ML20147C557
| ML20147C557 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 02/25/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20147C519 | List: |
| References | |
| 50-282-87-01, 50-282-87-1, 50-306-87-01, 50-306-87-1, NUDOCS 8803030107 | |
| Download: ML20147C557 (30) | |
See also: IR 05000282/1987001
Text
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SALP BOARD REPORT'
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U.S. NUCLEAR REGULATORY COMMISSION.
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REGION III
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SYSTEMATIC' ASSESSMENT OF-LICENSEE PERFORMANCE
50-282/87001; 50-306/87001
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Inspection-Report No.
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Northern States Power Co.
Name of Licensee
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Prairie Island Units 1 and 2
Name of Facility
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June 1, 1986 through November 30, 1987
Assessment Period
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-8803030107 880225 U
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- - TABLE OF CONTENTS
Page No.
I. -INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . .. 1~
. II. CRITERIA. . ._. . . ._. . . . . . . . . . . . . . . . ._. . . . 2
III . SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . . . . . 4
IV. PERFORMANCE ANALYSIS. . . . . .,. . . . . . . . . . . . . . . . 5
A. Plant Operations . . . . . . . . . . . . . . . . . . . . . 5
B. Radiological Controls. . . . . . . . . . . . . . . . . . . 7'
C. ' Maintenance. . . . . . . . . . . . . . . . . . . . . ... . 8
0. Surveillance . . . . . . . . . . . . . . . . . . . . . . . 9
E. Fire Protection. . . . . . . . . . . . . . . . . . . . . . 10.
F. ' Emergency Preparedness . . . . . . . . . . . . . . . . . . 12
G. Security . . . . . . . . . . . . . . . . . . . . . . . . .. 13
H. Outages. . . . . . . . . . . . . . . . . . . . . . . . . . 14
I. Quality Programs and Administrative Controls
Affecting Quality . . . . . . . . . . . . . . . . . . . 15
J. Licensing Activities . . . . . . . . . . . . . . . . . . . 17
K. Training and Qualification Effectiveness . . . . . . . . . 18
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . . 21
A. Licensee Activities.. ............,...... 21
B. Inspection Activities. . . . . . . . . . . . . . . . . . . 22
C. Investigations and Allegations Review. . . . . . . . . . . 24
D. Escalated Enforcement Actions. . . . . . . . . . . . . . . 24
E. Licensee Conferences Held During Assessment Period . . . . 24
F. Confirmatory Action Letters (CALs) . . . . . . . . . . . . 25
G. Review of Licensee Event Reports and
10 CFR Part 21 Reports Submitted by the Licensee . . . . 25
H. Licensing Activities. . . . . . . . . . . . . . . . . . . 26
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SALP 7
I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used
to ensure compliance to NRC rules and regulations. SALP is intended to
be sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant operation.
An NRC SALP Board, composed of staff members listed below, met on
January 20, 1988, and on February 8,-1988, to review the collection of
performance observations and data to assess licensee performance in
accordance with the guidance in NRC Manual Chapter 0516 "Systematic
Assessment of Licensee Performance." A summary of the guidance and
evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at the Prairie Island Nuclear Generating Plant for the period
June 1, 1986 through November 30, 1987.
SALP Board for Prairie Island Nuclear Generating Plant:
Name Title
C. J. Paperiello Deputy Regional Administrator
- J. A. Hind SALP Board Chairman, Director, Division
of Radiological Safety and Safeguards
- H. J. Miller Director, Division of Reactor Safety
- C E. Norelius Director, Division of Reactor Projects
- W. G. Guldemond Chief, Reactor Projects, Branch 2
- J. E. Hard Senior Resident Inspector, Division of
Reactor Projects
- D. Dilanni Licensing Project Manager, NRR
- D. Wigginton Acting Director, Project Directorate III-3
R. W. DeFayette Chief, Reactor Projects, Section 28
W. L. Axelson Chief, Technical Support Staff
R. L. Greger Chief, Facilities Radiation Protection
Section
W. B. Grant Specialist Inspector, Facilities Radiation
Protection Section
W. G. Snell Chief, Emergency Preparedness Section
M. J. Smith Specialist Inspector, Emergency
Preparedness Section
B. S. Drouin Specialist Inspector, Safeguards Section
D. Passehl Project Inspector
"Voting Members
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II. CRITERIA-
The licensee performance is assessed in selected functional areas
each of.which represents an area significant'to nuclear safety and the
environment and which corresponds to a normal programmatic area. Some
functional areas may not be assessed because of little or no licensee
activities, or lack of meaningful observations in that area. Special
areas may be added to highlight significant observations.
The following evaluation criteria were used in assessing each functional
area.
1. Management involvement in ensuring quality.
2. Approach to resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history,
5. Operational events (including response to, analysis of, and-
corrective actions for).
6. Staffing (including management).
However, the SALP Board is not limited to these criteria, and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and/or
construction quality is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety and quality is being achieved.
Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used, so that minimally satisfactory
performance with respect to operational safety is being achieved.
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' Trend: The SALP; Board may include an' assessment of the ' performance trend .
., of,a functional area. Normally this' performance trend is only used
. .where both a definite trend of. performance is discernible to the Board
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and the Board believes that continuation of.the trend may resultiin a-
. change of. performance level.
The-trend,~if=used, is defined as:-
a. Improving -
Licensee performance was determinedLto be improving near'the'close
'of the assessment period.
b.. Declining-
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Licensee performance'was determined to be declining near the'close.
of the assessment period.
