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05000282/FIN-2017002-0330 June 2017 23:59:59Prairie IslandNRC identifiedFailure to Make an 8Hour Report Required by05000306/201700203 10 CFR 50.72(b)(3)(ii)(B)The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.72(b)(3)(ii)(B) due to the licensees failure on March 20, 2017, to report an unanalyzed condition within eight hours of discovery. Specifically, removing the lower latch assembly of a transom above Door 225, a steam exclusion barrier, during maintenance resulted in the inoperability of the Units 1 and 2 safeguards batteries and Auxiliary Feed Water (AFW) systems, and Unit 1 safeguards bus as determined by CAP 1549724.The inspectors determined that the failure to submit a report required by 10 CFR 50.72 for the unanalyzed condition described above was a performance deficiency. The inspectors determined that this issue had the potential to impact the regulatory process based, in part, on the information that 10 CFR 50.72 reporting serves. Since the issue impacted the regulatory process, it was dispositioned through the Traditional Enforcement process. The inspectors determined that this issue was a SL IV violation based on Example 6.9.d.9 in the NRC Enforcement Policy. Example 6.9.d.9 specifically states, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. Because the issue has been evaluated under the Traditional Enforcement process, there was no cross-cutting aspect associated with this violation.
05000282/FIN-2015003-0330 September 2015 23:59:59Prairie IslandLicensee-identifiedLicensee-Identified ViolationTitle 10, CFR Part 50.72(b)(3)(xiii) states, in part, a licensee shall report (notify the NRC as soon as practical and in all cases within 8 hours of the occurrence) any event that results in a major loss of emergency assessment capability. Contrary to this requirement, over the past 3 years, the licensee identified six instances (on August 14, 2012; November 16, 2012; November 18, 2012; November 21, 2012; December 5, 2012; and January 16, 2013) of a failure to report the major loss of emergency assessment capability when the Seismic Monitoring Panel was non-functional for unplanned events. The licensee also identified three instances (on December 14, 2012; September 3, 2014; and September 30, 2014) of a failure to report the major loss of emergency assessment capability when the Seismic Monitoring Panel was non-functional for planned events for greater than 24 hours. The system degradation adversely impacted the sites ability to make an ALERT and a Notice of Unusual Event Emergency Action Level assessment in accordance with PINGP-1575, Emergency Action Level Matrix, and F3-2.1, Emergency Action Level Technical Bases. The licensee entered the issue into the corrective action program as CAP 01472229, OE Review of NRC Event Reports Related to Seismic Monitors, CAP 01472731, Missed Reportability for Seismic Monitor Out of Service, and CAP 01486147, Potential Licensee ID Violation from EP Inspection. The licensee completed the required report to the NRC on April 2, 2015 (Event Number 50948, Seismic Monitor Not Available for Emergency Plan Assessment). The inspectors determined that this issue had the potential to impact the regulatory process based, in part, on the generic communications input that 10 CFR 50.72 reports serve. Since the issue impacted the regulatory process, it was dispositioned through the Traditional Enforcement process. The inspectors determined that this issue was a Severity Level IV violation based upon Section 6.9, Inaccurate and Incomplete Information or Failure to Make a Required Report, example d.9 in the NRC Enforcement Policy. Example d.9 specifically states, A licensee fails to make a report requirement by 10 CFR 50.72 or 10 CFR 50.73. Because the issues were entered into the licensees corrective action program as CAPs 01472229, 01472731, and 01486147, the violation is being treated as an NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.
05000282/FIN-2015002-0330 June 2015 23:59:59Prairie IslandNRC identifiedFailure to Make an 8-Hour Report Required by 10 CFR 50.72(b)(3)(ii)(B)The inspectors identified a Severity Level (SL) IV NCV of 10 CFR 50.72(b)(3)(ii)(B) due to the licensees failure on August 8, 2014, to report an unanalyzed condition within eight hours of discovery. Specifically, the lack of fuse protection for the emergency bearing oil pump control circuitry created an unanalyzed condition due to the potential for a fire that impacted the licensees safe shutdown capabilities. The inspectors determined that the failure to submit a report required by 10 CFR 50.72 for the unanalyzed condition described above was a performance deficiency. The inspectors determined that this issue had the potential to impact the regulatory process based, in part, on the information that 10 CFR 50.72 reporting serves. Since the issue impacted the regulatory process, it was dispositioned through the Traditional Enforcement process. The inspectors determined that this issue was a Severity Level IV violation based on Example 6.9.d.9 in the NRC Enforcement Policy. Example 6.9.d.9 specifically states, A licensee fails to make a report required by 10 CFR 50.72 or 10 CFR 50.73. Because the licensee identified the technical issue as part of their NFPA-805 transition process, and no additional or separate NRC-identified or self-revealed more-than-minor Reactor Oversight Process findings were noted, there was no cross-cutting aspect associated with this violation.
