||
08/15/2017 | |||
Closure Basis: The inspectors reviewed the license basis documentation, procedures, and | |||
interviewed licensee personnel, and did not identify any licensee failure to meet a requirement | |||
or standard. | |||
71111.18Plant Modifications | |||
Unresolved Item Questions Regarding the Corrective Action and 71111.18Plant | |||
(Open) Aging Management Programs Following the Modifications | |||
Discovery of 122 DDCLP FOST Vent Piping | |||
Degradation | |||
URI 05000252/2018001-02 | |||
Description: | |||
On November 28, 2017, the inspectors identified a small hole in the vent piping for the | |||
below-ground 122 DDCLP FOST (located outside and adjacent to the plant screenhouse). | |||
The station generated AR 501000005894 and the shift manager declared the | |||
supported 22 DDCL pump operable-but-degraded with a temporary procedure change | |||
to AB-4, Flood as a compensatory measure and wrapping of the pipe to preclude foreign | |||
material intrusion. The site backed up the immediate operability determination with a POD, | |||
evaluated past operability (no issues identified) and, subsequently replaced the affected | |||
portion of the pipe to restore full qualification. The inspectors concluded that these short term | |||
actions were acceptable to address the issue, but identified several concerns regarding prior | |||
actions to address the vent pipe corrosion. | |||
On March 1, 2018, the inspectors were provided the final evaluations for AR 501000005894. | |||
After review, the inspectors were concerned that the evaluations did not perform a sufficient | |||
review of: | |||
* whether the corrective action program properly dispositioned corrosion of the pipe | |||
when first identified in July of 2015; | |||
* whether the corrective action program and aging management program (AMP) | |||
performed as required to correctly classify and correct and/or manage the corrosion | |||
aging mechanism; and | |||
* whether the extent of cause/condition for the adjacent 121 DDCLP FOST vent pipe | |||
was properly addressed. | |||
The inspectors passed these concerns to individuals in the engineering and regulatory affairs | |||
departments, but the licensee then stated that the evaluations provided on March 1, were, in | |||
actuality, still in a revision/review phase. The licensee stated that the final evaluations would | |||
likely address the inspectors concerns. | |||
On March 22, the inspectors were provided the final evaluations, but it appeared that only | |||
minor changes were made and the inspectors concerns were not addressed. On March 28, | |||
the inspectors again voiced their concerns with the licensee and two new ARs | |||
(501000010169 and 501000010178) were created documenting the following: | |||
* the AR written identifying corrosion of the piping in July of 2015 was not evaluated | |||
under the AMP, the condition was determined to be operable and fully qualified, and it | |||
was closed to a work request to re-coat the piping but was never performed. | |||
* the AR written in April of 2016 again noted the corrosion, but was closed to a | |||
non-conservative evaluation, the issue was not evaluated under the AMP, operability | |||
was again assessed as operable and fully qualified, and a work request was issued to | |||
apply a coating (not completed until May of 2017). | |||
* the AMP engineer was not consulted in 2015 or 2016 to determine if/how the issue fit | |||
into the AMP requirements for increased monitoring, development of acceptance | |||
criteria, and final corrective actions. | |||
Planned Closure Actions: To resolve this item, the inspectors will review planned actions | |||
regarding the degraded 121 DDCLP FOST vent pipe, further extent of condition reviews, and | |||
review planned licensee condition and causal evaluations regarding programmatic and/or | |||
human performance aspects of the issue. | |||
Licensee Actions: At the end of the inspection period, the licensee began excavation | |||
activities to replace the 121 DDCLP FOST vent pipe and had apparent cause and extent of | |||
condition evaluations in progress. | |||
Corrective Action Program References: ARs 501000005894, 501000010169 and | |||
501000010178. | |||
71152AProblem Identification and Resolution | |||
Observation 71152Problem Identification and | |||
Resolution | |||
The inspectors assessment of ACE 500000283593 was that the licensee appeared to focus | |||
on common and contributing causes for various prior issues where engineering rigor was not | |||
satisfactory. Upon completing their review of the ACE, the inspectors questioned whether two | |||
additional examples of an apparent ongoing lack of rigor associated with URIs | |||
5000306/2018001-01 and 5000252/2017008-01 discussed above could have been | |||
prevented based on corrective actions taken from the AC | |||
: [[contact::E. In response]], engineering | |||
management acknowledged the underlining apparent causes to be behaviorally based, and | |||
increased mentoring, coaching, and oversight by engineering leadership was ongoing at the | |||
end of the inspection period. The inspectors concluded that ongoing engineering department | |||
initiatives were in place and continuing at the end of the inspection period, and continued | |||
monitoring was appropriate to verify sustainability. | |||
71153Follow-Up of Events and Notices of Enforcement Discretion | |||
Minor Violation 71153Follow-up of Events and | |||
Notices of Enforcement Discretion | |||
Minor Violation: For LER 5000306/2017002-00 Reactor Coolant System Shutdown | |||
Communication Line Vent Through Wall Defect, the inspectors reviewed pictures from | |||
October of 2015 and October of 2017 of boric acid deposits at the upstream side of the socket | |||
weld of valve 2RC-8-37 and the licensees Equipment Cause Evaluation dated | |||
December 13, 2017 (AR 501000003738). Based on this review, boric acid deposits indicative | |||
of leakage existed at this degraded weld location in 2015 and recurred in 2017. The licensee | |||
had not recognized this condition as evidence of an ongoing pressure boundary leak during | |||
this operating period. Based upon discussions with the licensee staff, the inspectors | |||
concluded that leakage of reactor coolant from the socket weld of valve 2RC-8-37 could not | |||
be isolated in Mode 1 using valves upstream because of the high radiation levels and | |||
personnel safety issues (e.g. heat and potentially high pressure steam if a fault progressed to | |||
rupture). Therefore, leakage from a through-wall fault at this location represented pressure | |||
boundary leakage and operation with this type of leakage is prohibited in Modes 1-4 by | |||
Technical Specification Limiting Condition of Operation 3.4.14. The licensee documented this | |||
violation in AR 501000003738, and LER 500306/2017002-00. | |||
Screening: The portion of the reactor coolant pressure boundary affected by this leak was | |||
part of the Code Class 1 pressure boundary and the faulted location did not affect the | |||
functional capability of any safety system since the leak was very small and within the | |||
capacity of the charging system. Therefore, the inspectors applied the IMC 0612 Appendix B | |||
Issue Screening process and answered no to the more than minor questions for this | |||
violation because the licensee determined that no loss of safety functions occurred. | |||
Violation: Failure to comply with TS LCO 3.4.14 associated with past operation of Unit 2 with | |||
pressure boundary leakage constitutes a minor violation that is not subject to enforcement | |||
action in accordance with the NRCs Enforcement Policy. | |||
Licensee Identified Non-Cited Violation 71153Follow-up of Events and | |||
Notices of Enforcement Discretion | |||
This violation of very low safety significant was identified by the licensee and has been | |||
