IR 05000282/2022002
| ML22340A531 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island, 05000360  |
| Issue date: | 12/08/2022 |
| From: | Laura Kozak NRC/RGN-III/DORS/RPB3 |
| To: | Domingos C Northern States Power Company, Minnesota |
| References | |
| IR 2022002 | |
| Download: ML22340A531 (1) | |
Text
December 8, 2022
SUBJECT:
RE-ISSUE - PRAIRIE ISLAND NUCLEAR GENERATING PLANT - INTEGRATED INSPECTION REPORT 05000282/2022002 AND 05000306/2022002
Dear Mr. Domingos:
The U.S. Nuclear Regulatory Commission (NRC) identified that the inspection report sent to you on August 11, 2022 (ML22222A173), contained minor errors in the documentation of the inspection finding and violation. We corrected the minor errors and are issuing the report in its entirety. These changes do not affect the technical content of the report.
On June 30, 2022, the NRC completed an inspection at Prairie Island Nuclear Generating Plant.
On July 22, 2022, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.
One finding of very low safety significance (Green) is documented in this report. This finding involved a violation of NRC requirements. We are treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or the significance or severity of the violation documented in this inspection report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; the Director, Office of Enforcement; and the NRC Resident Inspector at Prairie Island Nuclear Generating Plant.
If you disagree with a cross-cutting aspect assignment in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region III; and the NRC Resident Inspector at Prairie Island Nuclear Generating Plant. 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, Signed by Kozak, Laura on 12/08/22 Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Docket Nos. 05000282 and 05000306 License Nos. DPR-42 and DPR-60
Enclosure:
As stated
Inspection Report
Docket Numbers: 05000282 and 05000306 License Numbers: DPR-42 and DPR-60 Report Numbers: 05000282/2022002 and 05000306/2022002 Enterprise Identifier: I-2022-002-0054 Licensee: Northern States Power Company Facility: Prairie Island Nuclear Generating Plant Location: Welch, Minnesota Inspection Dates: April 01, 2022, to June 30, 2022 Inspectors: S. Bell, Health Physicist K. Pusateri, Resident Inspector D. Tesar, Senior Resident Inspector Approved By: Laura L. Kozak, Acting Chief Reactor Projects Branch 3 Division of Operating Reactor Safety Enclosure
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Prairie Island Nuclear Generating Plant, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information.
List of Findings and Violations
Failure to Complete Required Inservice Testing Prior to Restoring Equipment to Operation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.15 Systems NCV 05000282,05000306/2022002-01 Conservative Open/Closed Bias The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.55a, "Codes and Standards" for the failure to meet the inservice testing requirements set forth in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (O&M) Code and Addenda for failure to complete required testing prior to returning equipment to operation following maintenance on the 22 diesel driven cooling water pump (DDCLP).
Additional Tracking Items
None.
PLANT STATUS
Unit 1 operated at or near rated thermal power for the entire inspection period.
Unit 2 operated at or near rated thermal power for the entire inspection period.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed activities described in IMC 2515, Appendix D, Plant Status, observed risk significant activities, and completed on-site portions of IPs. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
REACTOR SAFETY
71111.01 - Adverse Weather Protection
External Flooding Sample (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated that flood protection barriers, mitigation plans, procedures, and equipment are consistent with the licensees design requirements and risk analysis assumptions for coping with external flooding on May 3, 2022.