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III. SUMMARY OF RESULTS
Overall, the licensee's performance during this assessment period was
-excellent. Six functional areas maintained Category I ratings. One area
(Surveillance) improved from a Category 2 to a Category 1 rating. .Four
areas maintained Category.2 ratings. No areas declined, and there were
no Category 3-ratings. Operations, which maintained a Category 2 rating,
showed an improving trend near the end of the period, and if that trend
continues, should improve to a Category 1 during the next assessment
period. Management involvement in plant activities is one of the
strengths at Prairie Island.
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Rating Last Rating This
Functional Area Period (SALP 6) Period (SALP 7)
A. Plant Operations 2 2
9. Radiological Controls 1 1
C. Maintenance 1 1
0. Surveillance 2 1
E. Fire Protection 2 2
F. Emergency Preparedness 1 1
G. Security 1 1
H. Outages 1 1
I. Quality Programs and
Administrative Controls
Affecting Quality 2 2
J. Licensing Activities 1 1
K. Training and Qualification
Effectiveness 2 2
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IV. PERFORMANCE ANALYSIS
A. Plant Operations -
1. Analysis
Evaluation of this functional area was based on the results of
routine inspections conducted by ragion-based, resident, and
special Hid-SALP team inspectors.
Enforcement experience in this area was about the same as in
the previous assessment-period in terms of number of violations,
but with a slight increase in severity. During this 18-month-
assessment period, one Severity Level III violation, three '
Severity Level IV violations, and one Severity Level V violation-
were identified. No common element could be identified as the-
main cause of these violations. One violation resulted from
an oversight in making a 10 CFR 50.72 report promptly, two
resulted from inadequate procedures, one was the result of a
poor physics prediction of core leakage, and the Severity
Level III violation resulted from a personnel error along with
poor equipment design and inadequate training. During the
previous assessment period there'were three Severity Level IV
and two Severity Level V violations in this area.
During the assessment period, there were four reactor trips.
Three were on Unit I and one was on Unit 2. One of these was
attributable to operations personnel. All trips were from
significant reactor power (>15%). During the previous
assessment period there were six trips, four on Unit I and
two on Unit 2.
There were five licensee event reports (LERs) attributable to
operations personnel error, one of which, failure to properly
rack in a 4160V breaker, was viewed as safety significant.
There were six LERs due to operations personnel in the previous
assessment period.
Management's involvement in ensuring quality was evident during
the assessment period. Significant management changes were
instituted to improve the morale and performance of Operations
personnel. Specifically, a new General Superintendent of
Operations position was established and filled with an
individual who has broad experience both inside and outside the
plant. In addition, Shift Managers are being assigned to each
crew to provide coordination for the two shift supervisors and
to relieve shif t supervisors of some of their administrative
burdens. This Shift Manager program is to be fully implemented i
in 1988. In conjunction with these organizational improvements, the
licensee has had in effect for several years a technical
degree program for shift supervisors. With this program, the
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employee attends classes at a nearby college for a quarter,
returns to work for a quarter, and repeats this cycle until
a degree is obtained. Four shift supervisors'have received
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degrees with this program, and.another four are currendy in
.the program.
Another management decision which should improve long term
performance is the addition of two operators to each of the
six crews. Also, one-very experienced operator has been
assigned to. provide on-the-job training for new unlicensed
operators. .Because of these and other changes in the
Operations ~0epartment during the assessment period, poor
operator morale discussed in the Prairie Island SALP 6 report
appears to have been alleviated.
Plant management continues to be generally sensitive to the
concerns and initiatives of the NRC. For example, the question
of operator morale (highlighted in the previous SALP report)
was resolved in a comprehensive manner. Significant
reassessments of in plant procedures during review and follow-up
of plant occurrences were also performed.
The overall performance of the Operations group continues to
be good. One example of this is the superior operating
record during the assessment period. Unit 2 is completing its
third continuous operating run of more than 300 days. (At the
end of the assessment period, Unit 2 had run continuously for
more than a year.) Unit 1 and Unit 2 availability for the
period was 97.6% and 99.9%, respectively, excluding scheduled
outage time, and 88.3% and 93.9%, respectively, including
outage time. Control room decorum is good. Noise levels are
acceptable, and operators are professional in the performance
of their duties. Non professional reading materials are not
found in the control room, and an overall businesslike
atmosphere prevails. In response to an NRC order to remove
radios from the control room at Monticello, the licensee's
management removed them from both Monticello and Prairie Island.
2. Conclusion
The licensee's performance is rated Category 2 in this
functional area with an improving trend. The Board notes i. hat
there has been improvement by the licensee in this area. The
licensee was rated Category 2 in the previous assessment
period.
3. Board Recommendations
None.
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B. Radiole-* al Controls.
1. Analysis
Evaluation of this functional area was based on the results:of
one mid-SALP team inspection performed during the assessment
period by region based specialists and on observations by the
resident inspectors as part of the routine inspection program.
Enforcement history was. good in this area. No violations were
identified during this assessment period. One violation was
identified during the last assessment period.
Staffing continues to be a licensee strength. The radiation
protection staff has been exceptionally stable. The chemistry
group is small but also stable and efficient. Interactions
between specialists are good.
Management involver.cnt and support in this functional area
remains very good. There is consistent evidence that managers
and supervisors are involved in the day-to-day activities of
the pl6nt.
Licensee responsiveness to NRC issues was good during the
assessment period. A positive lockout procedure requiring
plant manager approval for entry into Very High Radiation Areas
was implemented in response to NRC Information Notice 86-107,
which deals with entries into PWR reactor cavities.