entered into the licensee corrective action program and is being treated as a Non-Cited | |||
Violation, consistent with Section 2.3.2 of the Enforcement Policy. | |||
Enforcement: | |||
Violation: Prairie Island Technical Specification 3.0.4 states, in part, that when an LCO is not | |||
met, entry into a MODE or other specified condition in the Applicability shall only be made | |||
when the associated ACTIONS to be entered permit continued operation in the MODE or | |||
other specified condition in the Applicability for an unlimited period of time. | |||
Contrary to the above, at 0303 hours on November 12, 2017, during startup activities from a | |||
Unit 2 refueling outage, the licensee entered MODE 4 with both containment spray pump | |||
control switches in pull-out and therefore not OPERABLE as required by LCO 3.6.5 that | |||
required two containment spray trains OPERABLE in MODE 4. | |||
Significance/Severity Level: The finding was of very low safety significance (Green) because | |||
it did not degrade the ability to close or isolate containment and did not degrade the physical | |||
integrity of reactor containment. | |||
Corrective Action Program Reference: AR 501000005299. | |||
EXIT MEETINGS AND DEBRIEFS | |||
The inspectors confirmed that proprietary information was controlled to protect from public | |||
disclosure. No proprietary information was documented in this report. | |||
* On February 16, 2018, the inspectors presented the 71124.03 and 71124.04 inspection | |||
results to Mr. | |||
: [[contact::T. Conboy]], Director of Site Operations, and other members of the licensee | |||
staff. | |||
* On April 12, 2018, the inspectors presented the overall quarterly integrated inspection | |||
results to Mr. | |||
: [[contact::S. Sharp]], Site Vice President, and other members of the licensee staff. | |||
THIRD PARTY REVIEWS | |||
The inspectors reviewed World Association of Nuclear Operators/Institute of Nuclear Power | |||
Operations reports that were issued during the inspection period. | |||
DOCUMENTS REVIEWED | |||
71111.01Adverse Weather Protection | |||
AR 501000009559; Trending Oil Results on D5/D6 Rad Fans; 03/16/2018 | |||
WO 00356590-02; TP 1676 Annual Meteorological Instruments Calibration; 04/06/2008 | |||
TP 1676; Meteorological Instrument Calibration; Revision 10 | |||
WO 00357688-01; TP 1677 Monthly Meteorological Instrumentation; 01/14/2009 | |||
WO 700011943; D6 Building Ventilation Instruction Calibration; 12/11/2017 | |||
AR 501000007124; D5/D6 Diesel Temperature Limit; 01/01/2018 | |||
DBD SYS-38A; Design Bases Document for the Emergency Diesel Generator System | |||
AR 501000006819; Seasonal Readiness Program FP-WM-SR-01; 01/02/2018 | |||
2C37.10; D5/D6 Diesel Generator Building HVAC; Revision 11 | |||
AR 501000007616; PMT Documentation Enhancement; 01/24/2018 | |||
AR 501000007584; MET Tower ERCS Points Not Checked; 01/23/2018 | |||
71111.04Equipment Alignment | |||
NF-88616-2; Electrical Heat Tracing Isometric Unit 2 Safety Injection Pump Suction; | |||
Revision 75 | |||
C1.1.18-2; S1, CS, CA, and HC System Checklist Unit 2; Revision 49 | |||
C1.1.20.5-1; Unit 1 4.16kV System Switches and Indication Checklist; Revision 27 | |||
C1.1.20.5-2; Unit 2 4.16kV System Switches and Indication Checklist; Revision 29 | |||
Heating, Ventilating & Air Conditioning Project 2121-7594 (R/E 6197); Revision 0 | |||
NE-40009; Annulus Vent Recirculation Fan Discharge Damper; Sheet 144; Revision CY | |||
C37.5; Screenhouse Normal Ventilation; Revision 9 | |||
AR 501000007481; NRC Question on 12 and 22 DD Clg Pump; 01/19/2018 | |||
FP-R-LIC-06; NRC Question Response Form-Outside Temperature; 01/2018 | |||
AR 501000007044; 11 CL PMP Packing Smoke; 01/06/2018 | |||
AR 501000007050; 21 Cooling Water Pump Packing Warm; 01/08/2018 | |||
AR 501000006858; Emrg Gen Bldg FO Tank Rm Htr Not Working; 01/03/2018 | |||
AR 501000007185; Expectations for Accuracy of Documentation; 01/11/2018 | |||
AR 501000007092; 47019-0506 Alarm upon 121 Pump Start; 01/10/2018 | |||
71111.05AQFire Protection Annual/Quarterly | |||
Appendix A; Fire Detection Zone 11; Revision 35F5 | |||
Appendix F; Table 6-1 Fire Hazards Analysis Matrix FireArea 41A; Revision 34F5 | |||
F5 Appendix KFire Protection Systems Functional Requirements; Diesel Driven Cooling | |||
Water Pumps; Revision 24 | |||
AR 501000006871; 2 FBMs Didnt Get 2 Fire Drills in 2017; 01/01/2018 | |||
71111.06Flood Protection Measures | |||
H36; Plant Flooding; Revision 11 | |||
AWI 8.9.0; Internal Flooding Drainage Control; Revision 20 | |||
71111.11Licensed Operator Requalification Program and Licensed Operator Performance | |||
1C1.4; Unit 1 Power Operation; Revision 65 | |||
AR 501000007687; Crew Failed Cycle 18A Simulator Eval; 01/24/2018 | |||
AR 501000007770; Trend in Simulator Evaluation Failures; 01/25/2018 | |||
AR 501000009799; SR RPS Failed RP Cycle 1 Continuing Training; 03/20/2018 | |||
LOR Cycle 18B Cycle SIM Session #3Licensed Operator Requalification; Revision 0 | |||
71111.12Maintenance Effectiveness | |||
Prairie Island Maintenance Rule Bases Document | |||
FP-E-MR-01; Maintenance Rule Process; Revision 9 | |||
FP-E-MR-02; Maintenance Rule Scoping; Revision 10 | |||
FP-E-MR-03; Maintenance Rule Monitoring; Revision 7 | |||
WO 700005259-0090; NEPA 805 EC 25120 CT12 4kV Breaker Addition; 12/22/2017 | |||
WO 00540589; Troubleshoot and Repair BUS 15 Load Sequencer; 11/09/2016 | |||
AR 501000007217; Unable to Hang Tags on New Unlabeled Breaker; 01/13/2018 | |||
AR 501000004433; Unexpected Plant Response Breaker 25-17; 10/28/2017 | |||
AR 501000007689; Bus 26 Relay 27-UV Out of Range; 01/25/2018 | |||
AR 1538329; 4kV Disconnect Danger Tag Placement Incorrect; 10/18/2016 | |||
AR 1534190; Breaker CT-BT112 Relay Chattering; 09/14/2016 | |||
AR 1520596; NRC Question about Breaker 15-4 Cable; 06/22/2016 | |||
SP 2322; Safeguards Buses Weekly InspectionOperating; Revision 31 | |||
WO 700015558; SP 2322 4.16 kV Safeguards Bus Weekly Inspection | |||
SP 2856; Monthly 4kV Bus 26 Undervoltage Relay Test (Omicron); Revision 6 | |||
71111.13Maintenance Risk Assessments and Emergent Work Control | |||
AR 501000007811; D2 Lockout during Slow Start Test; 01/29/2018 | |||
AR 501000007845; D2 PMT Plan Improper for Conditions; 01/30/2018 | |||
AR 501000008319; Increase in U2 Containment Sump A Operation; 02/14/2018 | |||
AR 501000008527; U2 Containment Sump A Consecutive Days Runtime; 02/17/2018 | |||
AR 501000008542; U2 Containment Sump A 3 Days With Runtime; 02/18/2018 | |||
AR 501000008538; Unit 2 Containment Sump A Pump Runtime; 02/19/2018 | |||
AR 501000008620; Unexpected Annunciator 47516-0504; 02/19/2018 | |||
AR 501000008640; Unit 2 Containment Sump A Consecutive Run Day #5; 02/20/2018 | |||
AR 501000008853; Strong Odor From D6 Serv Pnl 6; 02/26/2018 | |||
AR 501000008917; D6 Maintenance Run Issues; 02/27/2018 | |||
AR 501000008923; Excitation Voltage and Current on D6; 02/27/2018 | |||
AR 501000008950; Abnormal Conditions During D6 Maint Run; 02/27/2018 | |||
AR 501000009350; D5 DG Common Cause Documentation; 03/09/2018 | |||
1C20.7; D1/D2 Diesel Generators; Page 1 of 108; Revision 48 | |||
71111.15Operability Determinations and Functionality Assessments | |||
AR 501000007074; Relay Room Temperature Limit Question; 01/09/2018 | |||
AR 501000010535; D1 Bellow POD; 04/09/2018 | |||
AR 501000009850; Revise D1 Bellows Crack POD; 03/20/2018 | |||
AR 501000010554; POD for 21 Battery Needs Revision; 04/08/2018 | |||
AR 501000010411; Safety Battery Lid Crack Identification; 04/05/2018 | |||
AR 501000009553; NRC Question on 21 Battery Lids; 03/14/2018 | |||
SP 2323; 21 Battery Monthly Inspection; Revision 18 | |||
SP 2325; 21 Battery Quarterly Inspection; Revision 18 | |||
SP 2337; 21 Battery Semi-Annual Inspection; Revision 22 | |||
AR 1184867; Adverse Trend in 11 Battery Jar/Cover Leakage; 06/08/2009 | |||