71111.04 - Equipment Alignment
Partial Walkdown Sample (IP Section 03.01) (3 Samples)
The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:
- (1) Unit 1 B train safety injection system on April 22, 2022
- (2) 122 control room ventilation returned to service on May 26, 2022
- (3) Instrument air system walkdown on May 26, 2022
71111.05 - Fire Protection
Fire Area Walkdown and Inspection Sample (IP Section 03.01) (4 Samples)
The inspectors evaluated the implementation of the fire protection program by conducting a walkdown and performing a review to verify program compliance, equipment functionality, material condition, and operational readiness of the following fire areas:
- (1) Fire Zone 43, bus 111 and 121 switchgear rooms on April 4, 2022
- (2) Fire Zone 19, Unit 1 auxiliary building, elevation 715' on April 7, 2022
- (3) Fire Zone 26, bus 112 and train A event monitoring rooms, elevation 735' on April 22, 2022
- (4) Fire Zone 96, transformer 2RX on May 3, 2022
71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance
Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)
(1 Sample)
- (1) Observed licensed operator requalification scenarios on May 3, 2022
71111.13 - Maintenance Risk Assessments and Emergent Work Control
Risk Assessment and Management Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the accuracy and completeness of risk assessments for the following planned and emergent work activities to ensure configuration changes and appropriate work controls were addressed:
- (1) 2RY transformer work on April 25, 2022
- (2) 12 electro-hydraulic oil pump leak (potential Initiating Event) on May 2, 2022
- (3) Unit 2 turbine oil cooler 2CL-27-4 on April 25, 2022
on May 24, 2022
- (5) 12 CFCU inoperability not MRFF on May 5, 2022
- (6) Work Week 2219 SI pump risk on May 10, 2022
- (7) Corrective action program (CAP) 501000063397 11, "Condensate Storage Tank Leaking," on May 27, 2022
71111.15 - Operability Determinations and Functionality Assessments
Operability Determination or Functionality Assessment (IP Section 03.01) (6 Samples)
The inspectors evaluated the licensee's justifications and actions associated with the following operability determinations and functionality assessments:
- (1) SP 2284, "CV-31733 Closing Time Outside of REF," on April 13, 2022
- (2) AR 501000062700, "122 Control Room Air Handler," on May 2, 2022
- (3) 12 CFCU unplanned inoperability on May 5, 2022
- (4) Work Order 700097233, "D5 Ruskin Damper Positioner Replacement," on June 6, 2022
- (5) 22 DDCLP Comprehensive Test Not Performed on April 5, 2022
- (6) D5 rack differential detector CAP 501000064219
71111.18 - Plant Modifications
Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)
(2 Samples)
The inspectors evaluated the following temporary or permanent modifications:
- (1) 122 safeguards traveling screen T-MOD on May 11, 2022
- (2) 11 condensate storage tank leak repairs on May 27, 2022
71111.19 - Post-Maintenance Testing
Post-Maintenance Test Sample (IP Section 03.01) (7 Samples)
The inspectors evaluated the following post-maintenance testing activities to verify system operability and/or functionality:
- (1) Post-maintenance testing (PMT) of MV-32033 on April 28, 2022
- (2) 11 charging pump PMT on May 25, 2022
- (5) 22 charging pump PMT on June 8, 2022
71111.22 - Surveillance Testing
The inspectors evaluated the following surveillance testing activities to verify system operability and/or functionality:
Surveillance Tests (other) (IP Section 03.01) (5 Samples)
- (2) SP 2334, "D5 Emergency Diesel Generator 24 Hour Load Test," on May 1, 2022
- (3) SP 2295, "D5 Diesel Generator 6-Month Fast Start Test," on May 1, 2022
Inservice Testing (IP Section 03.01) (1 Sample)
on May 26, 2022 Containment Isolation Valve Testing (IP Section 03.01)
SP 2284, "RCDT Vent Header Containment Isolation Valves Quarterly Test," on April 13,
RADIATION SAFETY
71124.01 - Radiological Hazard Assessment and Exposure Controls
Radiological Hazard Assessment (IP Section 03.01) (1 Partial)
(1) (Partial)
The inspectors evaluated how the licensee identifies the magnitude and extent of alpha radiation levels and the concentrations and quantities of radioactive materials and how the licensee assesses radiological hazards.
71124.03 - In-Plant Airborne Radioactivity Control and Mitigation
Permanent Ventilation Systems (IP Section 03.01) (1 Sample)
The inspectors evaluated the configuration of the following permanently installed ventilation systems:
- (1) Radioactive waste building ventilation system
Temporary Ventilation Systems (IP Section 03.02) (1 Sample)
The inspectors evaluated the configuration of the following temporary ventilation systems:
- (1) Temporary HEPA ventilation system on the decontamination booth 695' auxiliary building
Use of Respiratory Protection Devices (IP Section 03.03) (1 Sample)
- (1) The inspectors evaluated the licensees use of respiratory protection devices.
