IR 05000282/1998001
| ML20217P614 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 05/01/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20217P607 | List: |
| References | |
| 50-282-98-01, 50-282-98-1, 50-306-98-01, 50-306-98-1, NUDOCS 9805060362 | |
| Download: ML20217P614 (7) | |
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Prairie Island Nuclear Generating Plant - SALP 13
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Report No. 50-282/98001; 50-306/98001
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) process is used to develop the Nuclear Regulatory Commission's (NRC) conclusions regarding a licensee's safety performance.
' Four functional areas are assessed: Plant Operations, Maintenance, Engineering, and Plant Support. The SALP report documents the NRC's observations and insights regarding performance and communicates the results to the licensee and the public. It provides a vehicle
' for clear communication with licensee management that focuses on plant performance relative to safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilities.
This report is the NRC's assessment of the safety performance at the Prairie Island Nuclear -
Generating Plant for the period February 18,1996, through March 28,1998. An NRC SALP j
Board, composed of the individuals listed below, met on April 8,1998, to assess performance in j
accordance with the guidance in NRC Management Directive 8.6, " Systematic Assessraent of Licensee Performance."
Board Chairperson Cynthia D. Pederson, Director, Division of Nuclear Materials Safety, Region lll Board Members
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Cynthia A. Carpenter, Director, Project Directorate ill-1, Office of Nuclear Reactor Regulation Marc L. Dapas, Deputy Director, Division of Reactor Projects, Region lli John A. Grobe, Director, Division of Reactor Safety, Region ll1 11.
PERFORMANCE ANALYSIS A.
Plant Operation _t Overall performance in the area of plant operations was good. Some operator errors occurred in the middle of the assessment period that by the end of the period had been adequately
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addressed and corrected. In addition, some weaknesses were identified in procedural adequacy; procedural adherence; and standards for operator professionalism, control room decorum, communications, and access. Management instituted comprehensive improvement programs in these areas and improvements were noted by the end of the assessment period. However, a continuous improvement philosophy and self-critical focus, using aggressive self-assessments, were not evident throughout most of the assessment period.
Operator performance in response to off-normal conditions was excellent during the entire assessment period. For example, operators responded well to a loss of offsite power which resulted in a trip of both units from full power and extended reliance on natural circulation cooling and emergency diesel generators. With only the normal weekend crew complement initially available, operators property identified and classified the event, stabilized plant conditions, and 9805060362 980501
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verified the proper operation of all emergency equipment.. In addition, three forced shutdowns and three planned shutdowns were conducted safely. Close monitoring of plant conditions by the
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operating crews resulted in the identification of two small reactor coolant system leaks, allowing
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prompt resolution of the material condition problems before conditions further deteriorated.
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Except for a few isolated cases, operators made conservative operability decisions. Generally, j
equipment was considered to be inoperable whenever any degradation was noted. For example, an auxiliarv feedwater pump was conservatively declared inoperable when flow through the test
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' line was fwnd to be higher than expected during a special test. Situations which would have I
resulted in the simultaneous inoperability of equipment, although not prohibited by Technical f
Specifications or procedures, were aggressively avoided. Management supported this l
conservative philosophy and made decisions on three separate occasions to shut down a unit before Technical Specifications would have required it. In one case, a voluntary shutdown was approved to allow modification of the Unit 1 auxiliary feedwater pump trip feature so that it would
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be identical to the trip feature of the Unit 2 pump, a modification to improve safety.
-J Operator performance during routine evolutions was a concem during the middle of the
' assessment period. Operator errors and procedure adherence problems led to four engineered f
safeguards system actuations during surveillance testing, three inadvertent reactor coolant system dilution events, a fuel handling error, and an incident involving excessive draining from j
- the reactor coolant system. These errors occurred within a relatively short period of time.
Management identified the root causes for this performance decline and was successful ir.
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addressing the problems.