AR 1293335; Hairline Cracks by Sample Tubes on Several Battery Cells; 07/06/2011 | |||
AR 1511537; Results of 21 Battery Monthly Inspection; 02/09/2016 | |||
AR 1546260; 21 Battery Inspection, SP 2323; 01/03/2017 | |||
AR 1558296; 21 Battery Inspection, SP 2323; 05/09/2017 | |||
AR 501000008489; Relay 1X/32215 Contacts Sticky; 02/16/2018 | |||
AR 726957; Engineering Inspection of 21-Battery Found New Cracks on Cell; 06/28/2004 | |||
AR 501000009528; D1 Turbocharger Outlet Bellows Leak; 03/15/2018 | |||
FP-OP-OL-01; Operability/Functionality Determination; Revision 21 | |||
Temporary Modification 601000000504; Temporary Repair of D1 Exhaust Bellows | |||
H59; Periodic Vendor Contact Program; Revision 3 | |||
SWI ENG-20; Disposition of Vendor Information; Revision 5 | |||
FP-PA-OE-01; Operating Experience Program; Revision 25 | |||
FP-PE-PM-01; Preventive Maintenance Program; Revision 20 | |||
FP-PA-ARP-01; CAP Process; Revision 52 | |||
WO 700027998-0030; Bench Test Motor 121N Relay Rm Unit CLR; 10/10/2017 | |||
WO 700027998-0010; Replace Motor 112G-15 and Motor 112G-23; 10/10/2017 | |||
D80; Scaffolds Requiring Seismic Consideration-Controlled Access Areas @ 695; Revision 36 | |||
71111.18Plant Modifications | |||
AR 501000010178; Aging Management CE Inappropriately Closed; 03/30/2018 | |||
AR 501000010169; Response to Degraded FOST Vent Pipe; 03/30/2018 | |||
H65.2.14; External Surfaces Monitoring Aging Management Program; Revision 0 | |||
PINGP 1516; Walkdown Checklist Mechanical Systems/Components; Revision 5 | |||
AR 501000005894; Hole in 122 DDCL Pump Oil Storage TK Vent; 11/28/2017 | |||
AR 1487938; DSL Storage Tank Vent Stack Corrosion; 07/30/2015 | |||
AR 1519124; Vent Line for 121 Clg Water Pump DSL Oil Storage Tank Corroded; 04/18/2016 | |||
71111.19Post Maintenance Testing | |||
D70.1; Motor Operated Valve Testing; Revision 23 | |||
WO 700027006-0020; 122 SWGR RM Unit Clr; 03/12/2018 | |||
WO 700027009-0010; Replace MTR 222G-19 per EC 21175; 12/29/2017 | |||
WO 700027009-0020; Replace MTR 222G-19 Bench Test Motor; 12/07/2017 | |||
WO 700027007-0010; Replace MTR 222G-16 (EC 21175); 12/29/2017 | |||
WO 700033770-0030; PMT and RTS 2 S/G Steam Flow; 01/19/2018 | |||
AR 501000007861; Inadequate PMT for MV-32129 Work Plan; 01/30/2018 | |||
5AWI 3.12.4; Post Maintenance Testing; Revision 24 | |||
AR 501000002920; D5 Simulator Relays Not Tested in PMT; 11/30/2017 | |||
WO 700033770-0010; Replace Analog Output Q Card Slot 6; 01/19/2018 | |||
AR 501000007542; Worn Connecting Rod on MD-32429; 01/21/2018 | |||
AR 501000007428; 22 S/G STM Flow 2FI-475 Failed; 01/19/2018 | |||
WO 700028081-0020; Benchtest Motor; 10/10/2017 | |||
WO 700027998-0020; Benchtest Motor 121 N Relay Room Unit CLR; 10/10/2017 | |||
WO 700028082-0020; Benchtest Motor 121 N Relay Room Unit CLR; 10/10/2017 | |||
AR 501000006972; Incorrect Bench Test Info Documented; 01/05/2018 | |||
AR 501000006985; Incorrect Bench Test Info Documented; 01/05/2018 | |||
71111.22Surveillance Testing | |||
WO 700011438; SP 1073A-Train A Shield Building Vent Test; 02/01/2018 | |||
SP 1073AMonthly Train A Shield Building Ventilation System Test; Revision 14 | |||
SP 1106B; 22 Diesel Cooling Water Pump Monthly Test; Revision 93 | |||
WO 700021965; SP 1106B 22 Diesel CL PMP Monthly; 03/23/2018 | |||
SP 2116; Monthly Power Distribution MAP U2; 01/15/2018 | |||
AR 501000008026; MD-32215 Green IL Not Lit After SP 1073A; 02/06/2018 | |||
71114.06Drill Evaluation | |||
LOR Cycle 18A Licensed Operator Requalification; Revision 0 | |||
71124.03In-Plant Airborne Radioactivity Control and Mitigation | |||
Self-Assessment; 6SAR01554468; 02/02/2018 Licensed Operator Respiratory Protection | |||
Eyeglass Records; Current Records | |||
C40.5; Control Room Breathing Air System; Revision 3 | |||
RPIP 1214; Respiratory Protection Equipment Testing; Revision 22 | |||
RPIP 1215; Respiratory Protection Control; Revision 10 | |||
H26; Respiratory Protection Program; Revision 14 | |||
Respirator Inspection Checks; 01/2018 | |||
Grade D Air Tests; 2016 through 2017 | |||
AR 501000007493; Leak on Fire Brigade SCBA; 01/19/2018 | |||
AR 501000007262; Large SCBA Mask Staged Vice Medium; 01/15/2018 | |||
AR 501000000477; MSA SCBA Cylinder Gauge Incorrect; 07/01/ 2018 | |||
AR 1557677; Fitting on SCBA Charging Hose is Leaking; 05/03/2017 | |||
AR 1547925; Fire Brigade SCBA Failed Monthly Testing; 01/19/2017 | |||
AR 1544020; Breathing Air Sample Lost for November 2016; 12/05/2016 | |||
AR 501000008404; Outdated Respirator Canisters; 02/15/2018 | |||
AR 501000008440; SCBA Inspection Incomplete; 02/15/2018 | |||
71124.04Occupational Dose Assessment | |||
NVLAP Accreditation Program for Mirion Technologies, 07/01/2017-06/30/2018 | |||
FP-RP-AM-01; Alpha Monitoring Program; Revision 5 | |||
FP-RP-BP-01, Bioassay Program; Revision 7 | |||
FPRP-DP-01; Dosimetry Program; Revision 10 | |||
FP-RP-IDA-01; Internal Dose Assessment; Revision 3 | |||
FP-RP-EDC-01; DMC 2000 S Electronic Dosimeter and IRD 2000 Calibration; Revision 4 | |||
RPIP 1107; Fetal Protection Program; Revision 11 | |||
RPIP 1115; Area TLD Locations, Emergency Plan TLDs & TLD Change Out; Revision 16 | |||
RPIP 1204; Evaluation of Airborne Radioactivity; Revision 22 | |||
2017 Prairie Island Isotopic Mix Evaluation; Undated | |||
2017 Annual Area TLD Trending Report; 01/24/2018 | |||
2017 TLD Data; Various Records | |||
Declared Pregnant Worker Records; One Record | |||
Technical Basis Document #13-002; ISFSI Cask Neutron Field Evaluation; Revision 1 | |||
Technical Basis Document #15-001; Unit 2 Containment Neutron Field Evaluation; Revision 0 | |||
TLD/ED Comparison Data and Evaluation; Various Records | |||
Whole Body Count Records; Various Records | |||
AR 501000008210; Dose Discrepancies for Period 02/03/2017-02/03/2017; 02/09/2018 | |||
AR 1549796; Personnel Dose in Green Warehouse; 02/07/2017 | |||
71151Performance Indicator Verification | |||
Operator Logs, Various, January 1 through December 31, 2017 | |||
71152Problem Identification and Resolution | |||
AR 500001548470; NRC Question on Door 225 Transom; 03/21/2017 | |||
AR 500001547498; NRC QuestionBusduct from 1R to BUS 15 at Cubicle 15-3; 03/21/2017 | |||
AR 501000003299; Inaccuracy in Statement Given NRC Resident Inspector; 11/03/2017 | |||
FP-PA-HU-01; Human Performance Program (Culpability Evaluation Tool); Revision 19 | |||
AR 501000006926; QIM 501000004740 POR Assignment; 01/05/2018 | |||
W/R #00130457; NRC Question Busduct from 1R to Bus 15 at Cubicle 15.3; 01/18/2017 | |||
AR 501000007264; PINGP Unacceptable Continued Poor HU; 01/14/2018 | |||
71153Follow-Up of Events and Notices of Enforcement Discretion | |||
AR 501000003738; BACC: 2RC-8-37 Indication of Leakage; 10/16/2017 | |||
Flowserve Certificate of Compliance/Conformance; 02/24/2014 | |||
Work Task 00532148-01; 10/17/2015 | |||
Work Task 00532148-02; 09/07/2017 | |||
FP-PE-NDE-200; Solvent Removable Visible Dye Penetrant; Revision 1 | |||
Work Order # 700028252; 10/19/2017 | |||
Liquid Penetrant Examination Report BOP-PT-17-048; 10/16/2017 | |||
AR 501000006279; PI&R Issue for 2RC-8-37; 12/11/2017 | |||
RCE 501000004815; 2R30 Configuration Management; 12/18/2017 | |||
UNITED STATES | |||
NUCLEAR REGULATORY COMMISSION | |||
REGION III | |||
2443 WARRENVILLE RD. SUITE 210 | |||
LISLE, ILLINOIS 60532-4352 | |||
May 9, 2018 | |||
Mr. Scott Sharp | |||
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, UNITS 1 AND 2NRC | |||
INTEGRATED INSPECTION REPORT 05000282/2018001 | |||
AND 05000306/2018001 | |||
Dear Mr. Sharp: | |||
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection | |||
at your Prairie Island Nuclear Generating Plant, Units 1 and 2. On April 12, 2018, 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. | |||
Based on the results of this inspection, the NRC inspectors documented a licensee-identified | |||
violation which was determined to be of very low safety significance in this report. The NRC is | |||
treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the | |||
Enforcement Policy. | |||
If you contest the violation or significance of the NCV, you should provide a response within | |||
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 the Prairie Island Nuclear Generating Plant. | |||
S. Sharp -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 10 CFR 2.390, Public Inspections, Exemptions, Requests for | |||
Withholding. | |||
Sincerely, | |||
/RA/ | |||
Kenneth Riemer, Chief | |||
Branch 2 | |||
Division of Reactor Projects/Safety | |||
Docket Nos. 50-282; 50-306; 72-010 | |||
License Nos. DPR-42; DPR-60; SNM-2506 | |||
Enclosure: | |||
IR 05000282/2018001; 05000306/2018001 | |||
cc: Distribution via LISTSERV | |||
S. Sharp -3- | |||
Letter to | |||
: [[contact::S. Sharp from K. Riemer dated May 9]], 2018 | |||
SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2NRC | |||
INTEGRATED INSPECTION REPORT 05000282/2018001 | |||
AND 05000306/2018001 | |||
}} | }} |
Latest revision as of 14:47, 2 November 2019
ML18129A181 | |
Person / Time | |
---|---|
Site: | Prairie Island |
Issue date: | 05/09/2018 |
From: | Kenneth Riemer NRC/RGN-III/DRP/B2 |
To: | Sharp S Northern States Power Company, Minnesota |
References | |
IR 2018001 | |
Download: ML18129A181 (21) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION May 9, 2018
SUBJECT:
PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2NRC INTEGRATED INSPECTION REPORT 05000282/2018001 AND 05000306/2018001
Dear Mr. Sharp:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Prairie Island Nuclear Generating Plant, Units 1 and 2. On April 12, 2018, 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.
Based on the results of this inspection, the NRC inspectors documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the Enforcement Policy.
If you contest the violation or significance of the NCV, 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 the Prairie Island Nuclear Generating Plant. 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 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Kenneth Riemer, Chief Branch 2 Division of Reactor Projects/Safety Docket Nos. 50-282; 50-306;72-010 License Nos. DPR-42; DPR-60; SNM-2506 Enclosure:
IR 05000282/2018001; 05000306/2018001 cc: Distribution via LISTSERV
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring licensee performance by conducting an integrated quarterly inspection at Prairie Island Nuclear Generating Plant, Units 1 and 2 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. Additional tracking items are summarized in the table below. One Licensee-identified NCV and one minor violation are documented in report section 71153.
List of Findings and Violations None.
Additional Tracking Items Type Issue Number Title Report Status Section LER 05000306/2017002-00 Reactor Coolant System 71153 Closed Shutdown Communication Live Vent Through Wall Defect LER 05000306/2017003-00 Both Containment Spray 71153 Closed Pump Control Switches in Pull-Out in Mode 4 LER 05000282/2018001-00 121 Motor Driven Cooling 71153 Closed Water Pump Auto Start due to Smoking Packing on 11 Cooling Water Pump URI 05000282/2017008-01 Questions Regarding the 71111.17T Closed Manual Override of the Automatic-Closure Function of Component Cooling System Valves URI 05000306/2018001-01 Questions Regarding 71111.15 Open Corrective Action Program,
Use of Operating Experience, and Qualification of the 21 125 VDC Battery due to Cell Lid Cracking URI 05000282/2018001-02 Questions Regarding the 71111.18 Open Corrective Action and Aging Management Programs Following the Discovery of 122 Diesel Driven Cooling Water (DDCL) Pump Fuel Oil Storage Tank (FOST) Vent Piping Degradation
TABLE OF CONTENTS
PLANT STATUS
INSPECTION SCOPES
............................................................................................................
REACTOR SAFETY
..................................................................................................................
RADIATION SAFETY
................................................................................................................
OTHER ACTIVITIES
BASELINE
INSPECTION RESULTS
..........................................................................................................
EXIT MEETINGS AND DEBRIEFS
........................................................................................ 13 THIRD PARTY REVIEWS ...................................................................................................... 14
DOCUMENTS REVIEWED
..................................................................................................... 14
PLANT STATUS
Units 1 and 2 operated at full power for the entirety of the inspection period, with the exception
of brief down-power maneuvers to accomplish planned surveillance testing or troubleshooting
activities.
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 plant status activities described in
IMC 2515 Appendix D, Plant Status and conducted routine reviews using IP 71152, Problem
Identification and Resolution. 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
71111.01Adverse Weather Protection
Impending Severe Weather (1 Sample)
The inspectors evaluated readiness for impending adverse weather conditions for Cold
Weather on January 4, 2018 (D5 and D6 emergency diesel generator (EDG) building).
71111.04Equipment Alignment
Partial Walkdown (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following
systems/trains:
(1) 21 cooling water (CL) system during the week of January 8, 2018;
(2) 12 and 22 DDCL ventilation system on January 19, 2018; and
(3) Offsite power sources with 345 kV Bus 2 out of service during the week of
March 5, 2018.
Complete Walkdown (1 Sample)
The inspectors evaluated system configurations during a complete walkdown of the Unit 2
safety injection system during the weeks of January 22 and 29, 2018.
71111.05AQFire Protection Annual/Quarterly
Quarterly Inspection (4 Samples)
The inspectors evaluated fire protection program implementation in the following selected
areas:
(1) Fire Area 41A, Screenhouse, Elevation 695;
(2) Fire Area 18, Relay and Cable Spreading Room, Elevation 715;
(3) Fire Detection Zone 11, Fire Areas 20 & 81; Bus 15 & 16 Switchgear Rooms,
Elevation 715; and
(4) Fire Zone 97, D5/D6 EDG Building.
71111.06Flood Protection Measures
Internal Flooding (1 Sample)
The inspectors evaluated internal flooding mitigation protections in the Unit 1 containment
spray pump room during the week of February 5, 2018.
71111.11QLicensed Operator Requalification Program and Licensed Operator Performance
Operator Performance (1 Sample)
The inspectors observed and evaluated a Unit 1 reduction in power to approximately 40 percent
for main turbine testing and main condenser inspections during the week of March 12, 2018.
Operator Requalification (1 Sample)
The inspectors observed and evaluated simulator requalification training on March 16, 2018.
71111.12Maintenance Effectiveness
Routine Maintenance Effectiveness (2 Samples)
The inspectors evaluated the effectiveness of routine maintenance activities associated
with the following equipment and/or safety significant functions:
(1) Unit 1 and 2 4.16kV AC electrical systems; and
(2) Unit 2 component cooling water system.
71111.13Maintenance Risk Assessments and Emergent Work Control (4 Samples)
The inspectors evaluated the risk assessments for the following planned and emergent
work activities:
(1) D2 EDG exciter pushbutton failure, lockout, and troubleshooting activities on
January 29, 2018;
(2) Unit 2 containment sump A in-leakage on February 20, 2018;
(3) D6 EDG return to service issues during the week of February 26, 2018; and
(4) Work week 1811 unplanned Technical Specification (TS) Limiting Conditions for
Operation (LCOs) (screenhouse safeguards exhaust fan & Bus 122 room cooling fan
motors) during the week of March 19, 2018.