Self-Contained Breathing Apparatus for Emergency Use (IP Section 03.04) (1 Sample)
- (1) The inspectors evaluated the licensees use and maintenance of self-contained breathing apparatuses.
71124.04 - Occupational Dose Assessment
Source Term Characterization (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated licensee performance as it pertains to radioactive source term characterization.
External Dosimetry (IP Section 03.02) (1 Sample)
- (1) The inspectors evaluated how the licensee processes, stores, and uses external dosimetry.
Internal Dosimetry (IP Section 03.03) (2 Samples)
The inspectors evaluated the following internal dose assessments:
- (1) Two internal dose assessments dated 10/19/2021
- (2) One internal dose assessment dated 04/23/2020
Special Dosimetric Situations (IP Section 03.04) (3 Samples)
The inspectors evaluated the following special dosimetric situations:
- (1) Declared pregnant worker records dated 04/01/2020
- (2) Declared pregnant worker records dated 03/05/2020
- (3) Declared pregnant worker records dated 09/23/2021
71124.06 - Radioactive Gaseous and Liquid Effluent Treatment
Walkdowns and Observations (IP Section 03.01) (4 Samples)
The inspectors evaluated the following radioactive effluent systems during walkdowns:
- (1) Turbine building sump effluent compositor and associated sampling lines
- (2) 1R19 and 2R19 steam generator blowdown effluent monitors and sample lines
- (3) 1R18 liquid waste discharge monitor and associated sample lines
- (4) Unit 1 auxiliary building ventilation system including the 1R30 and 1R37 effluent monitors
71124.07 - Radiological Environmental Monitoring Program
Environmental Monitoring Equipment and Sampling (IP Section 03.01) (1 Sample)
- (1) The inspectors evaluated environmental monitoring equipment and observed collection of environmental samples (air samples, water samples and TLD locations).
OTHER ACTIVITIES - BASELINE
===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:
BI02: RCS Leak Rate Sample (IP Section 02.11) ===
- (1) Unit 1 (April 1, 2021, through March 31, 2022)
- (2) Unit 2 (April 1, 2021, through March 31, 2022)
71152A - Annual Follow-up Problem Identification and Resolution Annual Follow-up of Selected Issues (Section 03.03)
The inspectors reviewed the licensees implementation of its CAP related to the following issues:
- (1) The inspectors reviewed the completed corrective actions associated with voids in the Residual Heat Removal (RHR) system in the Mitigating Systems Cornerstone. The inspectors determined if the corrective actions had been completed as documented in the CAP.
71152S - Semiannual Trend Problem Identification and Resolution Semiannual Trend Review (Section 03.02)
- (1) The inspectors reviewed the licensees CAP for potential adverse trends in Operability Determinations that might be indicative of a more significant safety issue.
INSPECTION RESULTS
Failure to Complete Required Inservice Testing Prior to Restoring Equipment to Operation Cornerstone Significance Cross-Cutting Report Aspect Section Mitigating Green [H.14] - 71111.15 Systems NCV 05000282,05000306/2022002-01 Conservative Open/Closed Bias The inspectors identified a Green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.55a, "Codes and Standards" for the failure to meet the inservice testing requirements set forth in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (O&M) Code and Addenda for failure to complete required testing prior to returning equipment to operation following maintenance on the 22 diesel driven cooling water pump (DDCLP).
Description:
On Saturday, March 26, 2022, the licensee performed routine maintenance on the 22 DDCLP. Upon completion of the maintenance, the licensee performed Post-Maintenance Testing (PMT) as specified in the Work Order (WO) by completing the quarterly portion of SP 1106B, "22 Diesel Cooling Water Pump Monthly Test," [performed at 9000 gpm] and declared the 22 DDCLP as operable.
On Monday, March 28, 2022, the Inservice Testing (IST) Engineer initiated CAP 501000061742, "Comp Not Performed After 22 DDCLP Maint," which identified the following:
1) During the maintenance, the pump was uncoupled [diesel engine uncoupled from right-angle drive] as well as other minor maintenance activities.