The licensee's approach to resolution of technical issues
continues to be very good. Collective doses for the last two
years (1986/1987) were 245 and 134 person Rems, respectively,
which are very low doses for the industry. ALARA reviews were
conducted when warranted, and good ALARA engineering was
accomplished. The effectiveness of the ALARA program is
reflected in the licensee's low collective dose history. Area
and personal contamination controls remain very good. The
licensee was well prepared for radiological problems associated
with the fuel rod consolidation activities (October-November
1987), including hot particles. While there was approximately
a twofold increase in detected hot particle areas and personnel
contaminations as a result of the fuel rod consolidation
activities, no significant personal exposures resulted.
Significant improvements during the assessment period included:
installation of new area radiation mo.11 tors and personal
whole body friskers; use of a super compactor for low level
radioactive waste; laundry facility upgrade; reduction in
contaminated areas; and silica removal from the Spent Fuel Pool
and Refueling Water Storage Tank using a reverse osmosis system.
No problems were identified with solid radioactive waste or the
radioactive waste transportation programs. Liquid and gaseous
releases continue to be viry low with resulting offsite doses
less than 0.1% of allowed limits.
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In limited confirmatory measurements comparisons, the licensee
did very well-in~ radiological measurements with twelve
agreements .in-twelve comparisons of spiked samples furnished by '
the inspector._ The results of nonradiological confirmatory
measurements-were reasonably good with seven agreements in nine
comparisons. 'The two disagreements (both fluoride) were within
ten percent of NRC standard values.
2. Conclusion
This licensee's performance is rated Category 1 in this
functional area. The licensee was rated Category 1 during the
previous assessment period.
3. Board Recommendations
None.
C. Maintenance
1. Analysis
Evaluation of this functional area was based on the results of
routine inspections conducted by the resident inspectors and
portions of one special region based inspection.
Enforcement history in this area indicated a slight decline
during this assessment period because three violations were
identified (Severity Level IV's) compared to no violations
identified during the previous period. The violations indicated
a minor weakness in licensee performance and program adherence,
but were not repetitive. Corrective actions were prompt and
effective.
Six events that involved personnel errors attributed to
activities in this functional area reautred the submittal of
LERs. One of the events resulted in a reactor trip. This is
an increase compared to the pre tous assessment period although
improved performance in this regard was seen in the last six
months of the assessment period. The previous assessment period
had one maintenance related LER attributable to personnel error.
The common element in these errors was a lack of attention to
detail by relay maintenance and construction personnel and
indicates a need for increased emphasis on being more methodical, i
A plant record 370 day continuous run (as of the end of this
assessment period) for Unit No. 2 was a significant achievement.
For a multi-unit plant, availability was the best in the United
States. The forced outage rate during this assessment period
was lower than for the previous SALP period. This performance
is indicative of a well maintained plant. ,
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Numerous plant improvements were completed during the period
including replacing the upper reactor vessel internals on both
units, replacing the reactor-coolant pump motor resistance
rings,:and changing out control rods on Unit No. 1.
Management-involvement in ensuring quality was evident by work
site tours by all maintenance supervisory personnel,~and by
continued development and improvement in preventive and
corrective maintenance procedures, with management emphasis on
improving quality. This is further evidenced by management's
commitment to purchase duplicate plant components for use by.
plant staff for rehearsals, troubleshooting problems,.and as
training aids. ~The practice of rehearsing maintenance
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activities on identical equipment in the maintenance shop's
training area before performing the activity on the plant
equipment is a big contributor to the success of the
maintenance. program. High plant availability, low forced
outage rates, and low work request backlogs are indicative of
an aggressive maintenance. program with strong management
support. A long term program of monitoring secondary-side pipe
erosion had been in effect prior to the Surry event.
The Maintenance Group response to NRC initiatives has been
prompt as evidenced by its timely review and resolution of
potential problems detailed in Information Notices, Bulletins,
and Generic Letters. Resolution of technical issues from a
safety standpoint'has been evidenced by programs and
modifications identified above that were performed to increase
plant and personnel safety.
Staffing was increased by six personnel. Low turnover and an
average experience level of 14 years continues to be one of the
strong points of this functional area.
2. Conclusion
The licensee's performance is rated Category 1 in this
functional area. The licensee was rated Category 1 in this
area during the previous assessment period.
3. Board Recommendations
None.
D. Surveillance
1. Analysis
Evaluatien of this functional area was based on the results
of routine inspections conducted by the resident inspectors.
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SALP 7
Enforcement history improved considerably in this area. Though
there were three late surveillances as a result of a single
oversight, no nothes of violation were written in this
functional area. During the previous assessment period, three
Severity Level IV and three Severity Level V violations were
identified.
Three surveillance related LERs, att,ibutable to personnel error,
were reported during the period: (1) failure to follow a
procedure because of poor communications causing a reactor trip
and safety injection; (2) a second event, essentially a repeat
of (1); and (3) the late surveillances discussed above. During
the previous assessment period two LERs were submitted relating
to this functional area.
As a result of the two reactor trips discussed above and
previous trips from the same cause, licensee management became
involved in corrective actions and directed that the safeguards
logic test procedure be reviewed and revised to minimize the
chance of personnel error causing an actual trip. As a result
of this review the procedure was simplified considerably.
However, the NRC believes that more expeditious and timely
management involvement could have prevented both of the reactor
trips.
Despite this lack of timely procedure revisions, management and
administration of the surveillance program is in general very
effective as evidenced by the very low rate of late or missed
surveillances. Furthermore, staffing is excellent in this area.
One engineer is assigned full time to manage the program.
