ML20199A823

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Forwards Draft NRR SALP Input for Util.Comments Requested by 860613
ML20199A823
Person / Time
Site: Prairie Island  Xcel Energy icon.png
Issue date: 06/10/1986
From: Diianni D
Office of Nuclear Reactor Regulation
To: Bernero R, Miraglia F, Novak T
Office of Nuclear Reactor Regulation
References
NUDOCS 8606160034
Download: ML20199A823 (15)


Text

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JWi 101986 s a Docket Nos. 50-282 ,

and 50-306 MEMORANDUM FOR: Thomas M. Novak, Acting Director Division of PWR Licensing-A Frank J. Miraglia, Director Division of PWR Licensing-B Robert M. Bernero, Director -

Division of BWR Licensing William T. Russell, Director Division of Human Factors Technology Themis P. Speis, Director Division of Safety Review and Cversight THRU: George E. Lear, Director PWR Project Directorate #1 Division of PWR Licensing-A FROM: Dominic C. Dilanni, Project Manager Project Directorate #1 Division of PWR Licensing-A

SUBJECT:

DRAFT NRR INPUT FOR SALP - NORTHERN STATES POWER COMPANY PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNITS NOS. 1 AND 2 Enclosed is a draft of the NRR Input for the SALP for Northern States Power Company. This draft report is based mostly upon the mini-SALP evaluations enclosed with SEs prepared during this SALP period. Please review the draft evaluation and provide any comments you feel appropriate. All xomments received by June 13, 1986 will be considered for incorporation in-the final report.

The assigned SES for this plant is George E. Lear.

/s Dominic . Dilanni, Project Manager kDR DO h0h0h82 G PDR Project Directorate #1 Division of PWR Licensing-A

Enclosure:

Input for SALP Report Office: LA/ PAD #1 PM/ PAD #1 PD/ PAD #1 Surname: PShuttle DDilanni/tg GLear Date: //df/86 0$/3/86 h/[Q/86 b/ffh

[  %, UNITED STATES

[ o NUCLEAR REGULATORY COMMISSION

,.- t , WASHINGTON, D. C. 20555

\*....

Docket Nos. 50-282 and 50-306 ,

FACILITY: Prairie Island Nuclear Generating Plant Unit Nos. I and 2 i LICENSEE: Northern States Power Company (NSP)

EVALUATION PERIOD: December 1, 1984 to May 31, 1986 PROJECT MANAGER: Dom Dilanni I. INTRODUCTION This report contains NRR's input to the SALP review for the Prairie Island Nuclear Generating Plant (PINGP). The assessment of the licensee's perfomance was conducted according to NRR Office Letter No. .

44, "NRR Inputs to SALP Process," dated January 3, 1984. This Office i

! I Letter incorporates NRC Manual Chapter 0516. " Systematic Assessment of

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l Licensee Performance."

II.

SUMMARY

i NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a perfomance category (Category 1, 2 or 3) based on a composite of a number of attributes. The single final rating should be tempered with judgment as to the significance of the individual elements.

Based on this approach, the performance of the Northern States Power Company in the functional area - Licensing Activities - is rated Category 1.

III. CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1. " Evaluation Criteria with Attributes for Assessment of Licensee Performance."

IV. METHODOLOGY This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort on PINGP licensing actions during the assessment period. Using the guidelines of NRC Manual Chapter 0516, the PM and each reviewer

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applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2 or 3,) to each attribute. The reviewers l included this information as part of each Safety Evaluation input I transmitted to the Division of Licensing. The PM, after reviewing the  !

SALP inputs of the technical reviewers, combined this information with '

his own assessment of licensee performance and, using appropriate weighting factors, arrived.at a composite rating for the licensee. i l

This rating also reflected the comments, if any, of the NRR Senior Executives assigned to the PINGP SALP assessment. A written evaluation was then prepared by the PM and circulated to NRR management for coments which, if provided, were incorporated in the final draft.

The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of octivity during the assessment period. There were a total of 25 active actions at the beginning of the assessment period. Twenty-one actions were added for a total of 46 actions by the end of the assessment period. We have closed 33 actions during the assessment

. period and have 13 active actions at the end of this assessment period. .

These actions and a partial list of completions consisting of amendment i 7

,. . requests, exemption requests, responses to generic letters, TMI items, j and licensee initiated actions are:

) 21 Multi-Plant Actions (15 completed). Some of the completed actions in this category are:

Equipment Qualifications of Safety Related Electrical Equipment (MPAB-60)

Control of Heavy Loads Phase II (MPA C-15)

  • Instrumentation to follow the course of an accident Reg Guide 1.97 (MPAA-17)

, Many Salem ATWS items (i.e. Items 4.3,4.2.1,4.2.2,3.2.1,etc.)