05000282/FIN-2014004-0430 September 2014 23:59:59Prairie IslandLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR 20.1601 requires control for access to high radiation areas (HRAs) and subpart (c) allows a licensee to apply to the NRC for approval of alternative methods for controlling HRA access. At Prairie Island Nuclear Generating Plant, the NRC-approved alternate methods for controlling access to HRAs include station TS 5.7. Specifically, TS 5.7.1.b for HRA access requires, in part, that Access to, and activities in each such area shall be controlled by means of a Radiation Work Permit (RWP)... Additionally, TS 5.7.1.e for HRA access requires, in part, that ...entry into such areas shall be made only after dose rates in the area have been determined and entry personnel are knowledgeable of them. Contrary to the above, on October 26, 2013, a worker willfully entered a posted and barricaded HRA inside the Unit-2 containment spray pump room on a RWP that did not authorize HRA entry and without being knowledgeable of the radiological conditions prior to entry. Corrective actions for this issue included performance management of the individuals involved in accordance with station management protocols. Because this violation was Severity Level IV, and it was entered into the licensees CAP as CAP 1403583, this violation is being treated as a NCV consistent with Section 2.3.2 of the NRC Enforcement Policy.
05000282/FIN-2014007-0430 June 2014 23:59:59Prairie IslandNRC identifiedFailure to Update the UFSAR for Pressure Isolation ValvesThe inspectors identified a Severity Level IV NCV of Title 10 CFR 50.71(e), Periodic Update of the Final Safety Analysis Report, and an associated Green finding for the licensees failure to update the Updated Safety Analysis Report (USAR) with a complete list of pressure isolation valves (PIVs) and periodic acceptance test requirements that had been reported to the Commission. Specifically, the licensee did not update Prairie Island Updated Safety Analysis (USAR) Section 4.6.1.2.1 Pressure Isolation Valves to include all PIVs and their associated test requirements. The licensee entered this issue into the CAP and initiated actions to change the USAR to incorporate the complete list of PIVs. The inspectors determined that the licensees failure to update the USAR with a complete list of PIVs and periodic acceptance test requirements and report the update to the Commission was a performance deficiency. The performance deficiency was determined to be more than minor in accordance with IMC 0612, "Power Reactor Inspection Reports," Appendix B, "Issue Screening," because, if left uncorrected the performance deficiency would have the potential to lead to a more significant safety concern. Additionally, the failure to include all PIVs in the USAR was more than minor because it was associated with the Initiating Event Cornerstone attribute of Equipment Performance and adversely affected the Cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions. The inspectors utilized IMC 0609, Significance Determination Process, Attachment 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined that the finding screened as very low safety significance (Green) since the inspectors answered No to the Loss Coolant Accident of Initiators questions in Exhibit 1, Section A, Initiating Events Screening Questions. In accordance with Section 6.1.d.3 of the NRC Enforcement Policy, this violation was also categorized as Severity Level IV because the licensees failure to update the USAR as required by 10 CFR 50.71(e) had not yet resulted in any unacceptable change to the facility or procedures. The inspectors determined that the performance characteristic of the finding that was the most significant causal factor of the performance deficiency was associated with the cross-cutting aspect of Human Performance, Documentation, and involving the organization creating and maintaining complete, accurate, and up-to-date documentation.