Procedural adequacy was another area where a number of problems.were identified, some of which led to operator errors. For example, steps that were missirg in one procedure for isolating
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the volume control tank resulted in operators inadvertently increasing the reactor vessel water i
level; and in another procedure for measuring reactor coolant system leakage, a step was missing for operating a divert valve for the holdup tank which resulted in operators inadvertently
' bypassing the letdown domineralizers. Other procedures could have caused problems if followed as written. For example, the NRC identified that a procedure contained instructions for responding to a failure of the reactor to trip that were contrary to guidance in an emergency j
operating procedure for this event. Management instituted a procedure improvement program in j
the last few months of the assessment period and also emphasized the responsibility of users to j
stop and correct procedural problems once identified. Some improvement in the operations area j
was recently noted where operators stopped specific activities directed by the procedures to correct procedure errors, j
One of the causes for inadequate procedures was a lack of clearly established and enforced management standards for the development, rcview, and approval of procedures and procedure revisions. Even at the highest review level, the Operations Committee, superficial procedure f
reviews routinely occurred which failed to identify obvious errors and deviations from the
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procedure writer's guide standards. In addition, the NRC identified that some procedures which j
contained operating instructions were incorrectly considered to be outside the scope of the j
Operations Committee's purview. After these issues were identified, management took actions j
which were generally effective to improve the performance of the Operations Committee.
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In addition, high standards for control room decorum, operator professionalism, communications,
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and control room access were not clearly established and enforced. After this issue was
identified by third parties, management took aggressive actions to implement improvement initiatives. By the end of the assessment period, performance in this area had improved.
Most of the weaknesses in plant operations were revealed through events or were identified by l
- third parties, the quality services organization, or the safety assessment group. Although performance in the area of plant operations during the last several months of the assessment period was improved, the structure and processes to achieve sustained superior performance in this functional area were not firmly established.
The performance rating in Plant Operations is Category 2.
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B.
Maintenance Overall performance in the maintenance area was excellent and resulted in superior reliability -
l and availability of plant equipment.- The conduct and planning of maintenance activities were very good. Although some procedure adherence and adequacy problems were noted as well as some problems with the inservice inspectior program, these problems did not result in significant
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equipment operability or availability issues. Effective management support and work control,
,j strong system engineering involvement, and experienced craft personnel resulted in excellent
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material condition of the facility.
Management involvement in the maintenance area was excellent as evidenced by a very small,
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stable work request backlog; appropriate attention to priority work and control room deficiencies; I
and infrequent equipment failures nece:sitating entry into Technical Specification Limiting Conditions for Operation.
Refueling and maintenance outage W!vities were conducted effectively with few errors and no challenges to shutdown safety. For example, the unscheduled outage to remove a leaking partial-length control rod drive mechanism was performed especially well. System engineer involvement in maintenance and testing activities was a strength. The engineers promptly investigated any operational abnormalities, took an active role in maintenance and
'j troubleshooting activities, and closely followed all surveillance testing on plant systems. Good I
teamwork and interdepartment communications were also evident.
The planning and conduct of the surveillance test program were very good. Surveillance tests in j
the past year were properly scheduled and conducted. However, plant staff identified that tests
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requiring laboratory or other analysis were being considered as completed before the analyses were done. Also, some concems were identified with the quality of surveillance test procedures.
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Sixteen surveillance procedures were examined as part of the procedure quality review pilot program and problems were identified with the quality of each of the procedures reviewad during
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this process. These problems mostly dealt with general formatting and ease-of-use. To address
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these problems, management recently implemented a procedure improvement program.
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Maintenance personnel errors, a minor weakness identified in the previous SALP period, were j
very infrequent in this period. However, problems were identifisd with the handling of heavy j-loads. One example, involving movement over the reactor vessel, resulted in an escalated
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enforcement action. These problems were adequately addressed midway through the assessment period. Also, some problems with procedure adequacy and adherence were
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identified. For example, an electrical breaker work order specified inappropriately sequenced instructions which resulted in an engineered safety feature actuation. An issue was identified with the inservice inspection program regarding the failure to obtain appropriate relief requests due to an incorrect interpretation of the regulations.
Self-assessments in this area were strong. For example, self-assessments identified a need to improve the quality of maintenance work instructions. In addition, as discussed above, the procedure quality review pilot program was a very good effort to fully scope the efforts needed to address surveillance procedure problems. Management closely tracked maintenance backlog and rework activities to assess maintenance performance.
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i The performance rating in Maintenance is Category 1.
C.
Enaineerina In general, performance in the engineering area was very good. A competent and knowledgeable engineering staff provided strong support to operations, maintenance, and other organizations. However, some technical deficiencies in procedures for operations, maintenance, and test activities were identified. ' System engineers effectively managed plant systems and contributed to excellent equipment performance. Through a variety of initiatives, the engineering staff continued to identify problems and, with some exceptions, effectively resolved them.
Design engineering activities, including modifications and calculations, were typically effective.