  • Diesel Generator Reliability (GL 84-15) (MPA D-19) 14 Plant-Specific Actions (11 completed). Some of the completed actions in this category are:

Reload Safety Evaluation method for Control Rod Drop Analysis Schedular Exemption Request for Requirement of Appendix R of 10 CFR <

50.48c l

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  • ECCS Error and Core Height Fq (Kz curve verification only)
  • Rod Cluster Control Guide Thimble Plug Removal Capsule Surveillance Summary Report Exemption 11 TMI (NUREG-0737) Actions (7 completed). Some of the completed actions in this category are: -

Small break LOCA Analysis item II.K.3.30 Safety parameter Display System Item I.D.2 Compliance with 10 CFR 50.46 Item II.K.3.31 Technical support center Item III.A.1.2 Meteorological Data Upgrade Item II.A.2.2 Emergency Operations Facility Item A.1.2 This appraisal also considers the remaining number of backlog licensing -

issues that are carried over to the next assessment period. The i p

,- remaining backlog reflects all existing issues for which the review effort has not yet been completed by staff and may need additional input i

by licensee in order to achieve a satisfactory resolution. At the end of this assessment period the breakdown of unresolved licensing issues for Prairie Island stands as follows:

. MPA 6 Plant Specific 3

TMI (issues) 4
Total 13 Figure 1 (enclosed) illustrates the percentage reduction in the backlog of licensing issues (52.2%) i;nd compares this value with the achievements of past assessment periods. The 52.2% reduction exceeds by far the performance of all past assessment periods and the 13 remaining issues is the lowest for all licensed operating plants in the country.
The low number of remaining open issues demonstrates the company wide l aggressive participation with the project manager to resolve safety issues.

V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the seven attributes specified in NRC Manual Chapter 0516. These are:

-- Management Involvement and Control in Assuring Quality ,

-- Approach to Resolution of Technical Issues from a Safety Standpoint

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-- Responsiveness to NRC Initiatives

-- Reporting and Analysis of Reportable Events

-- Staffing

-- Training and Qualification Effectiveness .

Enforcement In addition, the licensee was evaluated in the area of " Housekeeping."

i Fortheremainingtwoattributes(enforcementandtrainingandqualification effectiveness), no basis exists for an NRR evaluation for the functional area of Licensing Activities.

A. Management Involvement and Control in Assuring Quality During this assessment period, the licensee's management actively participateo in licensing activities and kept abreast of all current and anticipated licensing actions. Typical areas where management -

p participation was evident occurred in scheduling, planning and I responding to the NRC related to the efforts of Generic Letter 83-28.

In addition, management involvement in licensing activities assured timely response to the Comission's requirements related to TMI NUREG-0737 issues and preparing the new upper plenum ECCS injection model.

The licensee's management has consistently exercised good control over its internal activities and its contractors and has maintained effective comunication with the NRC staff. This was exemplified in the manner in which the verification of the Kz curve was handled. In addition, the i licensee's management actively participated with the Project Manager to l reduce the backlog of licensing actions within NRR. The 33 actions I completed attest to the licensee's management involvement and represent 72

! percent of the total number of licensing actions in force during the period.

The licensee's management maintained effective comunication with the staff.

The licensee has met schedules or informed the Project Manager at an early date of schedular problems.

One area where management attention could be increased is in the timeliness of amendment requests submittals that are tied to plant restart after a refueling cutage. A minimum of five months should be allowed to permit adequate processing through comission when establishing the date for the package submittal.

A rating of 1 is assigned to this attribute.

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B. Approach to Resolution of Technical Issues from a Safety Standpoint The licensee's management and its staff demonstrated sound technical understanding of issues involving licensing actions. The licensee demonstrated extensive technical expertise in technical areas involving the resolution of technical areas associated with l licer. sing actions. Sound technical approaches are taken by the licensee when meeting with the NRC to assure superior technical l discussions in resolving safety issues. These attributes were '

demonstrated in the resolutions of issues related to the ,

authorization of steam generator tube sleeving, the reload safety i evaluation method for control rod drop analysis and the environmental qualification of safety related electrical equipment to name a few of the actions that were resolved during the assessment period. On occasions, when the licensee deviated from the staff guidance as in cases of the implementation of the inadequate core cooling instrumentation'and the review of diesel generator reliability requirement, the licensee consistently provided good technical justification for such deviations. The NRC technical reviewers were able to complete.their Safety Evaluations on the basis of the original submittals with no more than telephone ,

questions for clarification. In the case of the amendment request i f associated with steam generator tube sleeving, the submittal was

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complete requiring only telephonic discussions for clarifying minor staff coments in order to complete the safety evaluation and issue the amendment. The licensee's visit to NRC to discuss forthcoming requests for staff actions prior to formal submittals demonstrates the licensee's desire to minimize potential problem areas that could arise during the NRC staff reviews. This approach has been consistently found to be beneficial to both the staff's and i licensee's efficiency in processing such actions.