05000282/FIN-2013002-0731 March 2013 23:59:59Prairie IslandNRC identifiedFailure to Provide Accurate Performance Indicator DataThe inspectors identified a Severity Level IV non-citied violation of 10 CFR Part 50.9, Completeness and Accuracy of Information, and an associated finding of very low safety significance (Green) due to the licensees failure to provide information to the Commission that was complete and accurate in all material respects. Specifically, the licensee failed to follow procedures to ensure that the Mitigating Systems Performance Index (MSPI) for the emergency alternating current power systems was accurately reported for the third and fourth quarters of 2012. Once the information inaccuracies were corrected, the Unit 2 MSPI performance indicator (PI) changed from green to white. Corrective actions for this issue included correcting the inaccurate information, assigning dedicated resources to manage the PI reporting process, and performing an extent of condition review to ensure that the remaining PIs were appropriately reported. This issue was determined to be more than minor because it was related to a PI and caused the PI to exceed a threshold. This finding was evaluated for significance using IMC 0609, Appendix M, because the other SDP methods and tools were not adequate to determine the significance of the finding. After consulting with NRC management, the inspectors determined that this finding was of very low safety significance because the actual time the PI was inaccurately reported was short and the reporting inaccuracies had no impact on the ability of safety related equipment to perform its safety function. The inspectors determined that this finding was cross-cutting in the Human Performance, Work Practices area because the inaccurate reporting was caused by a failure to follow procedures H.4(b). The violation of 10 CFR Part 50.9 impacted the ability of the NRC to perform its regulatory oversight function and was determined to be Severity Level IV based upon Example 6.9.d.11 of the NRC Enforcement Policy.
05000282/FIN-2013002-1331 March 2013 23:59:59Prairie IslandLicensee-identifiedLicensee-Identified ViolationTitle 10 CFR Part 72.150, Instructions, Procedures and Drawings, requires, in part, that licensees shall prescribe activities affecting quality by documented instructions, procedures, or drawings of a type appropriate to the circumstances. Instructions, procedures, and drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, prior to November 17, 2010, the licensee failed to perform ISFSI surveillance requirement testing with a procedure appropriate to the circumstance. Specifically, quantitative acceptance criteria contained in D95.3, TN-40 Cask Removal and Storage Procedure, Revision 15, and preceding revisions did not include gauge uncertainty when performing cask vacuum drying and helium backfilling surveillance requirements. As a result, the licensee was unable to verify that casks 1-26 were loaded in accordance with cask technical specification requirements. The violation was determined to be more than minor in accordance with IMC 0612, Appendix B, Issue Screening, and Appendix E, Example 4c. Consistent with the guidance in the NRC Enforcement Manual, Section 2.6.D, if a violation does not fit an example in the enforcement policy violation examples, it should be assigned a severity level: (1) commensurate with its safety significance; and, (2) informed by similar violations addressed in the Violation Examples. The violation screened as having very low safety significance, Severity Level IV. Specifically, following identification of the issue the licensee performed an operability assessment that showed the casks would continue to perform their design function with the addition of the gauge inaccuracy. The licensee documented this issue as CAPs 1259086 and 1370456. Corrective actions for this issue included issuing the revised procedure, performing an extent of condition review, performing an operability assessment of affected casks, and screening the issue for reportability.
05000306/FIN-2011004-0630 September 2011 23:59:59Prairie IslandNRC identifiedFailure to Provide Complete and Accurate Information in a Licensee Event ReportThe inspectors identified a Severity Level IV NCV of 10 CFR 50.9 due to the licensees failure to provide information to the NRC that was complete and accurate in all material respects. Specifically, Licensee Event Report (LER) 05000282/2011-001-00; 05000306/2011-001-00, stated that the unplanned actuation of the 121 motor driven cooling water pump (MDCLP) was caused by the over tightening of a gasketed connection on the 11 containment and auxiliary building chiller. The results of a subsequent apparent cause evaluation showed that the unplanned actuation of the 121 MDCLP was due to operating the chiller in a manner outside of its design. The licensee initiated corrective action document, CAP 1299410, to document this issue. Corrective actions for this issue included submitting a revised LER to the NRC and evaluating actions that could be taken to ensure that future chiller operation would not result in actuations of the cooling water pump. The inspectors determined that this violation was more than minor because the inaccurate information could impede or impact the regulatory process. Specifically, in order for the NRC to determine the acceptability of the licensees corrective actions as part of the LER review, the licensee was required to provide complete and accurate information regarding the cause of the event. As a result, the NRC dispositions these violations using the traditional enforcement process instead of the SDP. However, if possible, the NRC evaluates the underlying technical issue using the SDP. In this case, the inspectors determined that the failure to operate the 11 containment and auxiliary building chiller in accordance with design could be assessed using IMC 0609, Significance Determination Process, Attachment 0609.04, Phase 1 Initial Screening and Characterization of Findings, Tables 3b and 4a. The inspectors concluded that the finding was of very low safety significance because each of the questions in Table 4a could be answered No. In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. No cross-cutting aspect was assigned to this finding as the reason for operating the chiller outside of its design was not associated with any of the components/aspects provided in NRC IMC 0310, Components within the Cross-Cutting Areas.