71111.15Operability Determinations and Functionality Assessments (5 Samples)
The inspectors evaluated operability determinations for the following action requests
(ARs):
(1) AR 501000004740; 121S and 122N Relay Room Motor Amp Past Operability Evaluation
on January 2, 2018;
(2) AR 501000009553; NRC Question On 21 Battery Lids on February 20, 2018;
(3) AR 501000008489; Relay 1X32215 Contacts Sticky on February 21, 2018;
(4) AR 501000007896; Safeguard Strainer Room Screenhouse Seismic Evaluation on
February 26, 2018; and
(5) AR 501000009528; D1 Turbocharger Outlet Bellows Leak on March 21, 2018.
71111.17TEvaluations of Changes, Tests and Experiments (No Sample)
The inspectors performed a review of Unresolved Item (URI)5000282/2017008-01,
Questions Regarding the Manual Override of the Automatic-Closure Function of
Component Cooling System Valves. This review did not constitute an inspection sample.
71111.18Plant Modifications (1 Sample)
The inspectors evaluated a permanent modification associated with:
(1) AR 501000005894; Hole in 122 DDCL Pump Oil Storage Tank Vent.
71111.19Post Maintenance Testing (5 Samples)
The inspectors evaluated the following post maintenance tests:
(1) 22 steam generator steam flow and level indication circuit card replacement on
January 22, 2018;
(2) 122N relay room and B event monitoring room unit cooler motor replacement on
January 31, 2018;
(3) Testing of D2 EDG following exciter stop pushbutton replacement on February 1, 2018;
(4) Testing of MV-32129, 22 residual heat removal component cooling water inlet valve on
January 31, 2018; and
(5) Bus 122 room cooler fan motor replacement on March 21, 2018.
71111.22Surveillance Testing
The inspectors evaluated the following surveillance tests:
Routine (2 Samples)
(1) SP 2116; Unit 1 Monthly Power Distribution Map Surveillance Test on January 23, 2018;
and
(2) SP 1073A; Unit 1 Train A Shield Building Ventilation System on February 6, 2018.
In-service (1 Sample)
(1) 22 DDCL Pump Monthly SP on March 23, 2018.
71114.06Drill Evaluation
Drill/Training Evolution (1 Sample)
On January 25, 2018, the inspectors evaluated a simulator training session with Drill &
Exercise Performance (DEP) opportunities.
RADIATION SAFETY
71124.03In-Plant Airborne Radioactivity Control and Mitigation
Engineering Controls (1 Sample)
The inspectors evaluated airborne controls and monitoring.
Use of Respiratory Protection Devices (1 Sample)
The inspectors evaluated respiratory protection.
71124.04Occupational Dose Assessment
Source Term Characterization (1 Sample)
The inspectors evaluated the licensees source term characterization.
External Dosimetry (1 Sample)
The inspectors evaluated the licensees external dosimetry program.
Internal Dosimetry (1 Sample)
The inspectors evaluated the licensees internal dosimetry program.
Special Dosimetric Situations (1 Sample)
The inspectors evaluated the licensees performance for special dosimetric situations.
OTHER ACTIVITIESBASELINE
71151Performance Indicator Verification (8 Samples)
The inspectors verified licensee performance indicators submittals listed below:
(1) IE01: Unplanned Scrams per 7000 Critical Hours-2 Samples (01/01/2017-12/31/2017);
(2) IE03: Unplanned Power Changes per 7000 Critical Hours-2 Samples (01/01/2017-
2/31/2017);
(3) IE04: Unplanned Scrams with Complications (USwC)-2 Samples (01/01/2017-
2/31/2017); and
(4) MS05: Safety System Functional Failures (SSFFs)-2 Samples (01/01/2017-
2/31/2017).
71152AProblem Identification and Resolution
Annual Follow-Up of Selected Issues (1 Sample)
The inspectors reviewed the licensees implementation of its corrective action program
related to the following issue:
(1) Apparent Cause Evaluation 500000283593; Adverse Trend in Technical Rigor.
71153Follow-Up of Events and Notices of Enforcement Discretion Events
Licensee Event Reports (3 Samples)
The inspectors evaluated the following licensee event reports which can be accessed at
https://lersearch.inl.gov/LERSearchCriteria.aspx:
(1) Licensee Event Report (LER) 5000306/2017002-00: Reactor Coolant System
Shutdown Communication Live Vent Through Wall Defect;
(2) LER 5000306/2017003-00: Both Containment Spray Pump Control Switches in Pull-out
in Mode 4; and
(3) LER 5000282/2018001-00: 121 Motor Driven Cooling Water Pump Auto Start due to
Smoking Packing on 11 Cooling Water Pump.
INSPECTION RESULTS
71111.15Operability Determinations and Functionality Assessments
Unresolved Item Questions Regarding Corrective Action 71111.15
(Open) Program, Use of Operating Experience, and Operability
Qualification of the 21 125 VDC Battery due to Determinations and
Cell Lid Cracking Functionality
URI 5000306/2018001-01 Assessments
Description:
During the week of February 12, 2018, the inspectors performed a walkdown of
the 21 125 VDC battery. The inspectors noted that the majority of the 58 battery cells that
made up the 21 battery system had various degrees of cracks on the cell lids, including some
with cracks that were completely through the lid. During a cursory review of the corrective
action program, vendor information, and station testing and maintenance procedures, the
inspectors noted that all cracks identified since 2009 would not be addressed until the next
planned cell replacement (originally slated for the fall of 2017 Unit 2 refueling outage).
On February 22, 2018, the inspectors presented the following questions to the licensee:
- Did the cracking (especially those going through the lid) affect the qualification of
the 21 battery? The cracks could allow entry of foreign material and/or prevent the cell
flame arrestors from performing their function;
- Was there sufficient identification and tracking of battery lid cracks to monitor for
changes over time? Since 21 battery cell lid cracks had been identified on various
cells beginning in 2009, and the resolution was to replace the cells in 2017, there
didnt appear to be monitoring of the cracks in the interim; and
- Had the licensee interfaced with the vendor and verified that all the vendor
recommendations were properly dispositioned? Similarly, was the site aware of
applicable industry operating experience regarding battery lid cracking?
The inspectors noted that the batteries had passed all required TS surveillance tests, so there
was no immediate safety concern.
The licensee responses on March 2 included a copy of a letter from the battery vendor to a
different facility with recommendations to seal the cracks with epoxy to ensure flame arrestor
functionality and to preclude entry of foreign material. The responses also included an email
communication between the site and the vendor verifying that the recommendations applied
to Prairie Island.
The inspectors reviewed the responses to the above questions and concluded that they did
not support the basis for full qualification of the 21 battery. Specifically, the vendor
recommendation was not in the licensees corrective action program and it was unclear if it
would be added. Additionally, there was a recognition of deficiencies in existing visual
inspection practices (conducted as part of monthly and quarterly surveillance tests), but no
stated action to resolve them. The inspectors concluded that the licensee should perform a
formal evaluation of the 21 battery to determine its qualification.
On March 14, the inspectors raised this issue in a meeting with the licensee. Following the
meeting, the licensee initiated AR 50100009552, declared the 21 battery operable-but-
degraded, and initiated a prompt operability determination (POD). The POD was completed
on March 21, and concluded that the 21 battery was operable and fully qualified. The
licensee also initiated a maintenance action to seal the cracks as referenced in the vendor
recommendation letter, but strictly for personnel safety reasons.
Subsequently, the inspectors again voiced concerns with the qualification of the 21 battery.
The licensee stated that the POD was being revised and would likely conclude that
the 21 battery was not fully qualified (i.e. degraded or non-conforming) due to the lid cracks
and that changes to the visual inspections and application of epoxy sealant would serve as
compensatory measures. On March 31, the POD revision was completed; however, the
revised POD again concluded that the 21 battery was operable and fully qualified based, in
part, on newly identified vendor testing that demonstrated no impact on specified safety
function. The POD did not provide specifics on how existing visual inspections were adequate
to prevent foreign material intrusion and detect new or worsened cracks or otherwise provide
sufficient justification to support the conclusion that it was fully qualified. Additionally, the
POD no longer referenced the vendor recommendations to seal the cracks.
