IR 05000282/2010007

IR 05000282-10-007 & 05000306-10-007, on 09/20/2010 - 10/08/2010, Prairie Island Nuclear Generating Plant, Units 1 and 2, Routine Biennial Problem Identification and Resolution Inspection

ML103230328
Person / Time
Site:	Prairie Island
Issue date:	11/19/2010
From:	Jack Giessner Reactor Projects Region 3 Branch 4
To:	Schimmel M Northern States Power Co
References
IR-10-007
Download: ML103230328 (23)

Text

UNITED STATES ber 19, 2010

SUBJECT:

PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2, NRC BIENNIAL PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000282/2010007; 05000306/2010007

Dear Mr. Schimmel:

On October 8, 2010, the U.S. Nuclear Regulatory Commission (NRC) completed a biennial team inspection of Problem Identification and Resolution at your Prairie Island Nuclear Generating Plant, Units 1 and 2. The inspection team also reviewed the most recent independent assessment of safety culture to further understand a substantive cross-cutting issue that is open at Prairie Island. The enclosed inspection report documents the inspection findings which were discussed on October 8, 2010, with you and members of your staff.

This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, compliance with the Commission=s rules and regulations, and with the conditions of your operating license. Within these areas, the inspection involved selected examination of procedures and representative records, observations of activities, and interviews with personnel.

The inspection team concluded that on the basis of the sample selected for review, in general, problems were properly identified, evaluated, and corrected. The team noted that the licensee reviewed operating experience for applicability to station activities. Audits and self-assessments were performed at an appropriate level to identify deficiencies. Based on the independent assessment of safety culture results, interviews conducted during the inspection, and review of the employee concerns program, freedom to raise nuclear safety concerns was demonstrated.

Based on the results of this inspection, no findings were identified. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

John B. Giessner, Chief Branch 4 Division of Reactor Projects Docket Nos. 50-282; 50-306;72-010 License Nos. DPR-42; DPR-60; SNM-2506

Enclosure:

Inspection Report 05000282/2010007; 05000306/2010007 w/Attachment: Supplemental Information

REGION III==

Docket Nos: 50-282; 50-306;72-010 License Nos: DPR-42; DPR-60; SNM-2506 Report No: 05000282/2010007; 05000306/2010007 Licensee: Northern States Power Company, Minnesota Facility: Prairie Island Nuclear Generating Plant, Units 1 and 2 Location: Welch, MN Dates: September 20 through October 8, 2010 Inspectors: R. Lerch, Project Engineer, Team Leader P. Zurawski, Resident Inspector, Prairie Island J. Draper, Reactor Engineer C. Brown, Engineering Inspector M. Phalen, Senior Radiation Protection Inspector Approved by: J. Giessner, Chief Branch 4 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000282;05000306/2010-007; 09/20/2010 - 10/08/2010; Prairie Island Nuclear Generating

Plant, Units 1 and 2; Routine Biennial Problem Identification and Resolution Inspection.

This inspection was performed by four NRC regional inspectors and the Prairie Island resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Problem Identification and Resolution On the basis of the information reviewed, the team concluded that the corrective action program (CAP) at Prairie Island was adequate. The inspectors noted improved performance from the last inspection, but sustained improvement was not yet demonstrated. In general, the licensee had a low threshold for identifying problems (issue reports called CAPs) and entering them in the CAP. Most items entered into the CAP were screened and prioritized in a timely manner using established criteria. Most issues, including operating experience, were properly evaluated, and corrective actions were generally implemented in a timely manner, commensurate with the safety significance.

The backlog of corrective actions was reduced, but should be reduced further. Audits and self-assessments were determined to be performed at an appropriate level to identify deficiencies.

On the basis of interviews conducted during the inspection, and a review of the employee concerns program, workers at the site were willing to enter safety concerns into the CAP.

NRC-Identified

and Self-Revealed Findings No findings were identified.

Licensee-Identified Violations

No violations were identified.

REPORT DETAILS

4OA2 Biennial Problem Identification and Resolution

The activities documented in Sections a. through d. constituted one biennial sample of problem identification and resolution as defined in IP 71152.

a.