The licensee voluntarily exceeds regulatory surveillance
requirements in such areas as steam generator tube inspection
and feedwater piping inspection. The feedwater piping
inspection program has been in place since plant startup, well
before the Surry accident.
2. Conclusions
The licensee's performance is rated Category 1 in this functional
area. The licensee was rated Category 2 during the pievious
assessment period.
3. Board Recommendations
None.
E. Fire Protection
1. Analysis
Evaluation of this functional area was based on the re;ults of
one special inspection conducted by a region based inssector
and consultants and on observations by the rasident inspectors
as part of the routine inspection program.
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Enforcement history declined in this area from the last
assessment period. Early in the assessment period a Severity
Level IV violation was identified when a penetration fire .
barrier was found to have been inoperable for a period of time
in' excess of TS requirements. In addition, during the special
inspection which was conducted to determine licensee
implementation of and compliance to the requirements of-
10 CFR 50, Appendix R (Sections III.~ G, J, L, and 0), two
significant Severity Level IV violations were identified
regarding the lack of breaker coordination and lack of
redundant fusing of associated circuits. Emergency lighting
units were also not installed as required in two areas of the
plant. There were no violations identified during the previous
assessment period. '
While management involvement in this functional area was evident
by the attendance of corporate personnel at the er.it meeting and
involvement of station management during the week of the
Appendix R inspection, deficiencies in program oversight were
evident by the number of violations. The licensee's approach
to the resolution of technical issues from a safety standpoint
after discussions with the inspection team was generally
technically sound, and the majority of the issues were
scheduled to be corrected in a timely manner.
Positive points observed were fire brigade drills which
were well executed and fire brigade training sessions which
included comprehensive presentations.
The licensee's training and staffing was considered adequate
as determined by the walkdown of the safe shutdown procedure.
Significant achievements during the assessment period included:
major cleanup of the plant site and turbine and auxiliary
buildings with all removed materials stored in a new warehouse;
a three year painting program for the turbine, auxiliary, and
out buildings; and a new oil and chemical storage building.
Cleanliness of the plant has been improved significantly and
has reduced the fire hazard potential throughout the plant.
The improved cleanliness also has had a positive effect on
plant personnel attitudes.
2. Conclusion
The licensee is rated Category 2 in this area. The licensee was
rated Category 2 in this area during the previous assessment
period.
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3. Bl ard Recommendations
None.
1. Analysis
Evaluation of this functional area was based on one special
inspection and on evaluation of the 1986 annual exercise by
regional-based inspectors. Observations by resident inspectors
of the weekly alert siren system tests and of the 1987 annual
emergency preparedness exercise also contributed to this
evaluation.
Enforcement history remained constant during this assessment
period. No violations were identified during this or the ,
previous assessment period.
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Management involvement in ensuring quality.in this aret has been
consistently at a level which ensures adequate plant manegement-
review of the emergency plan and, implementing procedures.-
Corporate management was frequently involved in site activities
such as exercise participation, training of offsite agencies,
and media briefings. The licensee integrated the Emergency
Preparedness Program into its total plant operational program.
There were no long-standing regulatory issues attributable to
the licensee.
Plant emergency response staffing in this area was adequate.
Authorities and responsibilities of emergency personnel were ;
well defined. Key emergency personnel were experienced and
knowledgeable in emergency plan procedures and in their
responsibilities.
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No weakneswes were identified during the 1986 or 1987 exercises.
Licensee personnel adequately demonstrated their ability to
mitigate the consequences of an accident, to notify offsite
authorities, and to make protective action recommendations to
them. The 1986 exercise scenario was sufficiently challenging
to test the abilities of licensee personnel to respond to an
accident situation. This scenario was an improvement over
the 1985 exercises and demonstrates licensee management
responsiveness to NRC identified items.
2. Conclusion
Licensee performance is rated Category 1 in this area. The
licensee was rated Category 1 during the previous assessment
period.
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3. Board Recommendations
None.
G. Security
1. Analysis
Evaluation of this functional area was based on the results of
portions of one Region III team inspection and on the
observations of the resident inspectors as part of the routine
inspection program.
The licensee's enforcement history improved during this
assessment period. One Severity Level V violation was. identified, t
There were three Severity Level IV violations identified during
the previous assessment period.
Management's involvement in ensuring quality was excellent.
Management support was demonstrated through the acquisition of
new entry search equipment and the upgrading of existing
equipment (intrusion detection system and a perimeter fence).
A comprehensive security testing program assures reliability
and early identification and solution of problems. Management
has taken an active role in controlling and reducing vital area
access without impacting on plant safety. The security audit
program is comprehensive and is a significant contributor to
overall security program effectiveness.
The licensee's approach to resolving technical security issues
was adequate as noted in the following examples: (1) even
though the security computer satisfies NRC's requirements, it
is old and experiences periodic failures. To solve these
failures, the licensee has assigned an engineer to work full
time on the system and in 1988 will evaluate system replacement;
and (2) an alarm station which requires relocation to a more
suitable environment will be relocated after a new Administration
Building is completed in 1989.
The licensee's responsiveness to NRC initiatives has been
excellent. A detailed review of vital area access controls and
security barriers was conducted by the licensee in response to
NRC notices. An observation concerning the protection of
safeguards information identified during the Region III team
inspection was immediately corrected.
Security event reporting was good. There were seven reports this
period, compared to nine in the preceding period. Six reports
were computer failures. One resulted from a bomb threat. All
reports were timely, accurate, and properly analyzed, and
presented detailed corrective actions.
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^ lStaffingLwas-' good:and assured the proper administrationfof the.