At the end of the inspection period, the inspectors determined that more information was
needed to determine whether performance deficiencies existed associated with the licensees
identification and evaluation of battery lid cracking since 2009 and to date; whether the
operability process had been properly followed; and whether the station had appropriately
dispositioned vendor and operating experience information regarding battery lid cracking.
Prior to the exit meeting being held for the inspection period, the licensee documented two
additional ARs to perform individual cell inspections and identify cracks needing
repair (501000010411), and to re-consider the conclusions of the revised POD considering
Prairie Island USAR Section 8.5.7 that stated, in part, Battery Maintenance and
surveillance testing is performed in accordance with the recommendations of the
manufacturers (501000010554).
Planned Closure Actions: To resolve this item, the inspectors will review the final POD, any
planned actions to revise the visual inspection procedures and maintenance practices, any
planned actions to perform epoxy repairs per the vendor recommendations, and any
evaluations regarding programmatic (operability, corrective action program, operating
experience) and human performance aspects surrounding the issue (before and after
questioning by the inspectors on February 22, 2018).
Corrective Action Program References: ARs 501000009553, 501000010411,
and 501000010554.
71111.17TEvaluations of Changes, Tests, and Experiments
Unresolved Item Questions Regarding the Manual Override of the 71111.17T
(Closed) Automatic-Closure Function of Component Evaluations of
Cooling System Valves Changes, Tests, and
URI 5000252/2017008-01 Experiments
Description:
The inspectors identified an unresolved item regarding manual override of the auto-closure
function of component cooling water system valves. Specifically, the inspectors noted that the
system was not protected from tornado generated missiles when valves
CV-39153 & CV-39154 are opened per procedure to support system alignments. The
inspectors initially determined that further review was needed to determine if Technical
Specifications are met if/when CV-39153 & CV-39154 are maintained open.
Corrective Action Reference: AR 501000001642; 2017 50.59 Potential PD Evaluation 1133;
08/15/2017
Closure Basis: The inspectors reviewed the license basis documentation, procedures, and
interviewed licensee personnel, and did not identify any licensee failure to meet a requirement
or standard.
71111.18Plant Modifications
Unresolved Item Questions Regarding the Corrective Action and 71111.18Plant
(Open) Aging Management Programs Following the Modifications
Discovery of 122 DDCLP FOST Vent Piping
Degradation
Description:
On November 28, 2017, the inspectors identified a small hole in the vent piping for the
below-ground 122 DDCLP FOST (located outside and adjacent to the plant screenhouse).
The station generated AR 501000005894 and the shift manager declared the
supported 22 DDCL pump operable-but-degraded with a temporary procedure change
to AB-4, Flood as a compensatory measure and wrapping of the pipe to preclude foreign
material intrusion. The site backed up the immediate operability determination with a POD,
evaluated past operability (no issues identified) and, subsequently replaced the affected
portion of the pipe to restore full qualification. The inspectors concluded that these short term
actions were acceptable to address the issue, but identified several concerns regarding prior
actions to address the vent pipe corrosion.
On March 1, 2018, the inspectors were provided the final evaluations for AR 501000005894.
After review, the inspectors were concerned that the evaluations did not perform a sufficient
review of:
- whether the corrective action program properly dispositioned corrosion of the pipe
when first identified in July of 2015;
- whether the corrective action program and aging management program (AMP)
performed as required to correctly classify and correct and/or manage the corrosion
aging mechanism; and
was properly addressed.
The inspectors passed these concerns to individuals in the engineering and regulatory affairs
departments, but the licensee then stated that the evaluations provided on March 1, were, in
actuality, still in a revision/review phase. The licensee stated that the final evaluations would
likely address the inspectors concerns.
On March 22, the inspectors were provided the final evaluations, but it appeared that only
minor changes were made and the inspectors concerns were not addressed. On March 28,
the inspectors again voiced their concerns with the licensee and two new ARs
(501000010169 and 501000010178) were created documenting the following:
- the AR written identifying corrosion of the piping in July of 2015 was not evaluated
under the AMP, the condition was determined to be operable and fully qualified, and it
was closed to a work request to re-coat the piping but was never performed.
- the AR written in April of 2016 again noted the corrosion, but was closed to a
non-conservative evaluation, the issue was not evaluated under the AMP, operability
was again assessed as operable and fully qualified, and a work request was issued to
apply a coating (not completed until May of 2017).
- the AMP engineer was not consulted in 2015 or 2016 to determine if/how the issue fit
into the AMP requirements for increased monitoring, development of acceptance
criteria, and final corrective actions.
Planned Closure Actions: To resolve this item, the inspectors will review planned actions
regarding the degraded 121 DDCLP FOST vent pipe, further extent of condition reviews, and
review planned licensee condition and causal evaluations regarding programmatic and/or
human performance aspects of the issue.
Licensee Actions: At the end of the inspection period, the licensee began excavation
activities to replace the 121 DDCLP FOST vent pipe and had apparent cause and extent of
condition evaluations in progress.
Corrective Action Program References: ARs 501000005894, 501000010169 and
501000010178.
71152AProblem Identification and Resolution
Observation 71152Problem Identification and
Resolution
The inspectors assessment of ACE 500000283593 was that the licensee appeared to focus
on common and contributing causes for various prior issues where engineering rigor was not
satisfactory. Upon completing their review of the ACE, the inspectors questioned whether two
additional examples of an apparent ongoing lack of rigor associated with URIs5000306/2018001-01 and 5000252/2017008-01 discussed above could have been
prevented based on corrective actions taken from the AC
- E. In response, engineering
management acknowledged the underlining apparent causes to be behaviorally based, and
increased mentoring, coaching, and oversight by engineering leadership was ongoing at the
end of the inspection period. The inspectors concluded that ongoing engineering department
initiatives were in place and continuing at the end of the inspection period, and continued
monitoring was appropriate to verify sustainability.
71153Follow-Up of Events and Notices of Enforcement Discretion
Minor Violation 71153Follow-up of Events and
Notices of Enforcement Discretion
Minor Violation: For LER 5000306/2017002-00 Reactor Coolant System Shutdown
Communication Line Vent Through Wall Defect, the inspectors reviewed pictures from
October of 2015 and October of 2017 of boric acid deposits at the upstream side of the socket
weld of valve 2RC-8-37 and the licensees Equipment Cause Evaluation dated
December 13, 2017 (AR 501000003738). Based on this review, boric acid deposits indicative
of leakage existed at this degraded weld location in 2015 and recurred in 2017. The licensee
had not recognized this condition as evidence of an ongoing pressure boundary leak during
this operating period. Based upon discussions with the licensee staff, the inspectors
concluded that leakage of reactor coolant from the socket weld of valve 2RC-8-37 could not
be isolated in Mode 1 using valves upstream because of the high radiation levels and
personnel safety issues (e.g. heat and potentially high pressure steam if a fault progressed to
rupture). Therefore, leakage from a through-wall fault at this location represented pressure
boundary leakage and operation with this type of leakage is prohibited in Modes 1-4 by
Technical Specification Limiting Condition of Operation 3.4.14. The licensee documented this
violation in AR 501000003738, and LER 500306/2017002-00.
Screening: The portion of the reactor coolant pressure boundary affected by this leak was
part of the Code Class 1 pressure boundary and the faulted location did not affect the
functional capability of any safety system since the leak was very small and within the
capacity of the charging system. Therefore, the inspectors applied the IMC 0612 Appendix B
Issue Screening process and answered no to the more than minor questions for this
violation because the licensee determined that no loss of safety functions occurred.
Violation: Failure to comply with TS LCO 3.4.14 associated with past operation of Unit 2 with
pressure boundary leakage constitutes a minor violation that is not subject to enforcement
action in accordance with the NRCs Enforcement Policy.
Licensee Identified Non-Cited Violation 71153Follow-up of Events and
Notices of Enforcement Discretion
This violation of very low safety significant was identified by the licensee and has been
entered into the licensee corrective action program and is being treated as a Non-Cited
Violation, consistent with Section 2.3.2 of the Enforcement Policy.
Enforcement:
Violation: Prairie Island Technical Specification 3.0.4 states, in part, that when an LCO is not
met, entry into a MODE or other specified condition in the Applicability shall only be made
when the associated ACTIONS to be entered permit continued operation in the MODE or
other specified condition in the Applicability for an unlimited period of time.