Based on the above evaluation, the overall rating of 1 is assigned to this attribute.

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C. Responsiveness to NRC Initiatives The licensee has been consistently responsive to NRC initiatives.

Throughout the rating period, the licensee exhibited a superior effort to meet or exceed established commitments which contributed to the  ;

reduction of open issues (i.e., MPA's, plant specifics, and TMI NUREG-0737 l actions). When the NRC desired clarification or additional infonnation during the review of the licensee's submittals, the responsiveness by the licensee has been judged as excellent. In addition, when clarification or additional information could not adequately be resolved by conference calls and/or correspondence, the licensee has met on short notice with the NRC as soon as they were made aware of our concerns.

Typical examples of such perfonnances occurred when the NRC expressed concern with the preparation of amendment package dealing with upgrading the technical specification and the upoer Plenium Injection Evaluation Model to meet the requirement of 10 CrA 50.46 Appendix X. In these examples, the licensee gave oral presentations that exhibited thoroughne:s and sound technical judgement. The licensee is waiting for NRC to take positions on most submittals related to the remaining open issues at the end of the assessment period, and the licensee committed to reasonable schedules for those open issues where additional infonnation is needed in order to complete the NRC review. ,

t [, Based on the above evaluation, the overall rating of 1 is assigned to this attribute.

D. Enforcement No bases exists for an NRR evaluation of this attribute.

E. Reportable Events Events at PINGP appear to have been reported promptly and accurately.

Enclosure 2 at the end of this report is for consideration in the Region's Operations section of the SALP Report.

A rating of 1 is assigned to this attribute.

l l F. Staffing Thelicenseehasasufficientstafftoprovideadequateamidtimely response to our safety concerns. The staff is knowledgeable of our regulations, and the engineering aspects of the plant which results in a satisfactory resolution of licensing issues. In addition, the licensee's scheduled dates for completion of NRC items which were judged to be reasonable are rarely missed is an indication that adequate staffing exists.

A rating of 1 is assigned to this attribute.

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G. Training and Qualification Effectiveness No basis exists for an NRR evaluation of the attribute.

H. Housekeeping NRR was impressed with the clean, well ordered appearance of the plant simulator, training facilities and the control room during the plant visits. In-plant laboratories, tool rooms and storage areas were clean, bright, and well layed out. The Control Room appeared very well run and well organized in terms of reference materials and drawings.

A rating of 1 is assigned to this attribute.

VI. CONCLUSION An overall performance rating of 1 has been assigned by NRR for the current SALP rating period of December 1, 1984 to May 31, 1986. Except for the timeliness of amendment requests submittals (as noted in A above) there are no other areas for which we would recommend management attention on the part of the licensee. .

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FIGURE N0. 1 PRAIRIE ISLAND NUCLEAR GENERATING PLANT UNIT NOS 1 AND 2

!' LICENSING BACKLOG ISSUES NUMBER OF LICENSING ISSUES THAT NEED RESOLUTION AT THE END OF ASSESSi4ENT PERIOD SALP N0. -

2 3 4 5 6 ASSESSMENT PERIOD JUNE 30, JUNE 30, JUNE 30, .Nov 30, MAY 31, 1981 .L32 1983 1983 1986 MULTIPLANT ACTIONS 30 17 8 10 6 PLANT SPECIFIC 7 5 5 4 3 1 TMI ACTIONS E! 28 2Q 11 1 TOTAL 72 50 33 25 13

% REDUCTION (FROM PREVIOUS YEAR) 30.5 34.0 24.2 52.2

% INCREASE (FROM PREVIOUS YEAR) --- --- --- ---

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ENCLOSURE 1 l l

1. NRR/ Licensee Meetings j Upper Plenum Injection - Evaluation Model January 10, 1985 Reactor Upper Internal (Top Hat Design) June 26, 1985 Upper Plenum Injection Evaluation Model June 28, 1985 Upper Plenum Injection Evaluation Model and Technical Specification Upgrade November 22, 1985
2. NRR Site Visits / Meetings SALP 5 Meeting and Site Visit Feb 25 - Mar 1, 1985 Site Visit / Meeting / Resident Inspector June 19-20, 1985