2) Per the ASME OM Code Subsection ISTB-3310, "Effect of Pump Replacement, Repair, and Maintenance on Reference Values," "When a reference value or set of values may have been affected by repair, replacement, or routine servicing of a pump, a new reference value or set of values shall be determined in accordance with ISTB-3300, or the previous value reconfirmed by a comprehensive or Group A test run before declaring the pump operable."
3) IST [group] was also not given a review of the WO prior to maintenance.
Subsequently, station personnel reviewed the corrective action program (CAP) initiated by the IST Engineer and made the determination through their operability process to return the DDCLP to operation based upon the data obtained from the quarterly surveillance test performed as the PMT on March 26, 2022.
The inspectors, on March 29, questioned whether it was appropriate to return the DDCLP to service, given that there was a reasonable potential for the reference values to have changed due to the maintenance performed. Therefore, the conservative action should have been to verify the applicable reference values for the pump prior to returning it to service.
Title 10 CFR 50.55(a)(1)(iv) incorporates by reference the ASME O&M Code. O&M Code subsection ISTB-3000 "General Testing Requirements," specifies the inservice testing requirements which are to be completed in accordance with (IAW) Table ISTB-3000-1. The IST required data applicable to the 22 DDCLP per Table ISTB-3000-1 are, differential pressure, flow rate, and vibration measurements.
ISTB-3540, "Vibration" - ISTB-3540(b) specifies further requirements in that, "Vibration measurements shall be taken on the upper motor bearing housing in three approximately orthogonal directions, one of which is the axial direction."
By letter L-PI-14-015 dated April 09, 2014, Prairie Island Nuclear Generating Plant (PINGP)submitted Relief Request RR-03 seeking relief from code requirement ISTB-3540(b) which required that vibration measurements be taken on the upper motor-bearing housing in three approximately orthogonal directions, one of which must be in the axial direction. In lieu of this code requirement, PINGP proposed as an alternative to take vibration measurements on the right-angle drive in three orthogonal directions, one of which being in the axial direction, as well as one additional vibration measurement to be taken on each of the diesel engines. The NRC approved this relief request by response dated December 5, 2014 (ML14329A185).
As indicated in the CAP, ISTB-3310, "Effects of Pump Replacement, Repair, and Maintenance on Reference Values," requires that:
ISTB-3312, "When a reference value or set of reference values may have been affected by repair or routine maintenance, other than that covered under ISTB-3311, the following shall be performed before declaring the pump operable:
(a)A Group A or comprehensive test shall be performed and
- (1) The previous reference values reconfirmed or
- (2) A new reference value, or set of reference values, shall be determined in accordance with ISTB-3300."
The inspectors identified that because the diesel engine and right-angle drive were uncoupled and re-coupled during the maintenance, and that each of these components are locations for IST vibration data collection, that the potential existed that "a reference value or set of reference values may have been affected" by the maintenance activity. One of the purposes of performing the comprehensive test is to ensure that no unintended flaws or consequences were introduced during the performance of the maintenance. Therefore, the inspectors determined that the requirements of ISTB-3312(a)(1) (Subsection ISTB-3310) would apply to this maintenance activity, and a comprehensive test was required to have been performed prior to restoring the pump to operation.
In addition, licensee procedure H10.1 "ASME Inservice Testing Program" Section 5.6, "Establishing a New Reference Value for Pump Testing", quotes ASME OM Code, ISTB-3310 "When a reference value or set of values may have been affected by repair, replacement, or routine servicing of a pump, a new reference value or set of values shall be determined in accordance with ISTB-3300, or the previous value reconfirmed by a comprehensive or Group A test run before declaring the pump operable." Step 5.6.4 further requires that "The minimum USAR flow required for accident mitigation [10,400 gpm] shall be the limiting acceptance criteria for operability. If the flow is less than the USAR requirement, then the pump shall be declared inoperable, and the appropriate LCO condition entered."
Subsequently, on Wednesday March 31, 2022, the licensee took actions to perform the IST comprehensive pump test per the applicable portions of SP 1106B, "22 Diesel Cooling Water Pump Monthly Test." The results of this test indicated that the vibration data was similar to what was seen prior to the maintenance.