With few exceptions, safety evaluations were well-written. Engineering efforts in support of
' license amendments and relief requests were good, but some examples of untimely or incomplete license change submittals were noted.
Management oversight in engineering improved during this assessment period by separating the engineering functions by disciplir and adding a second engineering senior manager.
Engineering staffing levels were also increased. Several vacancies were filled and additional positions were created both in design and systems engineering. Management focused
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appropriate resources on the training program for new engineers to assure consistent, well-qualified staff. The continuing engineering training program remains a strength with many staff
holding senior reactor' operator certifications, in response to a weakness discussed in the
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previous SALP, training in 10 CFR 50.59 safety evaluations, including detailed reviews of actual
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examples, was given to all engineering personnel.
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The strong involvement of system engineers in operation, maintenance, testing, and trouble shooting activities for assigned systems substantively contributed to the excellent plant material j
condition. For example, a task force established to address the partial-length control rod drive
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mechanism leak was effective. The system engineering function was well-integrated into all aspects of plant operations and maintenance. For example, during pre-job control room briefings, system engineers were proactively involved in discussions regarding their plant systems. During the Unit 2 Integrated Safety injection Test with a simulated loss of offsite power, engineers provided effective support in establishing controls and monitoring sistems during the test. The engineers also monitored industry events for applicability to their systems
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and were frequently observed conducting system walkdowns.
In contrast, as discussed in the Maintenance and Operations sections of this report, several procedural deficiencies relating to technical completeness and accuracy revealed a need for improvement in engineering support to procedures. In addition, engineering support for
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emergent or infrequent work activities resulted in occasional failures to al., ropriately evaluate logic circuits causing test and maintenance problems. General!y, operability determinations
- performed on degraded equipment were conservative, technically well supported, and included compensatory actions where appropriate. However, in one case, a written operability determination for Unit 1 resulting from the Unit 2 partial-length control rod drive mecnanism leak was not timely or thorough.
Engineering staff continued to effectively identify and resolve technical issues. Issues related to design basis information and the quality of original analyses and procedures continued to be self-identified.. For example, engineering staff recently identified 10 CFR Part 50, Appendix R, issues regarding inadequate separation of pressurizer level cables and, following questions from NRC inspectors, identified control room ventilation system design and performance concems.
The engineering staff also identified an errorinvolving the administrative control of the containment boundary and reactor coolant system vent path. If undetected, this error would have resulted in a violation of requirements for containment boundary control.
In addition, the engineering organization responded well to generic issues and took the lead in identifying and correcting several industry issues. Two examples concemed spent fuel pool Boraflex degradation and operation of the auxiliary feedwater pump during certain ATWS-(anticipated transient without scram) events. Also, the plant's steam generator inspection program continues to be a strength; including use of state-of-the-art procedures and equipment.
In response to Generic Letter 96-01, the engineering staff performed a thorough review of logic circuits and actions taken in response to findings were conservative.
Overall, design activities were appropriately controlled resulting in the plant's design basis being adequately maintained. Effective design engineering staff support contributed to a steady reduction of operator work arounds, open operability evaluations, and temporary modifications.
One exception was the inadequate evaluation of the containment hydrogen monitor regulator settin0 changes which were not covered by the design control or configuration management procedures. Calculations were usually acceptable, but examples of inattention-to-detail were noted with several older calculations. As design basis issues were identified, appropriate evaluations were performed which were typically conservative. A good example of this was the actions taken upon discovery that there was no analysis for a dilution accident during shutdown conditions.
The 10 CFR 50.59 safety evaluation program was an area of weakness in the previous SALP period. Actions taken to address this weakness included a comprehensive self-assessment of the 50.59 program and an initiative to re-evaluate older safety evaluations. Changes to the program have satisfactorily addressed the weakness as evidenced by the thorough safety evaluation conducted in support of the change to the setpoint for the auxiliary feedwater pump runout protection modification.
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Engineering efforts in support of license amendments and relief requests were good; however, some instances were identified where license change submittals were incomplete or untimely.
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These include license amendments conceming voltage-based steam generator tube repair criteria, the third 10-year inservice inspection examination plan, and a cooling water amendment j
request.