Contrary to the above, at 0303 hours0.00351 days <br />0.0842 hours <br />5.009921e-4 weeks <br />1.152915e-4 months <br /> on November 12, 2017, during startup activities from a
Unit 2 refueling outage, the licensee entered MODE 4 with both containment spray pump
control switches in pull-out and therefore not OPERABLE as required by LCO 3.6.5 that
required two containment spray trains OPERABLE in MODE 4.
Significance/Severity Level: The finding was of very low safety significance (Green) because
it did not degrade the ability to close or isolate containment and did not degrade the physical
integrity of reactor containment.
Corrective Action Program Reference: AR 501000005299.
EXIT MEETINGS AND DEBRIEFS
The inspectors confirmed that proprietary information was controlled to protect from public
disclosure. No proprietary information was documented in this report.
results to Mr.
- T. Conboy, Director of Site Operations, and other members of the licensee
staff.
- On April 12, 2018, the inspectors presented the overall quarterly integrated inspection
results to Mr.
- S. Sharp, Site Vice President, and other members of the licensee staff.
THIRD PARTY REVIEWS
The inspectors reviewed World Association of Nuclear Operators/Institute of Nuclear Power
Operations reports that were issued during the inspection period.
DOCUMENTS REVIEWED
71111.01Adverse Weather Protection
AR 501000009559; Trending Oil Results on D5/D6 Rad Fans; 03/16/2018
WO 00356590-02; TP 1676 Annual Meteorological Instruments Calibration; 04/06/2008
TP 1676; Meteorological Instrument Calibration; Revision 10
WO 00357688-01; TP 1677 Monthly Meteorological Instrumentation; 01/14/2009
WO 700011943; D6 Building Ventilation Instruction Calibration; 12/11/2017
AR 501000007124; D5/D6 Diesel Temperature Limit; 01/01/2018
DBD SYS-38A; Design Bases Document for the Emergency Diesel Generator System
AR 501000006819; Seasonal Readiness Program FP-WM-SR-01; 01/02/2018
2C37.10; D5/D6 Diesel Generator Building HVAC; Revision 11
AR 501000007616; PMT Documentation Enhancement; 01/24/2018
AR 501000007584; MET Tower ERCS Points Not Checked; 01/23/2018
71111.04Equipment Alignment
NF-88616-2; Electrical Heat Tracing Isometric Unit 2 Safety Injection Pump Suction;
Revision 75
C1.1.18-2; S1, CS, CA, and HC System Checklist Unit 2; Revision 49
C1.1.20.5-1; Unit 1 4.16kV System Switches and Indication Checklist; Revision 27
C1.1.20.5-2; Unit 2 4.16kV System Switches and Indication Checklist; Revision 29
Heating, Ventilating & Air Conditioning Project 2121-7594 (R/E 6197); Revision 0
NE-40009; Annulus Vent Recirculation Fan Discharge Damper; Sheet 144; Revision CY
C37.5; Screenhouse Normal Ventilation; Revision 9
AR 501000007481; NRC Question on 12 and 22 DD Clg Pump; 01/19/2018
FP-R-LIC-06; NRC Question Response Form-Outside Temperature; 01/2018
AR 501000007044; 11 CL PMP Packing Smoke; 01/06/2018
AR 501000007050; 21 Cooling Water Pump Packing Warm; 01/08/2018
AR 501000006858; Emrg Gen Bldg FO Tank Rm Htr Not Working; 01/03/2018
AR 501000007185; Expectations for Accuracy of Documentation; 01/11/2018
AR 501000007092; 47019-0506 Alarm upon 121 Pump Start; 01/10/2018
71111.05AQFire Protection Annual/Quarterly
Appendix A; Fire Detection Zone 11; Revision 35F5
Appendix F; Table 6-1 Fire Hazards Analysis Matrix FireArea 41A; Revision 34F5
F5 Appendix KFire Protection Systems Functional Requirements; Diesel Driven Cooling
Water Pumps; Revision 24
AR 501000006871; 2 FBMs Didnt Get 2 Fire Drills in 2017; 01/01/2018
71111.06Flood Protection Measures
H36; Plant Flooding; Revision 11
AWI 8.9.0; Internal Flooding Drainage Control; Revision 20
71111.11Licensed Operator Requalification Program and Licensed Operator Performance
1C1.4; Unit 1 Power Operation; Revision 65
AR 501000007687; Crew Failed Cycle 18A Simulator Eval; 01/24/2018
AR 501000007770; Trend in Simulator Evaluation Failures; 01/25/2018
AR 501000009799; SR RPS Failed RP Cycle 1 Continuing Training; 03/20/2018
LOR Cycle 18B Cycle SIM Session #3Licensed Operator Requalification; Revision 0
71111.12Maintenance Effectiveness
Prairie Island Maintenance Rule Bases Document
FP-E-MR-01; Maintenance Rule Process; Revision 9
FP-E-MR-02; Maintenance Rule Scoping; Revision 10
FP-E-MR-03; Maintenance Rule Monitoring; Revision 7
WO 700005259-0090; NEPA 805 EC 25120 CT12 4kV Breaker Addition; 12/22/2017
WO 00540589; Troubleshoot and Repair BUS 15 Load Sequencer; 11/09/2016
AR 501000007217; Unable to Hang Tags on New Unlabeled Breaker; 01/13/2018
AR 501000004433; Unexpected Plant Response Breaker 25-17; 10/28/2017
AR 501000007689; Bus 26 Relay 27-UV Out of Range; 01/25/2018
AR 1538329; 4kV Disconnect Danger Tag Placement Incorrect; 10/18/2016
AR 1534190; Breaker CT-BT112 Relay Chattering; 09/14/2016
AR 1520596; NRC Question about Breaker 15-4 Cable; 06/22/2016
SP 2322; Safeguards Buses Weekly InspectionOperating; Revision 31
WO 700015558; SP 2322 4.16 kV Safeguards Bus Weekly Inspection
SP 2856; Monthly 4kV Bus 26 Undervoltage Relay Test (Omicron); Revision 6
71111.13Maintenance Risk Assessments and Emergent Work Control
AR 501000007811; D2 Lockout during Slow Start Test; 01/29/2018
AR 501000007845; D2 PMT Plan Improper for Conditions; 01/30/2018
AR 501000008319; Increase in U2 Containment Sump A Operation; 02/14/2018
AR 501000008527; U2 Containment Sump A Consecutive Days Runtime; 02/17/2018
AR 501000008542; U2 Containment Sump A 3 Days With Runtime; 02/18/2018
AR 501000008538; Unit 2 Containment Sump A Pump Runtime; 02/19/2018
AR 501000008620; Unexpected Annunciator 47516-0504; 02/19/2018
AR 501000008640; Unit 2 Containment Sump A Consecutive Run Day #5; 02/20/2018
AR 501000008853; Strong Odor From D6 Serv Pnl 6; 02/26/2018
AR 501000008917; D6 Maintenance Run Issues; 02/27/2018
AR 501000008923; Excitation Voltage and Current on D6; 02/27/2018
AR 501000008950; Abnormal Conditions During D6 Maint Run; 02/27/2018
AR 501000009350; D5 DG Common Cause Documentation; 03/09/2018
1C20.7; D1/D2 Diesel Generators; Page 1 of 108; Revision 48
71111.15Operability Determinations and Functionality Assessments
AR 501000007074; Relay Room Temperature Limit Question; 01/09/2018
AR 501000010535; D1 Bellow POD; 04/09/2018
AR 501000009850; Revise D1 Bellows Crack POD; 03/20/2018
AR 501000010554; POD for 21 Battery Needs Revision; 04/08/2018
AR 501000010411; Safety Battery Lid Crack Identification; 04/05/2018
AR 501000009553; NRC Question on 21 Battery Lids; 03/14/2018
SP 2323; 21 Battery Monthly Inspection; Revision 18
SP 2325; 21 Battery Quarterly Inspection; Revision 18
SP 2337; 21 Battery Semi-Annual Inspection; Revision 22
AR 1184867; Adverse Trend in 11 Battery Jar/Cover Leakage; 06/08/2009
AR 1293335; Hairline Cracks by Sample Tubes on Several Battery Cells; 07/06/2011
AR 1511537; Results of 21 Battery Monthly Inspection; 02/09/2016
AR 1546260; 21 Battery Inspection, SP 2323; 01/03/2017
AR 1558296; 21 Battery Inspection, SP 2323; 05/09/2017
AR 501000008489; Relay 1X/32215 Contacts Sticky; 02/16/2018
AR 726957726957 Engineering Inspection of 21-Battery Found New Cracks on Cell; 06/28/2004
AR 501000009528; D1 Turbocharger Outlet Bellows Leak; 03/15/2018