Corrective Actions: CAP 501000061742, "Comp Not Performed After 22 DDCLP Maint"
Performance Assessment:
Performance Deficiency: The licensee's failure to perform inservice testing IAW regulatory requirements in 10 CFR 50.55a, O&M Code Section 3310, and in accordance with their prescribed procedure (H10.1, "Inservice Testing") prior to returning the equipment to operation was a Performance Deficiency.
Screening: The inspectors determined the performance deficiency was more than minor because it was associated with the equipment performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors reviewed Inspection Manual Chapter 0612 App E, "Examples of Minor Issues, and determined that this issue was most closely related to example 2.b. The inspectors determined that the violation was more than minor because the performance deficiency was associated with the equipment performance attribute of the mitigating systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the licensee failed to complete the required in-service testing prior to returning the equipment to operation.
Significance: The inspectors assessed the significance of the finding using IMC 0609 Appendix A, The Significance Determination Process (SDP) for Findings At-Power. The violation was determined to be of very low safety significance and screened to Green because inspectors answered all screening questions as "no".
Cross-Cutting Aspect: H.14 - Conservative Bias: Individuals use decision making-practices that emphasize prudent choices over those that are simply allowable. A proposed action is determined to be safe in order to proceed, rather than unsafe in order to stop. The licensee failed to use conservative decision-making following initiation of CAP which identified that the O&M Code required performance of the comprehensive test prior to returning the equipment to operation. The licensee only performed the quarterly surveillance test to return the pump to operation. Following the CAP initiation, the licensee declared the equipment Operable and considered it available to perform its specified safety function but did not perform any kind of additional Engineering Evaluation.
Enforcement:
Violation: Title 10 CFR 50.55(a)(1)(iv) requires, in part, "When a reference value or set of values may have been affected by repair, replacement, or routine servicing of a pump, a new reference value or set of values shall be determined in accordance with ISTB-3300, or the previous value reconfirmed by a comprehensive or Group A test run before declaring the pump operable."
Contrary to the above, on March 26, 2022, the licensee returned the 22 DDCLP to operation following maintenance without completing the comprehensive pump test run.
Enforcement Action: This violation is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.
Observation: Annual Review of Residual Heat Removal Voids Found After 2R32 71152A Refueling Outage Inspectors selected Unit 2 residual heat removal (RHR) voiding long term actions for this annual follow-up sample to evaluate the timely disposition of this operability issue and ensure that corrective actions are commensurate with the safety significance. Inspectors reviewed the corrective action program (CAP) documents associated with a series of voids found following the 2R32 refueling outage. The significance of the voids was that in some cases the size of particular voids found exceeded the operability limits listed in procedure H64, Gas Accumulation Management Program. The licensee was able to perform Operability Evaluations to determine that the voids were acceptable to maintain reasonable assurance of operability.
The licensee determined this potential gaseous intrusion mechanism was related to chemical additions to the RHR system while it was aligned in Shutdown Cooling Mode.
The licensee created actions in the CAP to revise procedures to minimize the amount of gas left in the system following Shutdown Cooling Mode. The licensee created corrective actions to perform more void inspections during subsequent outages and to have engineering ensure both RHR pumps operate prior to plant heat-up after an outage.
Inspectors noted that corrective actions associated with changing the fill and vent procedures following an outage were closed to the procedure change requests (PCRs) but then those PCRs were subsequently cancelled. The licensee as part of their normal review process, plans to review the PCRs and add justification for the cancellation.
Since all actions are not completed and the licensee has not gone through another refueling outage, the inspectors cannot yet assess the adequacy and effectiveness of all the corrective actions.
The licensee-initiated CAP 501000064413 which created a tracking action for completion of the PCRs. The CAP has not been closed by the licensee so there is an opportunity to assess the effectiveness of all the corrective actions prior to the next RFO and CAP closure.
No findings or violations were identified during the review.