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fsecurity program. The security' shift, supervisors;have been
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(' '. t > Jeffectivelycintegrated into security operations. The chain ofJ
command is.wellEdefined and functionsjefficiently.
- Security training was.notDspecifically, reviewed during t'his
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. knowledgeable of their_ duties, andLno violations,were. attributed
- to, security force errors. These-results may be indicative of.
-an effective training program. :InTaddition, 16 members of_the
< Guard' Force _are certified emergency medical J technicians 'and,'as
ca result', the Guard Force is more readily-accepted-by plant
employees,
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The' licensee is, rated; Category 1 in this functional-area..'The
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- licensee was rated Category 1 during the previous assessment
period.
3. ' Board Recommendations
None.
H. Outages
1. Analysis
'
Evaluation of'this functional area was based on the results of
routine inspections conducted by the resident inspectors.
Enforcement history in this area during the assessment period
was good. No violations were identified during this assessment
- , period._ Two Severity Level IV violations were identified during
~
-the last asse'ssment period. Similarly, no LERs'were attributed
to this area. ~There was one LER attributed to this-area during
~
the previous period.
Two refueling outages were conducted during the assessment
period, one on each unit. Most of the work was accomplished
smoothly, on time, and with no major operational problems.
Recovery from the outages were not impacted by any outage-related
activity.
Outage planning continues to receive close management scrutiny.
A small dedicated planning staff works full time on this function.
During outages, this group provides hour-to-hour guidance to all
personnel concerned and involved with outage work. Daily
, morning meetings are conducted to brief plant staff on work
progress and to discuss any problems which have been encountered
or which could impact the schedule. During plant operation, the
group prepares lists of work activities which could be accompl{3hed
.
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.SALP 7
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during any unplanned outage and reviews this list ~ routinely.
Thus, there is always a current work activity list which could
be implemented immediately if the reactor was. shut down .. ~
unexpectedly for any' period of time. Implementation of these
.work activities and of. activities required for unplanned
outages in general is accomplished in an excellent manner, as
noted by licensee response to four. unplanned outages for Unit -1
during this assessment period.
Staffing for outage work is ample. Much of the work is
performed by the licensee's' site staff with assistance from
other company personnel. When needed, contractor personnel are
also used. All of the non-site personnel are trained,
supervised, and controlled in a manner to ensure control over
work activities.
There was one NRC. initiative directly related to outages
(Information Notice 87-23 and Generic Letter 87-12) which was
related to loss of decay heat removal during low reactor coolant
level operations, such as during outages. The licensee's
response to this initiative was timely and conprehensive and
retraining of operators concerning operation of the residual
heat removal system at reduced levels was completed.
2. Conclusion
The licensee is rated Category 1 in this functional area.
The licensee was rated Category 1 during the previous
assessment period.
3. Board Recommendations
None.
I. Quality Programs and Administrative Controls Affecting Qualig
1. Analysis
Evaluation of this functional area addresses two related but
separate functions. First, it assesses the licensee's
management activities aimed at achieving quality in overall
plant operations. As such, strengths and weaknesses identified
in other functional areas were reviewed to determine if common
attributes could be identified. In addition, licensee
initiatives to maintain or improve the overall quality of
operations were considered.
The second function assessed in this area is the effectiveness
of the licensee's independent quality organizations. This
includes the Quality Assurance organization as well as other
organizations that serve to independently review licensee
activities to identify problems and ensure corrective action.
15
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SALP 7
.
.
Overall management involvement _in ensuring quality of
day-to-day. operations remained a strength at Prairie Island.
Plant management was frequently involved in in plant activities,-
including monitoring activities in progress. Staffing stability
is indicative of a good working relationship between management
and staff. During this period, management took aggressive steps
to resolve morale problems that existed in the Operations
Department. In addition, the licensee has undertaken a number
of initiatives at considerable resource expenditure to improve
, the overall quality.of the Prairie Island operation. Among these
initiatives were adoption of the Shift Manager concept, a
commitment to add more operators on each shift, and an extensive
plant systems component labeling program identifying Unit No. 1.
Unit No. 2, and common components. In response.to concerns
raised by the NRC it also initiated planning to expand the
emergency on site electric power capability, and initiated a
comprehensive "pursuit of excellence" program which includes a
sefety system functional inspection program.
.
In areas less directly related to day-to-day plant operations,
some areas of weakness were identified. Examples include
shortcomings in the implementation of 10 CFR 50, Appendix R
requirements and overall poor performance on licensed operator
examinations. With respect to this latter item, licensee
management undertook a series of steps late in the assessment
period to improve performance.
Overall, mixed performance was achieved regarding resolution
of technical issues from a safety standpoint. In a positive
sense, management's commitment to the System Engineer concept
continued to ensure quality and timely support for problem
resolution and licensing issues in a technically sound manner.
Additionally, a proactive posture has been adopted regarding
surveillance and testing (i.e., stcam generator tube
inspections). However, some weaknesses were evidenced in a
number of instances, most notably in the untimely resolution
of a surveillance procedure deficiency which led to multiple
reactor trips, lack of aggressiveness in resolving switchyard
activity control issues, and iacomplete initial response to
river water contamination of cooling water systems.
Evaluation of the performance of the licensee's independent
l quality oversight organizations was based on routine
inspections by resident and regional inspections.
i
No violations were identified in this area during this
l assessment period compared to three Severity Level IV
l violations identified during the previous period.
l
! A self-initiated audit of the administration and management of
the Corporate Nuclear Operations QA Section by an outside
consultant concluded that the licensee's audit program is very
1
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SALP 7
effective. In part, this is the. result of efforts to staff the
section with well qualified and experienced personnel and to
provide specific reactor plant training to the auditors through
. participation in the operator training programs. Also, to
provide better coverage of the plant, Corporate QA is planning
to assign an auditor full time to the site, beginning in 1988.