Assessment of the Corrective Action Program Effectiveness Inspection Scope The inspectors reviewed the licensees Corrective Action Program (CAP) implementing procedures, interviewed personnel, and attended CAP meetings to assess the implementation of the CAP by site personnel.

The inspectors reviewed risk and safety significant issues in the licensees CAP since the last NRC Problem Identification and Resolution (PI&R) inspection in July of 2009. The selection of issues ensured an adequate review of issues across NRC Cornerstones. The inspectors used issues identified through NRC generic communications, department self assessments, licensee audits, operating experience reports, and NRC documented findings as sources to select issues. Additionally, the inspectors reviewed issue reports called CAPs (procedurally defined as a Corrective Action Program Action Request (CAP AR)), generated as a result of facility performance in daily plant activities. In addition, the inspectors reviewed a selection of completed CAP investigations from the licensees various investigation methods, which included root causes, apparent causes, and common cause investigations.

A 5 year review of Foxboro module issues was also undertaken to assess the licensee staffs efforts in monitoring and addressing equipment aging aspects. The inspectors also performed partial system walkdowns in the plant.

During the reviews, the inspectors evaluated the licensee staffs actions to comply with the CAP and 10 CFR Part 50, Appendix B requirements. Specifically, the inspectors evaluated if licensee personnel were identifying plant issues at the proper threshold, entering the plant issues into the CAP in a timely manner, and assigning the appropriate prioritization for resolution of the issues. The inspectors also evaluated whether the licensee staff assigned the appropriate investigation method to ensure the proper determination of root, apparent, and contributing causes. The inspectors also evaluated the timeliness and effectiveness of corrective actions for selected issue reports, completed investigations, and NRC findings, including Non-Cited Violations.

Assessment

(1) Effectiveness of Problem Identification In general, problem identification was adequate and at an appropriate threshold. The sample of issues reviewed by inspectors that were entered into the CAP indicated a low threshold, with a steady generation of CAPs on a monthly basis. Corrective Action Program generation numbers appeared representative of a good problem identification ethic. Other safety conscious work environment (SCWE) indications such as surveys and interviews indicated willingness to identify issues and capture them in the CAP.

Some disincentives to the initiation of CAPs were noted by the inspectors. The computer program for the CAP was difficult to access and manipulate for occasional users not familiar with its use. Survey results and interviews indicated that some employees had low expectations for the CAP to fix problems. Some of this feeling was related to a lack of feedback to CAP initiators, a lack of understanding of the process overall, and how some low level issues are addressed when they were closed to trend.

Findings No findings were identified.

(2) Effectiveness of Prioritization and Evaluation of Issues Assessment The inspectors determined that the overall performance in prioritization and evaluation of issues had significantly improved from the last inspection and was acceptable.

However, this area still presented the most challenges to the CA program. The previous PI&R inspection expressed concerns with CAP screening and the corrective action backlog. Both these areas have improved in the near term.

Overall, performance of the screening committee had improved. The screening committee was modified to be made up of managers and preceded by a pre-screening of the issues conducted by departmental liaisons. Good ownership was demonstrated by the line organization and the CAP team. However, inspectors observed, in some cases, that screening decisions were made using incomplete information. In addition, some in-progress CAPS took too long to complete the assignment process, resulting in a potential vulnerability if prompt action was required. The licensee was working to address these and other weaknesses. Screening participants were observed demonstrating the adoption of higher standards and expectations, and increased accountability. The process enhancements that were implemented were recent, however, and continued oversight by upper managers and the Performance Assessment Staff is required to ingrain the effective performance of the screening committee.

The licensee was addressing prioritization of backlog issues through a review and reassessment of the backlog issues. The backlog was being reduced with efforts continuing to lower the backlog further. Although improved, some backlog issues remain. For example, based on the total number and the length of time that outstanding temporary modifications have been open, resolution of temporary modifications appeared backlogged. In addition, issues with the emergency diesel generators D-5 and D-6 crank case pressures were not resolved, rendering the diesels operable, but degraded; and a containment spray level issue remained from 2003. Review of the 2003 containment spray issue determined there is no immediate concern and the overall issue related to system classification downgrades. Subsequent to the inspection exit, the licensee completed the evaluation of plant systems and established approved engineering changes. The last of 49 engineering change packages was approved October 14, 2010. Although there were no immediate concerns, these issues were indicative of a process which needs further maturation to ensure the timely resolution of issues.