Observation: Trend Review of ASME O&M Code Compliance 71152S Inspectors reviewed Operability determinations associated with the American Society of Mechanical Engineers (ASME) Code compliance for trending. Two examples were identified for evaluation as follows:
On October 27, 2021, a corrective action program (CAP) 501000057742, "SP 2269 Performed UNSAT," was initiated by the licensee to document the failure of 2SI-6-4 to pass its in-service testing acceptance criteria. The station performed an Operability Determination (CAP 501000057644, 500000316013) and concluded that "Valve 2SI-6-4 is not fully qualified.
This is due to not meeting the leakage criteria established per the IST Code. This condition does not affect the ability of 2SI-6-4 to perform its specified safety functions....," the licensee concluded that 2SI-6-4 was "Operable."
On October 28, 2021, CAP 501000057820, "Operability Process and Regulatory Requirements," was initiated by the licensee (and related to CAP 501000057742) to document in part, that the fleet procedure FP-OP-OL-01 for Operability was updated to incorporate guidance from NEI 18-03, "Operability Determination." The guidance was not endorsed by the NRC. The CAP also documented that "the regulatory aspect of how compliance with 10 CFR 50.55a is maintained still needs to be addressed."
As documented in Inspection Report 2021-004, the NRC identified "... a green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR)
Part 50.55a(f)(4) for the failure to meet the in-service testing requirements set forth in the American Society of Mechanical Engineers (ASME) Operations and Maintenance Code and Addenda after Check Valve 2SI-6-4 exceeded its ASME Code leakage acceptance criteria..."
On March 28, 2022, CAP 501000061742, "Comp Not Performed After 22 DDCLP Maintenance," was initiated to document the failure to perform the comprehensive test on the 22 diesel driven cooling water pump (DDCLP) following maintenance in accordance with the ASME operation and maintenance (O&M) Code requirements.
As documented in this inspection report (2022-002), the NRC identified "... a green finding and associated non-cited violation of Title 10 of the Code of Federal Regulations (10 CFR)
Part 50.55a, "Codes and Standards" for the failure to meet the in-service testing requirements set forth in the American Society of Mechanical Engineers (ASME) Operations and Maintenance (O&M) Code and Addenda for failure to complete required testing prior to returning equipment to operation following maintenance on the 22 diesel driven cooling water pump (DDCLP)."
On June 20, 2022, CAP 501000064047, "2SI-6-4 and FP-OP-OL-01," was initiated. This CAP identified that during the 2022 in-service testing focused self-assessment, "It was identified that there is currently no procedure guidance in FP-OP-OL-01 or other actions in place to prevent recurrence." (allowing the plant to move forward in power ascension without following the ASME OM Code)
The inspectors reviewed the above issues and identified differences in the Xcel Energy Fleet Procedure FP-OP-OL-01, "Operability" and NRC Inspection Manual Chapter 0326 "Operability Determinations" with respect to code compliance and operability. Subsequently, the licensee-initiated fleet CAP 501000065231, "NRC insight on IMC-0326 v FP-OP-OL-01".
Inspectors reviewed the CAPs and actions listed above and determined that at the time of review, there were no actions in place to address the differences between licensee procedures, NRC Inspection Manuals, and compliance with 10 CFR 50.55a Code Requirements. CAP 501000057820 had an action to provide training which was documented as complete in January of 2022; however, this action does not appear to have been effective based upon the events which occurred on March 28, 2022. CAP 501000064047 was initiated after the inspectors had started their trend review, and this CAP does capture the observations of the inspectors. Actions being implemented in this CAP may resolve the identified gaps, however, since the actions had not yet been created, inspectors were unable to assess their overall adequacy.
No new findings or violations were identified during this trend review.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
On July 22, 2022, the inspectors presented the integrated inspection results to Mr. C. Domingos, Site Vice President, and other members of the licensee staff.