FP-OP-OL-01; Operability/Functionality Determination; Revision 21
Temporary Modification 601000000504; Temporary Repair of D1 Exhaust Bellows
H59; Periodic Vendor Contact Program; Revision 3
SWI ENG-20; Disposition of Vendor Information; Revision 5
FP-PA-OE-01; Operating Experience Program; Revision 25
FP-PE-PM-01; Preventive Maintenance Program; Revision 20
FP-PA-ARP-01; CAP Process; Revision 52
WO 700027998-0030; Bench Test Motor 121N Relay Rm Unit CLR; 10/10/2017
WO 700027998-0010; Replace Motor 112G-15 and Motor 112G-23; 10/10/2017
D80; Scaffolds Requiring Seismic Consideration-Controlled Access Areas @ 695; Revision 36
71111.18Plant Modifications
AR 501000010178; Aging Management CE Inappropriately Closed; 03/30/2018
AR 501000010169; Response to Degraded FOST Vent Pipe; 03/30/2018
H65.2.14; External Surfaces Monitoring Aging Management Program; Revision 0
PINGP 1516; Walkdown Checklist Mechanical Systems/Components; Revision 5
AR 501000005894; Hole in 122 DDCL Pump Oil Storage TK Vent; 11/28/2017
AR 1487938; DSL Storage Tank Vent Stack Corrosion; 07/30/2015
AR 1519124; Vent Line for 121 Clg Water Pump DSL Oil Storage Tank Corroded; 04/18/2016
71111.19Post Maintenance Testing
D70.1; Motor Operated Valve Testing; Revision 23
WO 700027006-0020; 122 SWGR RM Unit Clr; 03/12/2018
WO 700027009-0010; Replace MTR 222G-19 per EC 21175; 12/29/2017
WO 700027009-0020; Replace MTR 222G-19 Bench Test Motor; 12/07/2017
WO 700027007-0010; Replace MTR 222G-16 (EC 21175); 12/29/2017
WO 700033770-0030; PMT and RTS 2 S/G Steam Flow; 01/19/2018
AR 501000007861; Inadequate PMT for MV-32129 Work Plan; 01/30/2018
5AWI 3.12.4; Post Maintenance Testing; Revision 24
AR 501000002920; D5 Simulator Relays Not Tested in PMT; 11/30/2017
WO 700033770-0010; Replace Analog Output Q Card Slot 6; 01/19/2018
AR 501000007542; Worn Connecting Rod on MD-32429; 01/21/2018
AR 501000007428; 22 S/G STM Flow 2FI-475 Failed; 01/19/2018
WO 700028081-0020; Benchtest Motor; 10/10/2017
WO 700027998-0020; Benchtest Motor 121 N Relay Room Unit CLR; 10/10/2017
WO 700028082-0020; Benchtest Motor 121 N Relay Room Unit CLR; 10/10/2017
AR 501000006972; Incorrect Bench Test Info Documented; 01/05/2018
AR 501000006985; Incorrect Bench Test Info Documented; 01/05/2018
71111.22Surveillance Testing
WO 700011438; SP 1073A-Train A Shield Building Vent Test; 02/01/2018
SP 1073AMonthly Train A Shield Building Ventilation System Test; Revision 14
SP 1106B; 22 Diesel Cooling Water Pump Monthly Test; Revision 93
WO 700021965; SP 1106B 22 Diesel CL PMP Monthly; 03/23/2018
SP 2116; Monthly Power Distribution MAP U2; 01/15/2018
AR 501000008026; MD-32215 Green IL Not Lit After SP 1073A; 02/06/2018
71114.06Drill Evaluation
LOR Cycle 18A Licensed Operator Requalification; Revision 0
71124.03In-Plant Airborne Radioactivity Control and Mitigation
Self-Assessment; 6SAR01554468; 02/02/2018 Licensed Operator Respiratory Protection
Eyeglass Records; Current Records
C40.5; Control Room Breathing Air System; Revision 3
RPIP 1214; Respiratory Protection Equipment Testing; Revision 22
RPIP 1215; Respiratory Protection Control; Revision 10
H26; Respiratory Protection Program; Revision 14
Respirator Inspection Checks; 01/2018
Grade D Air Tests; 2016 through 2017
AR 501000007493; Leak on Fire Brigade SCBA; 01/19/2018
AR 501000007262; Large SCBA Mask Staged Vice Medium; 01/15/2018
AR 501000000477; MSA SCBA Cylinder Gauge Incorrect; 07/01/ 2018
AR 1557677; Fitting on SCBA Charging Hose is Leaking; 05/03/2017
AR 1547925; Fire Brigade SCBA Failed Monthly Testing; 01/19/2017
AR 1544020; Breathing Air Sample Lost for November 2016; 12/05/2016
AR 501000008404; Outdated Respirator Canisters; 02/15/2018
AR 501000008440; SCBA Inspection Incomplete; 02/15/2018
71124.04Occupational Dose Assessment
NVLAP Accreditation Program for Mirion Technologies, 07/01/2017-06/30/2018
FP-RP-AM-01; Alpha Monitoring Program; Revision 5
FP-RP-BP-01, Bioassay Program; Revision 7
FPRP-DP-01; Dosimetry Program; Revision 10
FP-RP-IDA-01; Internal Dose Assessment; Revision 3
FP-RP-EDC-01; DMC 2000 S Electronic Dosimeter and IRD 2000 Calibration; Revision 4
RPIP 1107; Fetal Protection Program; Revision 11
RPIP 1115; Area TLD Locations, Emergency Plan TLDs & TLD Change Out; Revision 16
RPIP 1204; Evaluation of Airborne Radioactivity; Revision 22
2017 Prairie Island Isotopic Mix Evaluation; Undated
2017 Annual Area TLD Trending Report; 01/24/2018
2017 TLD Data; Various Records
Declared Pregnant Worker Records; One Record
Technical Basis Document #13-002; ISFSI Cask Neutron Field Evaluation; Revision 1
Technical Basis Document #15-001; Unit 2 Containment Neutron Field Evaluation; Revision 0
TLD/ED Comparison Data and Evaluation; Various Records
Whole Body Count Records; Various Records
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AR 1549796; Personnel Dose in Green Warehouse; 02/07/2017
71151Performance Indicator Verification
Operator Logs, Various, January 1 through December 31, 2017
71152Problem Identification and Resolution
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AR 501000003299; Inaccuracy in Statement Given NRC Resident Inspector; 11/03/2017
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AR 501000006926; QIM 501000004740 POR Assignment; 01/05/2018
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71153Follow-Up of Events and Notices of Enforcement Discretion
AR 501000003738; BACC: 2RC-8-37 Indication of Leakage; 10/16/2017
Flowserve Certificate of Compliance/Conformance; 02/24/2014
Work Task 00532148-01; 10/17/2015
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Work Order # 700028252; 10/19/2017
Liquid Penetrant Examination Report BOP-PT-17-048; 10/16/2017
AR 501000006279; PI&R Issue for 2RC-8-37; 12/11/2017
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
May 9, 2018
Mr. Scott Sharp
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, UNITS 1 AND 2NRC
INTEGRATED INSPECTION REPORT 05000282/2018001
AND 05000306/2018001
Dear Mr. Sharp:
On March 31, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection
at your Prairie Island Nuclear Generating Plant, Units 1 and 2. On April 12, 2018, 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.
Based on the results of this inspection, the NRC inspectors documented a licensee-identified
violation which was determined to be of very low safety significance in this report. The NRC is
treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the
If you contest the violation or significance of the NCV, you should provide a response within
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 the Prairie Island Nuclear Generating Plant.
S. Sharp -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 10 CFR 2.390, Public Inspections, Exemptions, Requests for
Withholding.
Sincerely,
/RA/
Kenneth Riemer, Chief
Branch 2
Division of Reactor Projects/Safety
Docket Nos. 50-282; 50-306;72-010
License Nos. DPR-42; DPR-60; SNM-2506
Enclosure:
IR 05000282/2018001; 05000306/2018001
cc: Distribution via LISTSERV
S. Sharp -3-
Letter to
SUBJECT: PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2NRC
INTEGRATED INSPECTION REPORT 05000282/2018001
AND 05000306/2018001