IR 05000282/2018001

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NRC Integrated Inspection Report 05000282/2018001 and 05000306/2018001
ML18129A181
Person / Time
Site: Prairie Island  Xcel Energy icon.png
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

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;

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 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.

  • On February 16, 2018, the inspectors presented the 71124.03 and 71124.04 inspection

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 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

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