2. Conclusion
The licensee's performance is rated Category 2 in this
functional area. The licensee was rated Category 2 during
the previous assessment period.
.3. Board Recommendations
None.
-J. Licensing Activities
1. Analysis
The basis for this evaluation was the licensee's performance in
support of licensing actions (amendment requests, responses to
generic letters, and other actions) which have been reviewed and
evaluated by the staff during the assessment period. Tiecse
actions have resulted in four license amendments for each unit
and changes to the Technical Specifications, clarification of
seven relief requests associated with the second 10 year IST
program for pumps and valves, and changes to the 1981 LOCA model
for analyzing postulated accidents for Unit No. 1 Cycle 12.
During this SALP assessment period, the licensee's management
was active and kept abreast of all current and anticipated
licensing activities. Licensee submittals were consistently of
high quality and timely, and did not require significant rework
to address staff requirements. These attributes were a
significant factor in maintair.;ng a low number of licensing open
items. At the beginning of the assessment period, there were 13
open licensing issues. Subsequently, 11 new licensing actions
were initiated during this assessment period. Of these 24
licensing issues, only nine issues remained open at the end of
the period. This licensing status was possible only because of
the company's policy for providing quality licensing submittals
and for aggressive participation with the project manager to
resolve safety issues. In the actions involving modification to
the technical specifications (including those associated with the
hot channel factors, reactor coolant heatup and cooldown curves,
radiation environmental program, etc.), the licensee's
management demonstrateo consistent evidence of planning,
scheduling, and control of these licensing activities.
Submittals were well prepared and technically sound and
17
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SALP 7
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exhibited a conscientious. effort to. comply with the regulations.
In one technical specification change request,~the licensee
demonstrated that-it would go to considerable expense and effort
to improve plant safety by proposing numerous. changes throughout
the technical specifications in support of the human error.
.- reduction program. This change request was further expanded to
include elements of the standard technical specifications which
should result in an upgrade of.the Prairie Island technical.
specifications.
2. Conclusion-
The licensee's performance is rated Category 1 in this functional
area. The licensee was rated Category 1 during the previous
assessment period.
-
3. Board Recommendations
None.
K. Training and Qualification Effectiveness
1. Analysis
Evaluation of this functional area was based on the results of
licensed operator replacement and requalification examinations
administered by the NRC during the' assessment period; routine
inspections of licensed operator requalification training,
non-licensed staff training, and general employee training
performed by the Resident Inspectors; and review of reportable
events and violations by the Resident Inspectors to determine
whether lack of training effectiveness was a contributing factor.
While no violations of NRC requirements relative to training were
identified, lack of training effectiveness was identified as a
contributing factor in a number of reportable events, the most
significant of which involved a failure on the part of a
non-licensed operator to properly restore a safety injection pump
breaker to an operable status. . Additionally, collectively poor
performance on the part of Senior Reactor Operators on NRC
administered requalification examinations midway through the
period resulted in an unsatisfactory rating for the licensed
operator requalification program, issuance of a Confirmatory
Action Letter (CAL-RIII-87-013) regarding ree dial measures to
be taken, snd two management meetings.
Management involvement in ensuring quality yielded mixed
results in this area. The pass rate on Senior Reactor Operator
replacement examinations, while improved from the last evaluation
period, was low overall. Requalification examination results
led the NRC to declare the requalification training program
unsatisfactory. This was the second such finding, the first
j occurring in 1985. In a positive sense, following the second
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unsatisfactory rating of the.requalification program, the .
'
.
licensee undertook three initiatives to improve the_ quality and
effectiveness of training. The first was the development of a
certification program for systems engineers and management
personnel which supplants license training and allows license
..
. training resources to be focused on replacement and
requalification training. The second initiative involves
development of an advanced Senior Reactor Operator course.
This course is designed for long-standing license holders and
will periodically provide 11 weeks of intensive "back to basics"
retraining comparable to initial license training. The third
initiative involves rotation of shift supervisors and training
instructors for two year periods.
The licensee completed development of its performance based
training programs and received accreditation in all areas
recognized by INPO. As noted in Section IV.A.,-the licensee
has a technical degree program for shift supervisors which
allows them to attend a nearby college and obtain a technical
degree. Also noted in that section is the experienced'
operator who has been assigned to provide on-the-job training
for new unlicensed operators. As noted in Section IV.C.,
maintenance activities are rehearsed on identical equipment in
the maintenance training area before the ' activity is done on
the real equipment. Training, staffing, and program
implementation was found to be satisfactory during routine
reviews. Additionally, these reviews identified that viable
mechanisms exist for feedback of operating events into the
training programs.
In the latter half of the evaluation period, licensee
responsiveness to and communications with the NRC improved.
Some basic disagreements in the focus of the training program
were resolved with the result that the licensee is now devoting
more atteation to abnormal and emergency events, the approach
to procedural usage has been strengthened, and program scope as
it relates to overall knowledge has t,een expanded. In addition,
management responsibility for licensed operator training was
reassigned both at the plant and at the corporate level to
address identified weaknesses, and the licensee has initiated
a number of meetings with the NRC to improve communications
and resolve matters of common concern. One effect of these
changes was improved pass rates on Senior Reactor Operator
replacement examinations late in the assessment period.
2. Conclusion
The licensee is rated Category 2 in this functional area.