Prairie Island continued to experience plant transients and equipment deficiencies due to the failure to adequately resolve previously identified problems. Specifically, Unit 2 tripped from 13 percent power on April 16, 2010. The licensees subsequent investigation determined that similar events on Unit 2 had occurred in 2001 and 2003.

The licensee assigned corrective actions following the 2001 event. However, no evidence exists to show that these actions were completed. Had they been completed, the 2010 reactor trip would not have occurred. Following the 2003 event, the licensee made several recommendations to address the cause. Contrary to procedural requirements, these recommendations were not viewed as corrective actions since the 2003 event resulted in a turbine trip and not a reactor trip. The actions were not completed. These corrective action weaknesses were dispositioned as a Green finding in NRC Inspection Report 05000282/2010003; 05000306/2010003. At present, the corrective actions have been completed on Unit 2, and additional evaluation is required on Unit 1.

Root causes and Quality Assurance (QA) reports also documented issues that the licensee had earlier opportunities to address such as for control of important door keys and radioactive sources. The keys and sources were evaluated in root cause evaluation 1214773, and discussed in Inspection Report 05000282/2010002; 05000306/2010002, Section

4OA7 Licensee Identified Violations. Although this was a missed opportunity,

this self-critical identification of past evaluation weaknesses was, also, considered positive and provided lessons learned and motivation for more rigorous evaluations going forward.

The licensee had enhanced CAP oversight functions through the Plant Assessment Review Board and addition of the Technical Review Panel. These bodies reviewed and graded CAP evaluations for all higher significance items such as Root Causes and Apparent Causes and provided feedback to the staff. The Performance Assessment staff reviewed a sample of lower level CAP closures for adequacy as well. Enhanced oversight of the process combined with higher standards for products, increased adherence to due dates, and reductions in backlogs were recent improvements that had potential for long term improvements. However, it is too soon to conclude that these efforts will have the desired long term benefits.

Observations Foxboro H-Line Modules Another long term equipment issue evaluated by the inspectors was associated with the Foxboro H-Line modules which are used in reactor protection, reactor control, and balance of plant applications. These components were refurbished in 1985 with replacement anticipated by 1995. However, in 1989 the licensee became aware the vendor would no longer be supporting the product line. As a result, the licensee procured 30 spare modules with the intent to utilize them until a formal replacement process was established. The licensee has conducted studies and risk evaluations to determine both short and long term corrective actions. In the short term, the licensee will maintain, monitor, and replace the equipment, as necessary, through existing processes. If failures are anticipated or occur, available replacement components will be utilized to correct the plant condition. The licensee has also been involved with the industry regarding alternative long term solutions for the replacement of the modules.

This effort is being coordinated with input from Westinghouse and other licensees pilot replacement programs.

Since the refurbishment in 1985, Prairie Island had not experienced any significant transients due to module failures until July 2008 when a plant trip occurred as a result of a module failure. Since that time, the licensee has considered several additional options to address the obsolescence of these modules. Based on studies and risk analysis, the licensee has identified a 3 phase approach to module replacement in the reactor protection, steam exclusion, and reactor control systems. The licensee has begun Phase 1 design activities and obtained project funding for limited module replacements on the two most risk significant systems, the RPS and the steam exclusion system. The project team is pursuing approval for the two remaining phases. Phase 2 will replace the remaining modules in the reactor protection and steam exclusion systems. Phase 3 will replace the reactor control system modules.

In summary, the licensee continues to be at risk for Foxboro H-Line module failures and potential plant trip conditions during their monthly RPS testing. However, the licensee has taken actions to assess the risk and establish both short and long term solutions based on a prioritization of risk.

Findings No findings were identified.

(3) Effectiveness of Corrective Actions Overall, the effectiveness of corrective actions was acceptable. The licensee had improved issue screening, program oversight and was developing other process improvements to the CAP. The inspectors identified a few issues with ineffective corrective actions. For example, some corrective actions were closed without taking the action specified. In one case, this contributed to the cause of a reactor trip. Some weak corrective actions also failed to resolve issues. For example, Nuclear Oversight identified that workers installed grout under conditions outside its temperature range.