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Strong self-assessment in the engineering area was evident through effective implementation of a variety of initiatives including quality assurance audits. As a result of findings, the surveillance l
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testing and 50.59 safety evaluation programs were improved. Resolution of most of the identified issues was effective. However, some issues that were identified prior to this assessment period were not effectively addressed until this period. For example, midway through the assessment
period during an NRC System Operational Performance inspection, the NRC identified a failure
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to accomplish corrective action for an issue identified in 1991 concoming the rev.ew of safety-related pump test acceptance criteria. This issue, combined with test control deficiencies and a
failure to update the Updated Safety Analysis Report, resulted in an escalated enforcement action. Several issues were identified by plant staff and through NRC inspections where plant configuration did not match the. Updated Safety Analysis Report. In response, the engineering organization initiated action to better control the design basis, and implemented the Updated Safety Analysis Report review project. The first stages of this project consisted of verifying that plant systems, components, and parameters met the design and licens!ng basis, j
The performance rating in Engineering is Category 2.
D.
PI' ant Support
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With the exception of fire protection, plant support performance continued to be excellent.
Effective performance was noted in radiation protection, with strengths observed in ALARA (as-low-as-Is-reasonably-schievable) planning and implementation, radiological coni sls for non-routine and outage activities, and calibration and operability of survey instruments. The chemistry staff maintained plant water quality well within industry guidelines and laboratory analyses were accurate. Performance in the security area was strong and consistent.
Emergency preparedness remained in an effective state of readiness, as the facilities and equipment were well-maintained and management support was strong. Fire protection performance was generally good, with several strengths noted and only one small fire during the
assessment period; however, isolated problems were identified in several program areas, J
including fire brigade member training and qualification, and emergency lighting.
i The radiation protection program was well-implemented, with strengths observed in ALARA planning and implementation, radiological controls of outage and non-routine activities, and calibration of survey instrumentation. The staff effectively implemented ALARA planning to J
achieve significant dose savings. Radiation worker practices were generally very good, with J
isolated instances of inappropriate work practices identified.. The program for thc storage, classification, treatment, and transportation of radioactive waste'and material was successful,
and the calibration and maintenance of dosimetry and radiation detection equipment was effective. Environmental monitoring for various plant operations was well-implemented, as plant
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staff accurately assessed offsite dose and the environmental data showed no discemable radiokgical impact. Self-assessments and audits were extensive, and issues were resolved in a j
timely manner.
The chemistry program remained a strength. Plant water quality was excellent, and the staff pursued sources of chercical contamination aggressively. Recent cooperative initiatives by the I
chemistry and operations staffs improved the quality of makeup water. Quality control and
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material condition of laboratory and in-line instruments were very good, and quality assurance data demonstrated that analyses were accurate. Effective accomplishment of chemistry tasks
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demonstrated that initial and continuing training were effective. Self assessments and audits were comprehensive, and issues were effectively addressed.
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l Security performance was strong and consistent during this assessment period. Significant changes were implemented to further strengthen the security training program. Self-assessment efforts at several levels continued to be aggressive in identifying weaknesses and the findings were closely tracked, monitored, and trended. Corrective actions were effective in preventing recurrence of identified problems. Installation of the vehicle barrier system was completed in accordance with rule requirements and associated commitments. The security equipment
. testing program was aggressive, and security staffing has stabilized. With few exceptions, security procedures were well-written and reviewed at appropriate intervals. Strong oversight of security activities was provided by security supervisors. Weaknesses noted during the previous assessment period in tecurity supervisor performance and procedure weaknesses at the corporate security office were effectively addressed.
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The emergency preparedness (EP) program was maintained in an effective state of operational
readiness. In particular, the emergency response facilities and equipment were well-maintained, and management support of the program was strong. Key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. The EP coordinator and plant personnel were proactive in planning with offsite authorities for the May 1997 floods. Site staff performed appropriately during an actual activation of the Emergency Plan due to the storm-related loss of three of five off-site power lines. Effective performance was noted during the 19% evaluated exercise, as this EP exercise successfully demonstrated the capabilities to imp!ement the emergency plans and procedures. Self-assessment of the exercise
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performance was thorough and accurate.
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Implementation of the fire protection program was generally good. Fire protection program strengths included the low number of fire protection impairments requiring a fire watch, the successful maintenance of most fire protection equipment, and for the most part, the effective i
control of transient combustibles. There was only one small, contained plant fire during the past
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three years, which indicated that hot work was being safely performed. However, isolated l
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problems were identified in several program areas involving fire brigade drills and training, qualification of brigade members, timeliness of reviews for hot shorts, emergency lighting, record retention, and penetration fire seals.
The performance rating in Plant Support is Category 1.
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