On June 22, 2022, the inspectors presented the radiation protection baseline inspection results to Mr. S. Skoyen, Acting Plant Manager, and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection Type Designation Description or Title Revision or
Procedure Date
71111.01 Procedures CY-ENVR-003 Three Day Flood Forecast Reporting 6
SP 1293 Inspection of Flood Control Measures 27
Work Orders WO 700083238- SP 1293 Annual Inspection of Flood Contr 06/02/2022
0010
71111.04 Calculations M-385-FP-001 Analysis of Record and Engineering Calculations for Cardox 2
Piping Equivalent Length
Drawings NF-39244 Flow Diagram Instrument Air Piping Unit 1 & 2 98
Procedures C1.1.35-3 Checklist for Cooling Water System 45
71111.05 Fire Plans F5 Appendix A Fire Detection Zone 26, Bus 112 & Train A Event Monitoring 46
Rooms El. 735'
F5 Appendix A Fire Detection Zone 43 46
F5 Appendix A Fire Detection Zone 19 46
F5 Appendix A Fire Detection Zone 96 Transformer 2RX 46
Miscellaneous NFPA No. 12- Standard of Carbon Dioxide Extinguishing Systems 1972
1972
QF0739, NRC Pertaining to ENG-ME-804 CO2, Concentration in the Relay 0
Question and Cable Spreading Room Attachment 10.1 Retrotec Final
Response, CAP Report Cardox Validation Project
501000063724
71111.13 Engineering EC 11 CST: Temp Clamp for Thru-Wall Leak 0
Changes 601000003804
Procedures SP 2857 4KYV Bus 21/22 Undervoltage and Underfrequency Relay 1
West (Omicron)
Work Orders WO 700106197- Replace O-Rings/Seals on Flex Hose Fittings 05/01/2022
0010
71111.15 Calibration ENG-ME-804 CO2 Concentration in the Relay Room and Cable Spreading 0
Records Room
Corrective Action AR Comp Not Performed after 22 DDCLP Maint 03/29/2022
Documents 501000061742
Engineering EC Revise SP 1091 Monthly Containment Fan Coils Units 05/06/2022
Changes 602000018704 Surveillance Test
Inspection Type Designation Description or Title Revision or
Procedure Date
Miscellaneous API Standard 650 Welded Steel Tanks for Oil Storage September
2003
API Standard 653 Tank Inspection, Repair, Alternation, and Reconstruction September
2003
C1.1.19-4 Containment and Shield Building Penetration Checklist - Unit 53
H10.1 ASME Inservice Testing Program 42
H10.1.B Inservice Testing Program Component Basis Document 6
OMN-16 ASME Code Case OMN-16 - Use of a Pump Curve for 2
Testing
QF0739, NRC Requested API 650 and API 653 06/02/2022
Question
Response Form
Operability CV-31733 / SP IST 96 Hour Evaluation 04/13/2022
Evaluations 2284 / WO 700099357
Procedures FP-OP-OL-01 Operability 22
SP 2284 RCDT Vent Header Containment Isolation Valves Quarterly 20
Test
TP 1806 122 Control Room Chiller Inspection 18
71111.18 Drawings Drawing NF- Flow Diagram Condensate System Unit 1 82
220
Drawing XH-74- General Plan 30-29 High Dome Roof 76
71111.19 Procedures GMP GREE-001 CVCS Suction Stabilizer Maintenance 6
GMP SULL-001 SULLAIR Station Air Compressor 1000 Hour Preventative 9
Maintenance
PE MCC-G7 MCC Electrical Preventive Maintenance for GE 7700 Line 44
MCCS
Work Orders WO 700025194 PE-121C-16 BKR PM, 2TB LP B CL HDR MV-320 04/28/2022
WO 700089255 245-042 SPD Reducer Oil Chang Smpl 06/08/2022
WO 700093503 22 CHG PMP CVCS SUCT STABLZR MAINT 03/19/2022
WO 700096494 PMT 125 STA AIR COMPR 1000 HR PM 05/25/2022
WO 700096494 GMP SULL-001-125 STA AIR CMPR 1000 HR PM 05/28/2022
Inspection Type Designation Description or Title Revision or
Procedure Date
WO 700096614 MD-32421 Insp. and Adjust Ruskin SR MD 05/28/2022
