ML20154N541
| ML20154N541 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 05/24/1988 |
| From: | Milano P Office of Nuclear Reactor Regulation |
| To: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| NUDOCS 8806020333 | |
| Download: ML20154N541 (11) | |
Text
_
s May 24, 1988
.l Docket b'o. 50-285 MEMOPAhDUM FOR:
L. J. Callan, Director Division of Reactor Projects Region IV THRU:'
Jose A. Calvo, Project Director Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects FROM:
Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects
SUBJECT:
DRAFT NRR INPUT FOR FORT CALHOUN STATION SALP FOR THE PERIOD OCTOBER 1, 1986 TO APRIL 30, 1988 Enclosed is the draft input for the Fort Calhoun Station SALP dealing with the category of Licensing Activities. The proposed overall performance rating in this functional area is Category 2.
This document and enclosure contain predecisional information and have not been distributed to the PDR/LPDR.
/s/
Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III, i
IV, Y and Special Projects
Enclosure:
Draft SALP Report Input i
DISTRIBUTION iDocketFileu T. Westerman, RIV P. Milano J. Calvo T, Rehm i
Plant File F. Miraglia T. Murley D. Crutchfield PD4 R/F P. Noonan P. Harrell L. Rubenstein NRC PDR Local PDR P. Noonan 0GC-Rockville E. Jordan J. Partlow ACRS (10)
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May 24,1988 p
6 Docket No. 50-285 MEMORANDUM FOR:
L. J. Callan, Director Division of Reactor Projects Region IV THRU:
Jose A. Calvo, Project Director Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects FROM:
Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects
SUBJECT:
DRAFT NPR INPUT FOR FORT CALHOUN STATION SALP FOR THE PERIOD OCTOBER 1, 1986 TO APRIL 30, 1988 Enclosed is the draft input for the Fort Calhoun Station SALP dealing with the category of Licensing Activities.
The proposed everall performance rating in this functional area is Category 2.
This document and enclosure contain predecisional infonnation and have not been distrit'uted to the PDR/LPDR.
/s/
Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III.
IV, Y and Special Projects
Enclosure:
Draft SALP Report Input DISTRIBUTION Docket File T. Westerman, RIV P. Milano J. Calvo T. Rehm Plant File F. Miraglia T. Murley D. Crutchfield PD4 R/F P. Noonan P. Harrell L. Rubenstein NRC PDR Local PDR P. Noonan OGC-Rockville E. Jordan J. Partlow ACRS(10)
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
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May 24, 1988 e....,.
Docket No. 50-285 MEMORANDUM FOR:
L. J. Callan, Director Division of Reactor Projects Region IV THRU:
Jose A. Calvo, Project Director Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects FROM:
Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III, IV, Y and Special Projects
SUBJECT:
DRAFT NRR INPUT FOR FORT CALHOUN STATION SALP FOR THE PERIOD OCTOBER 1, 1986 TO APRIL 30, 19CF Encicsed is the draft input for the Fort Calhoun Station SALP dealing with the categcry of Licensing Activities. The proposed overall performance rating in this functional area is Category 2.
This document anc' enclosure contain predecisional information ar.d have not beer distributed to the PDR/LPDR.
M Patrick D. Milano, Project Manager Project Directorate IV Division of Reactor Projects - III, IV, V and Special Projects
Enclosure:
Draft SALP Report Input l
l i
J.
Licensing Activities 1.
Analysis The assessment of the licensing activities for the Fort Calhoun Station represents the integration of inputs from the Operating Reactor Project Manager and the technical reviewers who provided significant effort en the licensing actions during the rating period. Using the guidelines in NRC Manual Chapter 0516, specific evaluation criteria were applied to the relevant licensee perfomance attributes and an overall rating category was assigned for each attribute. This infomation was provided to the Project Manager as an enclosure with the Safety Evaluation Reports corpleted for each licensing activity. The Project Panager utilized this information by combining it with his assessment of licensec perfomance and by using appropriate weighting factors bcsed on the complexity of the suteittal.
From this combination a rating for the licensee's performance in the functional areas was attained.
As stated, the basis for this assessment is the licensee's performance in suppcrt of significant licensing actions that were either completed or had a substantial level of activity during the rating period. These licensing actions are presented in the supporting data.
The attributes specified in NRC Panual Chapter 0516 as applicable to the functional area of licensing are:
a.
Management Involvement and Control in Assuring Quality b.
Approach to Resolution of Technical Issues from a Safety Standpoint c.
Responsiveness to NRC Initiatives d.
Reporting and Analysis of Reportable Events e.
Staffing 2.
Evaluation of Each Assessment Attribute a.