Although evaluation of the grout determined it was acceptable, this was a repeat observation by Nuclear Oversight (NOS) (CAP 01241226). Another weakness determined by inspectors was poor linkage between corrective actions and work orders such that cancelled or postponed work orders could eliminate corrective actions. A positive observation was the benchmarking of the site program against other plants programs and implementation of lessons learned.

Findings No findings were identified.

b.

Assessment of the Use of Operating Experience 1) Inspection Scope The inspectors reviewed the licensees implementation of the facilitys Operating Experience (OE) program. Specifically, the inspectors reviewed OE program procedures, attended screening meetings, reviewed several OE evaluations, interviewed OE program personnel, and reviewed the licensees most recent OE self-assessment.

The inspectors review was to determine whether the licensee was effectively integrating operating experience into their performance of daily activities, whether evaluations of issues were proper, whether the licensees program was sufficient to prevent future occurrences of previous industry events, and whether the licensee effectively used the information in developing departmental assessments and facility audits. The inspectors also assessed if corrective actions, as a result of the OE, were identified and effectively implemented in a timely manner.

2) Assessment The inspectors determined that the licensee effectively screened OE for applicability to the facility and that any corrective actions that the licensee initiated from OE evaluations were appropriate. The inspectors also noted that root cause evaluations and apparent cause evaluations included discussions of OE.

After the licensees latest self-assessment, the licensee revised their OE program procedure to make sure all OE evaluations were handled through the CAP, and thus included a supervisory review. Through the review of several OE evaluations, the inspectors identified examples of evaluations that were not of high quality even though they had received supervisory review. The licensee reopened the operating experience evaluation for Information Notice 2010-06 Inadvertent Control Rod Event While Shutdown (CR 1228173), because it was originally screened as applicable to boiling water reactors only, although the reactivity control issues were applicable to the site as well. Another is still awaiting its CAP closure review.

The inspectors did not identify any major deficiencies in the OE program; however, the major changes to the OE program were implemented only 3 months prior to the inspection, and under this program it can take up to 2 months for an OE evaluation to be completed. Thus, there were very few completed evaluations the inspectors could review to assess the current state of the program to ensure further improvements were being made. Also, the licensee indicated that they are planning additional changes to the OE program procedure, specifically in the area of OE evaluation guidance.

3) Findings No findings were identified.

c.

Assessment of Self-Assessments and Audits 1) Inspection Scope By review of a sample of audits and self-assessments, the inspectors assessed the licensee=s ability to identify and enter issues into the CAP, prioritize and evaluate issues, and implement effective corrective actions, to address departmental and nuclear oversight (NOS) assessment concerns. The inspectors assessed whether the licensee properly captured the documented deficiencies from assessments into CAPs. The inspectors also reviewed the focused self-assessment performed on the CAP in 2010, and NOS assessments of the CAP.

2) Assessment The licensee had programs and processes in place to conduct meaningful assessments and audits. In the last inspection, full benefits of self assessments were not realized because they were only conducted prior to audits by external organizations.

Subsequently, the schedule of assessments had been expanded and addressed other performance areas.

The licensee performed a 2010 self-assessment of the CAP and determined, although several areas needed improvement, personnel were adequately implementing the CAP.

Generally, the assessment was thorough and critical and identified issues that were consistent with the conclusions of the inspectors.

The inspectors considered the quality of the NOS assessments to be adequate. The stations CAP had been assessed by NOS as performing below expectations, but with an improving trend which generally matches the inspectors conclusions. Overall, the inspectors concluded the licensee and NOS performed assessments and audits that were effective.

4) Findings No findings were identified.

d. Assessment of Safety Conscious Work Environment 1) Inspection Scope The inspectors assessed the licensees safety conscious work environment through the reviews of the facilitys employee concerns program (ECP) implementing procedures, postings for maintaining employee awareness of the ECP program, discussions with the ECP coordinator, interviews with personnel from various departments, and reviews of issue reports. The inspectors reviewed the results from a June 2010 Nuclear Safety Culture Assessment conducted by the Utilities Service Alliance (USA) and reviewed the licensees actions in response to the assessment.