The licensee was rated Category 2 during the previous
assessment period.
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3. ' Beard Recommendations
-The board notes that in--an inspection subsequent:to the SALP-
'
> period for followup on the CAL, the inspectors. identified a
-continuing. lack of management involvement in ensuring quality
in the licensed operator requalification program.~ This will
.
be followed closely by the NRC during the next SALP assessment.
pe ri od.'
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V. SUPPORTING DATA AND SUMMARIES-
~A. Licensee Activities
1. Unit 1
Prairie Island Unit-1 began this. assessment period base loaded
and operating-at 100% power. Significant outages or major
~
events which occurred during the assessment period are summarized
below:
Significant Outages / Major Events
a. December 12-13, 1986 - Unit I shut down when an electrical
hydraulic controller became disabled,
b. February 20 - March 4, 1987 - Unit I underwent a controlled
shut down because of increasing primary to secondary
system leakage. The source of the leakage was identified
as steam generator tube leakage. Repairs were made.
c. March 30-31, 1987 - Unit 1 experienced an inadvertent
safety injection and reactor trip due to an improperly
performed surveillance. The unit remained down to flush
out injection lines and to deborate the reactor coolant
system.
d. April 7 - May 27, 1987 - Unit I was taken off line for
a scheduled refueling and maintenance outage. Major
activities included the replacement of all rod cluster
control assemblies and repairs to the main generator,
e. July 10-12, 1987 - Unit 1 experienced a planned shut down
to inspect all main generator resistance temperature
detectors and to repair a hydrogen cooling tube.
Unit 1 experienced eight ESF actuations*, including one safety
injection with flow to the vessel, and three reactor trips,
all from greater than 15% power. Unit l's reactor trips were
due to personnel error.
- 0ne steam exclusion damper closure was not included here.
2. Unit 2
Prairie Island Unit 2 began this assessment period base loaded
and operating at 100% power. Significant outages or major
events which occurred during the assessment period are summarized
below:
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Significant Outages / Major Events
a. July 28-29,1986~ - Unit 2 experienced an' inadvertent safety
injection due to an improperly performed surveillance which
resulted in a.short plant shut down to flush the safety
injection line and to remove any= concentrated boric acid
solution which was present.
October 22 through November 24, 1986 - Unit 2 was taken off
~
b.
line for a scheduled refueling and maintenance outage.
Major activities included: replacement of reactor upper
internals, steam generator tube eddy current. inspections,
plugging.21 steam generator tubes, and incore thimble
replacements.
Unit 2 experienced two ESF actuations, including one safety
injection with flow to the vessel and one reactor trip at greater.-
.than 15% power. The reactor trip was due-to a personnel error.
B. Inspection Activities
There were 21' inspection reports issued covering the assessment
period of June 1,1986 through November 30, 1987.
Significant inspection activities are listed in Paragraph 2 of
this section, "Special Inspection Summary."
1. Inspection Data
Facility Name: Prairie Island
Unit: 1
Docket No: 50-282
Inspection Report Nos: 86001, 86006, 86008 through 86012,
87002 through 37009, and 87011 through 87016.
Facility Name: Prairie Island
Unit: 2
Docket No: 50-306
Inspection Report Nos: 86001, 86006, 86010 through 86014,
87002 through G7009, and 87011 through 87015.
L
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6, - -
; Table I 1
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Numberiof~ Violations in Each Severity Level'
'
UNITi l ' UNIT 2: COMM0N-
Functional-Areas III IV V III IV V- III IV V.
A.. Plant' Operations. .
1 3 1
. B. Radiological Controls.
C. Maintenance 1. 1 1-
10. Surveillance
. E. Fire ~ Protection 1 2 '
G. Security 1
H. 0utages
I. Quality Prog. & Admn.
Controls Affecting
-Quality .
J. Licensing Activities
K. Training & Qualification
Effectiveness
'
UNIT 1 UNIT 2 COMMON-
TOTALS III IV V III IV V. III IV V
..
1. .4 2 1 31
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2.~ Special Inspection Summary
a.- .An energency preparedness inspection / exercise was.
conducted during June 16-19,.1986.(Inspection Report'Nos.
282/86006, 306/86006).
b. During the weeks of November 17 - December 2,'1986, a six
person team performed an environmental qualification
. inspection of electrical equipment within the scope of,
10'CFR 50.49 (282/86012, 306/86014).
c. .A special team inspection (mid-SALP) was conduct'ed during
May 11-15, 1987, to review plant activitiesfin accordance
with the Reduced Inspection Program (282/87006, 306/87006).
C. Investigations and Allegations Review
One allegation was reported and closed during this assessment
period, and one previously reported allegation was also closed.
D. Escalated Enforcement Actions
During this assessment period, the licensee paid a Civil Penalty in
the amount of $25,000. This action was based on failure to verify
that a power supply breaker for a safety injection pump was in the
properly racked position. The civil penalty was mitigated by 50%
because of licensee identification and reporting.
E. Licensee Conferences Held During Assessment Period
1. July 10, 1986 - Site, Management meeting with licensee
representatives to discuss the modification control process,
operational QA, security items, and diesel generator
reliability.
2. August 20, 1986 - Regional Office, Management meeting with
licensee representatives to discuss the Systematic Assessment
of Licensee Performance for December 1, 1984 through May 31,
1986.
3. September 12, 1986 - Site, Management meeting with licensee
representatives to discuss operator morale, modification
control process, fitness for duty implementation, IE Bulletin
86002, and the Davis-Besse Task Force conclusions.