Management involvement and control in assuring quality The management attention cf the licensee toward the assurance cf c,uality in the resolution of issues of major significance remained at an acceptable level. During this period, the licensee management was specifically required to be actively involved in the resolution of concerns arising from reportable events.
In addition to havino to direct this activity, licensee management was required to rake detailed presentations on the impact of the events and corrective actions. These presentations were not initially successful in answering the basic infomation necessary for the NRC to make a determination of the significance and impact on plant operations. This was an indication that the 1
licensee management had not taken an aggressive approach
2-toward an understanding of the implications of the event and its outcome, and that the evaluation of the basic data was not fully controlled.
Subsequent rneetings were then required to obtain the necessary infomation.
In the area of more routine preparation of licensing actions, the basic documentation appears to be promptly developed and controlled. The quality of the documentation prepared to support licensing amendments and actions have been technically adequate in addressing the issues involved. While the amendment for the Cycle 11 Reload was well developed, others such as for the extension of the operating license duration and for the errergency diesel generator surveillance testing and reliability did lack some essential considerations which the licensee made available later. Also, the amendment requesting technical specification changes involving radioactive effluents was partially denied due to the potential concerns with exceeding concentrations en an instantaneous basis. Additional management attention or oversight may have prevented the concerns or the reiterative process for answering questions.
After the events surrounding the instrument air problem and the NPC inspection into the design mcdification processes, the lictnsee has irplemented several key programs which ray aid in the irprovement in these areas. An evaluation of the licensee r:anagerent organizaticnal relationships is being conducted by an independent agent to determine actions which can increase the efficiency and function of the organization.
Also, a design basis reconstitution program is in process.
This multi-year program will regain the necessary control over the design control process and reverify the design basis and.,;rgins as changed by the plant modifications.
In the interim until completion, the licensee is taking a conservation approach toward future changes that may further affect these margins.
Finally, of note, is the decision by the licensee to improve the reliability of the auxiliary feedwater system with the addition of a third AFW pump.
b.
Approach to resolution of technical issues from a safety standpoint As a result of the findings raised by the Safety System Outage Panagement Inspection (SSOMI), a comprehensive review of the design basis of safety-related air operated control valves was implemented.
From this review a number of safety issues were raised about the sustained operability of various valves after a design basis event. These issues required the licensee to evaluate the impact on continued operation of the facility.
The documentation to support this operation was generally not
- well detailed to allow an independent determination that the decision were appropriately reached and valid.
While the NRC staff reviews of selected decisions did not disagree with the finding, further information was needed from the technical preparer to come to the same conclusion.
During the instrument air event and the subsequent problems associated with the operation of the emergency diesel generators, the licensee approach toward resolution of the problems and understanding the significance of the safe operation of the facility was not adequate. The licensee made noncenservative decisions which allowed continued operation durirg a period when the status of many air operated components recuired for safe operation were of a questionable operability.
This item was the focus of an escalated enforcement action by the NRC.
c.
Respensiveness to NRC initiatives The licensee continues to rake progress on several significant safety issues. As previously stated, the AFW reliability will be enhanced by the completion of the comitment to install a third pump. Also, progress N,s been made tcward the resolution of generic issues on the control reem design and safety parareter display system. Further the design basis reconstitution program taken based en the SSOMI findings was a significant endeaver toward upgrading the control of the design of the facility.
In the area of licensing actions, the.esponse of the licensee to questions raised which required diret.t contact with the technical preparer has been generally well coordinated and titely, d.
Reporting and analysis of reportable events The single factor most affecting the determination of the licensee's degree of attainment for this attribute was the event surrounding the water ingress into the instrunent air systen. The NRC review of ti.e analysis found that the licensee took a less than conservative approach toward detennining operability for com>onents and systems. Additionally, the licensee did not ma ce a determination for the precursor event that the NRC should be notified.
No further discussion of this is necessa.y since it has been previously addressed and has been the scMeet of escalated enforcement action.
o 4
The design basis reconstitution program also has generated findings that are deterr:ined to be reportable. The analysis of the condition and the decision to report has been adequate.
Since this could create conditions which could affect operability of equipment, the licensee has had to analyze the impact on continued operation. These have been prepared and received the required reviews by the Plant Review Cemittee and Safety and Reliability Comittee. However, the documentation of the basis for the determination has been found in several cases to not be fully detailed in the report. Otherwise, the licensee's event reports appear to be comprehensive and well documented.
e.
Staffing The results of significant events and the findings of NRC inspec-tions have created an intensive workload for periods of time.