05000306/FIN-2011004-0330 September 2011 23:59:59Prairie IslandNRC identifiedFailure to Make Eight Hour Report Pursuant to 10 CFR 50.72The inspectors identified a Severity Level IV NCV of 10 CFR 50.72(b)(3)(v)(D) for the licensees failure to report an event or condition that could have prevented the fulfillment of a safety function to the NRC within 8 hours. Specifically, on June 27, 2011, an unexpected lockout of the 2RY transformer rendered one of two required offsite power paths inoperable. A subsequent review of the remaining transmission system capabilities resulted in declaring the second offsite power path inoperable due to inadequate minimum post-trip voltage. However, the licensee failed to recognize that the inoperability of both offsite power paths constituted a loss of safety function that was reportable to the NRC within 8 hours. The licensee initiated a corrective action document, CAP 1292940, for this issue. Corrective actions for this issue included reporting this issue to the NRC on July 1, 2011, revising procedures to ensure that inoperable offsite power paths that remain available were reported to the NRC, and repairing the 2RY transformer. The inspectors determined that the failure to report required plant events or conditions to the NRC had the potential to impede or impact the regulatory process. As a result, the NRC dispositions violations of 10 CFR 50.72 using the traditional enforcement process instead of the SDP. However, if possible, the underlying technical issue was evaluated using the SDP. In this case, the inspectors determined that the 2RY transformer locked out due to moisture entering a degraded bus duct, which was exposed to the environment. The licensee failed to identify the degraded bus duct earlier due to the inappropriate deferral of preventive maintenance activities. The inspectors determined that this issue was more than minor because it was associated with the protection against external factors attribute of the Initiating Events Cornerstone, and affected the cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during power operations. Since the finding contributed to both the likelihood of a plant trip and that mitigating systems equipment or functions would not be available, a Region III Senior Reactor Analyst (SRA) was contacted for assistance. The results of the Phase 3 analysis showed a change in core damage frequency of 2.4E-8/year, which represented a finding of very low safety significance (Green). In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation was categorized as Severity Level IV because the underlying technical issue was evaluated by the SDP and determined to be of very low safety significance. The inspectors concluded that this finding was cross-cutting in the Human Performance, Work Practices area because licensee personnel failed to follow procedures regarding the preventive maintenance deferral process.
05000282/FIN-2011502-0130 June 2011 23:59:59Prairie IslandNRC identifiedIncomplete and Inaccurate Emergency Action Level Change SubmittalThe NRC identified a Severity Level IV Non-Cited Violation of 10 CFR 50.9 for failing to provide complete and accurate information for prior approval of a new Emergency Action Level (EAL) scheme. The licensees submittal to the NRC, entitled, Revision to Emergency Action Levels, dated October 22, 2004, was not complete and accurate in all material respects. The submitted EAL scheme specified instrument threshold values for Alert classifications, EALs RA1.1 and RA1.2, which were beyond the indicated ranges of the effluent radiation monitors R-18, R-25, and R-31. The NRC accepted and approved the proposed EALs not realizing the information was incomplete and inaccurate. The inspectors determined that the licensees failure to provide complete and accurate information to the NRC, a violation of 10 CFR 50.9, was a performance deficiency and within the licensees ability to foresee and prevent. The deficiency was determined to be more than minor because it was associated with the Emergency Preparedness Cornerstone attribute of Procedure Quality. As a violation that potentially impedes or impacts the regulator process, it was dispositioned using the traditional enforcement process as described in NRC Inspection Manual Chapter 0612, Revision 04/30/10. Using Section 6.9 of the Enforcement Policy and after consultation with the Director of the Office of Enforcement, this issue was determined to be a Severity Level IV violation. Specifically, though the NRC would have questioned the issue with additional and correct information, the EAL ultimately would have been acceptable with an adjustment in the indicator range or EAL entry criteria value. In either case, it would not have resulted in substantial further inquiry. Additionally, the associated technical violation was determined to be of very low safety significance. As this was a traditional enforcement action, no cross cutting aspect was screened.