4. December 2, 1986 - Site, Management meeting with licensee
representatives to discuss operator morale, modification
control process, security events, and the Raychem splice
inspection program.
5. May 27, 1987 - Corporate Office, Management meeting with
licensee representatives to discuss operator licensing issues.
24
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' 6.' July 9,'1987 - Corporate Office, Management meeti,g with
licensee representatives-to discussithe~ July 15, 1987
'
.
' enforcement conference,,the'new Northern States Power HQ .
emergency . center, requalification' exams, plant organization,
"- ; auxiliary feedwater pump problems, nuclear plant aging, "Y
femergency battery? room temperature, and' security. matters.
'
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? July'15, 1987J- Regional'0ffice, Enforcement Conference with
~
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licensee-representatives to discuss inspection findings 1
-
. concerning-the-inoperability of a safety' injection.pumplat-
Prairie Island.
'
8. August 10, 1987 - Regional Office, Management meeting with
licensee. representatives to discuss their assessment of recent
examination results and their plans for. corrective measures
concerning Prairie Island's requalification program.-
F. Confirmatory Action Letters (CALs)
One CAL was issued.during the assessment period on August 3, 1987
(CAL-RIII-87-013).. ~ The subject of the CAL was the licensed operator
requalification program. This CAL' remains open.
G. A Review of Licensee Event Reports and 10 CFR Part 21 Reports
Submitted by the Licensee
1. Licensee ~ Event Peports (LERs)
Unit 1
,
Prairie Island
Docket No: 50-282
LER Nos: 86006 through 86011, 87001 through 87019.
- There were 25 events during the assessment period.which were
assigned to Unit-1. (These were events which affected either
Unit 1 or equipment shared by both units.) Six of.these events
have been reported voluntarily; that is, NRC-rules and
regulations do not require reporting, but the licensee felt that
the reports would be of interest to the NRC. Of the 25 events,
'
52% (13) were due to personnel error, 16% (4) were the result
l. of procedural inadequacies, 8% (2) were the result of
l' component / equipment failures, 12% (3) were related to design
L
problems, 8% (2) were caused by management / quality assurance
E deficiencies, and 4% (1) fell into the external cause category.
!
L Unit 2
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Prairie Island
Docket No: 50-306
LER Nos: 86003, 86004, 86005
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There,were'three events assigned to Unit 2, all of which were
the result of personnel error.
'
Collectively,-Units 1 and 2 experienced 28111censee events
during this SALP period,. averaging about 1.6 events per month.
The frequency of events remains about the same,as in the last-
assessment period; however, LERs resulting from personnel
errors have increased by 11%,.and LERs resulting from procedural
errors increased by 10%.
Personnel Errors 46.0% (12) ~ 57% (16)
Procedure Inadequacies 4.0% ( 1) 14% ( 4)
Equipment / Component 0.0% ( 0). 7% ( 2)
Design Discrepancies' 27.0% ( 7) 11% ( 3)
Management /QA Defc. 11.5% ( 3) 7% ( 2)
External 0.0% ( 0) 4% ( 1)-
Other. 11.5% ( 3) 0% ( 0)
100.0% (26) 100% (28)*
- Includes 4 voluntary LERs
2. 10 CFR, Part 21 Reports
No 10 CFR, Part 21 reports originated at Prairie Island during
the assessment period.
H. Licensing Activities
1. NRR/ Licensee Meetings
July 26-30,-1986 Resolution of open issues related
to the detailed review of Control
Room Design
September 28 - October 2, 1986 Design review and field
inspection of Auxiliary Feedwater
System GI 124
March 3-6, 1987 Monitor the fire protection
inspection by Region III
(Compliance with Appendix R)
' April 26-30, 1987 Review and inspect plant
modifications during Unit I
refueling
August 14, 1987 Meetin0 held in Bethesda to
discuss spent fuel consolidation
safety evaluation
.
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h October 27-30,fl987 Witness' fuel rod consolidation
demonstration at r, pent fuel. pool
~
2. Commiss' ion Meetinas
None.
3. Schedular Exemptions
.
None.
4. Reliefs Granted
July ^13, 1987 A relief request (No. 69) was
granted for the second 10 year
inservice testing of pumps and
valves; in addition, relief
request Nos. 16, 18, 27, 57a,
57b, 57c, and 59 were modified.
5. Exemptions Denied
~
September 10, 1986 10 CFR, Part 73, Appendix B,
Section IV.C, shotgun training and
qualification from the hip firing
position.
6. Emergency Technical Specifications Issued
.None.
7. License Amendments Issued
Amendment Nos. 78 and 71 Changes to technical specification
August 28, 1987 requirements related to Generic
Letters 82-28 and 83-37 and NUREG
0737 Item II.F.2.
Amendment Nos. 79 and 72 Amendments change the expiration
i September 23, 1986 date of the facility operating
,
periods for both units.
l
l Amendment Nos. 80 and 73 Changes to technical
l.
November 14, 1986 specification requirements
l:
related to reactor coolant heatup
and cooldown curves, radiation
environmental monitoring program,
l
design features, clarifying
management review of the security
plans, and administrative changes
in Section 6.
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Amendment Nos.-81 and 74- . Change to the technical
July.8,:1987- ' specification relatedlto.the hotL
channel factors F delta-Q and F.
delta H-for the power distribution
limits.
8 .' ' Orders Issued
October:20, 1986 Orders to show cause why radios-
'should not be removed =from
control ~ room.
- May 1, 1987 Show cause order rescinded.
- ' ^
9. Licensing Actions
Open at beginning of period 13
' Number added during period 11
Number completed during period .15
Number open at end of period 9
,
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