$ite Visit / Meeting / Resident Inspector Unit 2 Oct7-10,i985

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Refueling Outage Site Visit / Meeting / Resident Inspector Unit 1 Refueling Mar 11-14, 1985 Outage

3. Comission Meeting
None
4. Schedular Extensions Granted Fire Protection Appendix R 10 CFR 50.48c May 7, 1985 Surveillance Capsule Sumary Report Extension Mar 17, 1986 Confirmatory Order Supplement 1 NUREG-0737 Feb 5, 1986

! (June 14, 1984)

5. Relief Granted None i
6. Extensions Granted l None
7. License Amendments

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Amendment No. Title Date Unit 1/ Unit 2 72/65 Operability period Feb 15, 1985 of cooling H2O header 73/66 Thirteen changes to June 25, 1985 technical specification 74/67 Spent Fuel Shipping Cash June 26, 1985 Movement are Spent Fuel Pool No. I 75/68 Shunt trip and Manual June 26, 1985 reactor trip circuitry GL 83-28 Item 4.3 76/69 Steam Generator Tube Oct 11, 1985 Sleeving 77/70 Fuel Reload Technical April 3, 1985 Specification Change

8. Emergency Technical Specification .

,I. None

9. Orders Issued None
10. NRR/ Licensee Management Conference None i

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ENCLOSURE 2 SALP INPUT, PRAIRIE ISLAND 1 & 2 12/1/84 - 5/31/86 The report period for this SALP evaluation extends from December 1,1984 through May 31, 1986.

Everts

! During the report period, 24 non-security occurrences were reported for Prairie Island Unit 1 and 14 non-security occurrences were reported for Prairie Island Unit 2. Because occurrences may have been reported for a variety of reasons, some for multiple reasons and others for information only, the number of occurrences in the discussions below should not be construed to be the arithmetic sum of the various categories included in the set of events for each plant.

1 Of the 24 occurrences for Unit 1, 9 were LERs, 14 were reported under the provisions of 10 CFR 50.72, 4 were scrams, 5 involved ESF actuations, and 8 involved human error (3 operations, 4 test and maintenance, and one

- construction worker); the other occurrences involved various hardware -

component malfunctions. Three events (all involving human error) account i p

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for at least 45 of the 50 hours5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br /> of forced shutdown during the SALP period.

The first of these events (2 occurrence reports) occurred on May 8 and 9, 1985. While Unit I was operating at 100% power, a broken airline to the feedwater control valve caused it to go shut. A reactor trip occurred due to the resulting feed flow / steam flow mismatch concurrent with low level.

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Automatic systems and manual action responded appropriately and the unit was I placed in hot shutdown. The event was reported in 33 minutes. Appropriate repairs were made. On May 9, while returning to power (at 5%), the reactor tripped due to an imbalance between reactor power and feed rate (manual feed). This occurrence was reported in 12 minutes. The above event (2 occurrences) resulted in 25-28 hours of forced shutdown time.

The second event (2 occurrence reports) occurred on September 15, 1985.

- While Unit I was at 100% power, the control room operator attempted to lower generator output using a voltage adjuster. Because of an automatic compensating feature which the operator was not familiar with, the adjuster did not respond. The operator tried to "ccrrect" the situation manually; resulting in a reactor trip. The event wat reported in 19 minutes and imediately investigation of the root cause was begun. During restart, a steam generator isolation valve failed to open due to a component malfunction.

The occurrence was reported in 53 minutes. Appropriate repairs were made.

The above event (2 occurrences) resulted in 14.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of forced shutdown time.

The third event occurred on April 10, 1986 wLen Unit 1 tripped from 15% power due to low low SG level while feeding the SG. The regulator was in manual.

The event was reported in 59 minutes. Intermediate power range setpoints were readjusted and because a pattern of difficulties in controlliiig steam generator level at low power levels was noticed, the licensee purchased

hardware to improve feedwater flow indication at low power. The installation of this hardware is planned for next refueling. This event resulted in 6.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of forced shutdown.

The remainder of the occurrences at Unit I were a collection of rather routine malfunctions which did not result in the loss of operating time or compromise to safety.

Of the 14 occurrences for Unit 2, 4 were LERs, 10 were reported under the provisions of 10 CFR 50.72, 2 were scrams, 2 involved ESF actuations, and 4 involved human error (1 operator, 3 test and maintenance).