05000282/FIN-2009005-0331 December 2009 23:59:59Prairie IslandNRC identifiedFailure to Provide Complete and Accurate Information for LER 05000306/2008-001-00A NRC-identified issue and a NCV of 10 CFR 50.9 was identified when the inspectors discovered that Licensee Event Report (LER) 05000306/2008-001-00 was not complete and accurate in all material aspects. Specifically, the LER omitted information regarding when and how the licensee became aware that the Unit 2 component cooling water system was susceptible to failure following a postulated high energy line break in the turbine building. The omitted information was considered to be material to the NRC because it potentially affected the NRC\'s determination as to whether this issue would be characterized as an old design issue per Inspection Manual Chapter 0305. Subsequent to discovery of the deficiency, the licensee submitted Revision 1 to LER 05000306/2008-001-00, on January 19, 2009, which documented the originally omitted information. This issue was determined to be more than minor because it affected the NRCs ability to perform its regulatory function. As a result, this finding was evaluated with the traditional enforcement process. Using the information provided in IMC 0612, Appendix B, Issue Screening, this issue was determined to be a Severity Level IV NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy. This finding was determined to be cross-cutting in the Human Performance, Work Control area, because the licensee failed to properly plan and coordinate work activities to address the impact of work on different job activities and the need for groups to communicate, coordinate, and cooperate with others during work activities (H.3(b)). (Section 4OA3.1
05000282/FIN-2008007-0131 December 2008 23:59:59Prairie IslandNRC identifiedFailure to Perform a 10 CFR 50.59 Evaluation for Bulk Hydrogen Storage FacilityThe inspectors identified a Severity Level IV NCV, having very low safety significance, of 10 CFR 50.59, Changes, Tests, and Experiments, for the licensees failure to perform a safety evaluation associated with installation of a bulk hydrogen storage facility. Specifically, the licensee had not evaluated the adverse affects on the Circulating Water System from a postulated hydrogen tank explosion in the bulk storage facility located directly above buried Circulating Water System return lines. The licensee stopped work on the installation of the bulk hydrogen facility and documented the NRC identified issues in the corrective action system. The inspectors concerns also prompted the licensee to identify above ground Cooling Water System pipe in the nearby Turbine Building, which had not been evaluated in the hydrogen blast analysis. The finding was more than minor because the inspectors could not reasonably determine that this change would not have ultimately required prior approval from the NRC. This finding was categorized as Severity Level IV because the underlying technical issue for the finding was determined to be of very low safety significance based on a Phase 1 screening in accordance with IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situation. Specifically, the inspectors answered No to the Mitigating Systems screening questions in the Phase 1 Screening Worksheet because the licensee had not yet filled the bulk storage facility with hydrogen, so no possibility of explosion and damage to plant equipment existed. The cause of the finding is related to the cross-cutting element of Human Performance Decision Making, because the licensee failed to make conservative assumptions in decision making associated with the effects of a postulated hydrogen tank explosion (IMC 305, Section 06.07.c, Item H.1(b)). (Section 1R17.1.b
05000282/FIN-2008003-0230 June 2008 23:59:59Prairie IslandNRC identifiedUSAR Not Updated to Include AnalysesThe inspectors identified an Non-Cited Violation of 10 CFR 50.71, Maintenance of records, making of reports, for the licensees failure to adequately update the Prairie Island Nuclear Generating Plant Updated Safety Analysis Report (USAR) to include analyses performed in response to Generic Letter (GL) 2004-02. Title 10 CFR 50.71(e) requires, in part, that the USAR be revised to include the effects of all analyses of new safety issues performed by or on behalf of the licensee at Commission request. The Commission, through GL 2004-02, requested that licensees perform an evaluation of the Emergency Core Cooling Systems and its associated recirculation functions and, if appropriate, take additional actions to ensure system function. The licensee, in response to GL 2004-02, performed analyses of debris generation and transport, chemical effects, downstream effects, upstream effects, and strainer and other structural analysis, but did not update the safety analysis report to include those analyses. This issue potentially impacted the NRCs ability to perform its regulatory function and therefore, it was evaluated using the traditional enforcement process. The inspectors determined that the finding was more than minor because of the potential to impact the regulatory process by using IMC 0612, Appendix B, Issue Screening, dated September 20, 2007. Specifically, the failure to provide complete licensing and design basis information in the USAR could result in either the licensee making an inappropriate interpretation or the NRC making an inappropriate regulatory decision based on incomplete information in the USAR. This finding has a cross-cutting aspect in the area of human performance, work practices (H.4(c)) because the licensee did not ensure supervisory and management oversight of work activities such that nuclear safety was supported. Corrective actions included revising the USAR to reflect the analyses and submitting the updated information to the NRC. (Section 4OA5.1.c