WO 700097233 21 D5 DSL RM OA (MD-32420) RPLC POSNR 06/07/2022
WO 700097663 MD-32422 Insp & Adjust Ruskin SR M 06/16/2022
WO 700097663 MD-32422 Insp &n Adjust Ruskin SR M 06/16/2022
71111.22 Procedures SP 1110B Train B Turbine Cooling Water Header Isolation Valves 7
Quarterly Test
SP 2088A Train A Safety Injection Quarterly Test 37
SP 2284 RCDT Vent Header Containment Isolation Valves Quarterly 20
Test
SP 2295 D5 Diesel Generator 6 Month Fast Start Test 57
SP 2307 D6 Diesel Generator 6 Month Fast Start Test 51
SP 2334 D5 Diesel Generator 24 Hour Load Test 24
SP 2857 4kV Bus 21/22 Undervoltage and Underfrequency Relay 1
Test (Omicron)
Work Orders WO 700092735 SP2334 - D5 DG 24 Hour Load Test 03/04/2022
WO 700095690 SP 111OB TRN B CL HDR ISOL VLVS TEST 04/28/2022
WO 700096197 SP 2857 Bus 21/22 Undervolt Omicron 05/23/2022
WO 700097314 SP2295 D5 DG 6MO Fast Start Test 05/01/2022
WO 700099357 SP2284 RCDT VENT HDR CTMT ISOL VLVS QTR 04/12/2022
WO 700099357 SP 2284 RCDT Vent HDR CTMT Isolation Valves Qtr 03/23/2022
WO 700105218 SP2307 D6 DG Fast Start Test 05/23/2022
71124.01 Corrective Action 501000062752 Alpha Analysis 05/03/2022
Documents
Resulting from
Inspection
Engineering Prairie Island Plant Alpha Characterization Study 11/26/2021
Evaluations
Radiation 2R32 Refueling Outage Radiation Surveys Various
Surveys
71124.03 ALARA Plans 2R32 Refuel Work Radiation Protection Job Plan 09/28/2021
Miscellaneous Four Quantitative Respirator Mask Fit Tests 05/02/2022
Respiratory Protection Qualification Records for Day Shift Various
Reactor Operators and Senior Reactor Operators for May 4,
Inspection Type Designation Description or Title Revision or
Procedure Date
22
Annual SCBA Tests for Units LAD090896 and LAD090890 07/13/2021
43525-0 Breathing Air Tests December 2021 12/09/2021
4433895-0 and Breathing Air Checks for November 2021 11/15/2021
433653-1
Procedures FP-RP-RPP-02 Respirator Fit Testing and Portacount Fit Tester Operation 1
RPIP 1604 Breathing Air Test 17
Self-Assessments Inspection Procedure 71124.03 Undated
Work Orders 7000680170020 12 Shield Building Ventilation Filter Removal Efficiency Test 08/18/2020
71124.04 Corrective Action 501000047700 Improper Area TLD Changeout 01/23/2021
Documents 501000050416 Dose Discrepancies for Period 2, 2020 04/16/2021
Engineering 17-005 Technical Basis Document Passive Monitoring Capability 11/05/2019
Evaluations Testing
SSA 2019 Prairie Island Isotopic Mix Evaluation Undated
606000001052
SSA 2021 Prairie Island Isotopic Mix Evaluation Undated
606000001454
Miscellaneous Three Declared Pregnant Worker Records Various
21 Annual Area TLD Trending 02/21/2022
Period 2 (July - December) 2021 Dosimetry Data Undated
Mirion Technologies Inc., Oak Ridge TN, NVLAP
Accreditation for 07/01/2021 through 06/30/2022
Period 2 (July through December 2021). 2021 Dose Various
Discrepancy Reports
Procedures FP-RP-DR-01 Dosimetry Program 15
FP-RP-IDA-01 Internal Dose Assessment 4
Radiation Work 220059 Dose Restricted Individuals 0
Permits (RWPs)
71124.07 Procedures H4 Offsite Dose Calculation Manual 32
RPIP 4721 REMP Air Sampling 22
71152A Miscellaneous 602000018696 Adverse Condition Monitoring Plan for Unit 2 RHR Discharge 01/06/2022
Voids
Operability POD Prompt Operability Determination for Unit 2 Train A RHR 0
Inspection Type Designation Description or Title Revision or
Procedure Date
Evaluations 50100000316297 Piping
18