Two events cccurring during a 41 hour4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> period on May 19 and 20, 1986 account for all of the forced outage time at Unit 2 during this SALP period. While surveillance was being perfonned on I&C instrumentation, a false low pressurizer pressure signal resulted in a spurious safety injection signal l tripping the reactor from 100% pcwer. Prompt operator attention identified the SI signal to be spurious. The operator blocked the signal prior to safety l injection. The Unit was placed in hot shutdown and the event was reported in 38 minutes. The second event occurred when a steam generator was overfed during manual transfer to main feedwater control. The turbine tripped on high high steam generator level and this caused the reactor to trip. The event was -

reported in 21 minutes. I Other occurrences at Unit 2 were the result of hardware malfunctions or errors in performing two tests and did not result in outage time or compromise to safety.

Neither unit at Prairie Island was the' subject of an operating reactor

. briefing during the SALP period.

In the twenty-seven occurrences that were reviewed, the licensee established a consistent pattern of effective tennination of the event, conservative selection of events to report, prompt and accurate reporting, appropriate investigation into the causes of the event, and appropriate action to avoid recurrence.

' Availability During this SALP period, Unit I reported an overall availability of 82.9% and a capacity factor of approximately 75.5%. For this same period Unit 2 had an availability of 89.4% and a capacity factor of approximately 84.6%. The 2-Unit site capacity factor was approximately 80.1%. This performance is consistent with results reported in Nuclear News (April,1986) for the period 1983 to 1985. Prairie Island Unit I had a capacity factor of 84.1%

(highest in the country) and Prairie Island Unit 2 had a capacity factor of 80.5%(5th). The combined site capacity factor was 82.3% (highest for multi-unit stations).

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s These results for Prairie Island were accomplished in spite of refueling outages that included 10-year in-service inspections for both units (Unit 1, 1/11/85-3/10/85, 59 days; Unit 2, 9/6/85-11/1/85, 57 days). Unit 1 also had a normal refueling outage during the SALP period (3/4/86 - 4/10/86, 38 days).

Refueling and inspection outages represent about 11% of the SALP period for Unit 2 and about 18% for Unit 1. Unscheduled unavailability was less than 1%

i for either plant. A review of the historical performance of the reactors at Prairie Island indicate that the results presented for'this SALP period typify those since their original startups: Unit I lifetime availability -

(thru 4/30/86) 81.1% (73.5% capacity factor); Unit 2 availability (thru -

4/30/66)-85.7%(77.7% capacity factor).

The continuance in this SALP period of what would seem to be a tradition at Prairie Island of high availability, few events, and low operational doses (see below) indicates to us a meticulous surveillance and maintenance program and an orderly and careful operating philosophy.

Dose For the 10 year period 1974 - 1983, the Prairie Island site reflected relatively low dose to personnel ranging in annual doses of 0.1 to 0.6 4

man-rems per W-year as compared to the national average ranging from 0.7 to l f 1.4 man-rems per W -year. During the period 1969-1983, Prairie Island ranked c- second in the country with 0.3 man-rems per W -year, and during the period 1979-1983 Prairie Island did not rank lower than third in any given year. In 1983 a total of 233 man-rems at Prairie Island translated to 0.3 man-rems per W -year.

. Available data show that Prairie' Island had 136 man-rems in 1984 and 392

- man-rems in 1985. The higher doses in 1985 are the result of both units having their 10-year in-service inspections. In any event, exposures at Prairie Island were significantly lower than the national average, and particularly low for plants in its (their) age and size class.

Summary During the SALP period, Prairie Island Units 1 and 2 have had high

_ availability and capacity factors (about 80% versus the national average of ,

about 61%); few trips (Unit 1, 4 trips, 2.6 per year, 0.4/1000 hours; Unit 2, 2 tri s, 0.16/1000 hours; versus a national avera 1.1/1000 hours,; few ESF actuations (Unit 1, 5; Unit 2, 2)ge of 5.9/ year

efficient or operational and hardware response to the few events that did occur; conservative, prompt and thorough reporting of events; low overall operational doses; an evidently strong surveillance and maintenance program; and an orderly and conscientious operating philosophy.

Conclusion In consideration of the above, we recommend a rating of I for this attribute for Prairie Island Units 1 and 2. -

Distribution: .

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NRC PDR-Local PDR

-G. Lear T. Novak- '

D. Dilanni~

P. Shuttleworth D. Eisenhut-C. Rossi PAD #1 r/f. -

PAD #1 s/f-h 4

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