The licensing staff and technical support appear to be adequately staffed to handle the nortnal workload. During the periods of increased unplanned activity, the technical support for the acalysis effort has appeared to be overtayed. The tenporary assignment of technical assets to areas working on resolutions cf cencerns and problems may be a reans of alleviating shortfalls in staffir.g during these periods. The outcome of the independent caragement review will be watched to see if changes are recomended in the staffing and canagerent of this area.
3.
Conclusion The licensee's perforrance in the area of licensing activities during this rating period has been average.
The circunstances surrounding the events noted abcve were a major criticism of the activity that lead to the icwering of the previous grade in this area. Historically, the licensee has maintained a responsive licensing interface with the NRC and management control over the various licensing inputs. This has resulted in no need to request erergency relief for requirements and allows the routine reviev and amendment processing. The licensee must, however, ensure that closer reviews are conducted prior to submittal to the NRC to preclude the need for further requests for infonration.
While not significant for the final determination, the review processing tire could thus be improved.
l The overall rating of the licensee in the category of Licensing Activites is a grade of 2.
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. 4.
Board Reconmendations a.
Recommended NRC Actions The staff should increase its efforts toward review of licensee decisions on-plant operability as related to questionable seismic qualifications of certain equipment.
b.
Recommended Licensee Actions The licensee should continue with established programs for recenstitution of the design and evaluation of the staffing and ranagement. Technical reviews must be conducted in more detailed manner and documented such that an independent review can be successfully accomplished.
I I
SUPPORTING DATA AND SUMMARIES J.
Licensing Actions 1.
NPR/ Licensee Meetings November 5, 1987 Meeting in Bethesda, MD regarding the water ingress into the instrument air system.
November 13, 1988 Peeting in Bethesda, MD regarding further information on the above event.
2.
Comissien Meetings None 3.
NRC Site Visits August 17-21, 1987 Vendor Inspection Branch to review the inservice testing of check valves.
September 14-17, 1987 Combined Detailed Control Room Design Review and Safety Paramenter Display System.
October 14-15, 1987 Resolve tatstanding questions on second 10-year inservice testing period for purrps and valves.
February 1-5, 1908 Inspection of the Health Physics Program April 4-8, 1988 Followup inspection to review status of firdings from the 1986 Safety System OutageManagementInspection(SS0MI).
4.
Schedular Exemptions Granted Extension of time to coniplete the Thennal Shield Support Inspections under OPPD letter dated April 4, 1984, on January 12, 1987 Extension on date of implementation of USNRC Regulatory Guide 1.97 on February 20, 1987 One-time extension of the surveillance inspection interval for Diesel Generator No. 2 on April 18, 1988
0
- i 5.
Relief Granted Relief from ASME Code Section XI requirements for inspection of inaccessible welds in the main steam and feedwater systems.
Staff letter dated on November 10, 1986.
Pelief from the ASME requirements for visual inspection of the reactor pressure vessel interior, except when the core support vesel is removed.
Staff letter dated April 1, 1987.
6.
Exemptions Granted Schedular exemption for the relief from property insurance requirerents of 10 CFR 50.54(w)(1).
Staff letter dated December 2, 1087.
See other exenptions in section 4 above.
7.
Emercency Action Granted None 8.
Licensee Arendments Issued Amendment No. Date Description 101 November 24, 1986 Organizational Changes 102 January 20, 1987 Reporting requirements for primary coolant iodine spike 103 March 9, 1987 Modifies boren concentration from 1700 to 1800 ppm 104 March 26, 1987 Revision to surveillance criteria for steam generator tubes 105 March 26, 1987 Deletion of snubber tables from the Technical Specifications 106 March 26, 1987 Revision of surveillance for the H and 0 m nitoring 2
2 107 March 30, 1987 Delete hydrogen floride detectors 108 April 28, 1987 LCO and surveillance change for steam generator isolation 109 May 4, 1987 Cycle 11 Reload i
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3-Amendment No. Date Description 110 August 31, 1987 Inadequate core cooling instrumentation 111 Septenber 24, 1987 Diesel generator reliability 112 April 19, 1988 One-time extension of surveillance interval for diesel generator no. 2 9.
Orders Issued None
- 10. Multiplant Actions and Generic Safety and Security Issues Having Significant Activity During This Rating Period NRC Performance of Auxiliary Feedwater Reliability Analysis Response to NRC on Safety Parameter Display System and Control Room Design Review
- 11. Plant Specific Issues Having Significant Activity During Rating Period Response on revised thermal sheck analysis for incorporation into the Technical specifications Amendment for extended fuel burnup fo Batches K and L Request for relief on ASME XI inspection requirements on welds in l
the main steam and feedwater systems v
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