2) Assessment The licensee maintained an accessible, functioning ECP program that periodically assessed employee attitudes though email surveys. The safety culture assessment concluded, through interviews, that personnel feel that they can raise a nuclear safety concern, without fear of retaliation. Some results, however, indicated worker confusion between nuclear safety and personal safety, and a desire for more information about the resolution of issues raised. In response to the safety culture survey, the licensee initiated several tracking items including one for communications to the staff about the CAP and safety culture. Based on the CAPs generated at the plant, discussions with employees, and survey results, the willingness of employees to raise nuclear safety issues appeared adequate. No concerns were identified by the inspectors.

3) Findings No findings were identified.

e. Review of the 2010 Independent Nuclear Safety Culture Assessment Report The inspectors compared the 2010 Nuclear Safety Culture Assessment report to the 2008 assessment report and concluded the quality of the assessment report was improved. More information was included which gave additional support to the conclusions that were drawn. The report also included references to source documents, description of the assessment procedure, and external team member biographies. The assessment included an anonymous electronic survey which obtained an 88 percent response from the staff. The assessment provided insight into the sites performance in general. However, there was some information that was not in the report nor made available separately. No demographic information was provided showing which organizations or what working levels responded (vertical and horizontal affiliations),preventing any analysis for specific groups that may have differing perspectives, may be under-represented, or whose views may be overshadowed by other data. Maintaining respondent anonymity would have to be considered in presenting this information, but balanced on getting additional data to address specific group trends.

Some descriptors of the data were not defined or given context. For example, survey responses that appeared to be neutral or no opinion responses were labeled as expected. Other response data percentages were generally described in terms such as higher negative response rates without providing any context or evaluation. Although the specific survey results were very positive for willingness to identify nuclear safety concerns, the results for Prairie Island, in general, appeared somewhat negative to the inspectors. But the inspectors could not draw a conclusion based on the limited context of the data. Comparing the responses to a broader database such as the fleet or industry would be more meaningful. Many other indicators of performance are compared to the rest of the industry at least by quartile.

Overall, the 2010 safety culture assessment conducted by a team from the Utilities Service Alliance concluded that the Prairie Island nuclear safety culture had a healthy respect for nuclear safety. The inspectors determined this assessment was reasonable.

No findings were identified.

4OA6 Management Meetings

Exit Meetings Summaries On October 8, 2010, the inspectors presented the inspection results to M. Schimmel and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Schimmel, Site Vice President

B. Sawatzke, Director Site Operations

K. Davison, Plant Manager

T. Roddey, Site Engineering Director

G. Salamon, Director Nuclear Licensing and Emergency Preparedness

J. Anderson, Regulatory Affairs Manager

M. Birkel, Performance Assessment Coordinator

D. Blakesley, Analyst, Security

M. Brassart. Engineering Supervisor

D. Burdick, Evaluation Coordinator, Performance Assessment

H. Butterworth, Operations Support Fleet Director Operations Standards

S. DePasquale, Senior Licensing Engineer

M. Davis, Regulatory Affairs Analyst

C. Esser, Performance Assessment Coordinator

D. Hartinger, Nuclear Oversight Supervisor

L. Jenson, Nuclear Oversight Assessor

B. Johnson, Operations Shift Manager

J. Kivi, Employee Concerns Program Manager

L. Koehl, Communications

G. Lenertz, Maintenance Engineer

R. McIntyre, Radiation Protection Supervisor

J. Muth, Operations Manager

S. Northard, Recovery Manager

A. Notbohm, Performance Assessment Supervisor

K. Petersen, Business Support Manager

D. Schantzen, Engineering Supervisor

S. Schmidt, Performance Assessment

F. Sienczak, Corrective Action Program/Operations Support

A. Velaski, Performance Assessment Coordinator

J. Walker, Facilities and FIN General Supervisor

J. Windschill, Fleet Performance Assessment Manager

Nuclear Regulatory Commission

G. Shear, Acting Director, Division of Reactor Projects

R. Orlikowski, Acting Branch Chief, Branch 4 Division of Reactor Projects, Region III

K Stoedter, Senior Resident Inspector, Prairie Island

Attachment

LIST OF ITEMS

Opened

None

Closed

None

Discussed

None Attachment