ML20205F733
| ML20205F733 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 08/14/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20205F704 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.2, TASK-2.A.2, TASK-2.K.3.30, TASK-2.K.3.31, TASK-3.A.1.2, TASK-TM 50-282-86-01, 50-282-86-1, 50-306-86-01, 50-306-86-1, GL-83-28, GL-84-15, IEIN-86-003, IEIN-86-3, NUDOCS 8608190314 | |
| Download: ML20205F733 (36) | |
See also: IR 05000282/1986001
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SALP 6
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SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-282/86001; 50-306/86001
Inspection Report No.
Northern States Power Company
Name of Licensee
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Prairie Island Nuclear Generating' Plant
Name of Facility
December 1, 1984 - May 31, 1986
Assessment Period
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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 construction and operation.
An NRC SALP Board, composed of staff members listed below, met on July 23,
1986, to review the collection of performance observations and data to
assess the 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
December 1, 1984 through May 31, 1986.
SALP Board for Prairie Island Nuclear Generating Plant:
C. E. Norelius, Director, Division of Reactor Projects
J. A. Hind, Director, Division of Radiological Safety and Safeguards
C. J. Paperiello, Director, Division of Reactor Safety
D. Dilanni, Licensing Project Manager, NRR
W. D. Shafer, Chief, Emergency Preparedness and Radiological Protection
Branch
G. Lear, Director, PWR Project Directorate No. 1
C. W. Hehl, Chief, Operations Branch, DRS
1. N. Jackiw, Chief, Reactor Projects Section 2
T. M. Burdick, Chief, Operator Licensing Section
J. E. Hard, Senior Resident Inspector
J. R. Creed, Chief, Safeguards Section
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J. A. Bauer, Reactor Engineer, Technical Support Staff
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M. M. Moser, Resident Inspector
M. A. Ring, Chief, Test Programs Section
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II. CRITERIA
The licensee performance is assessed in selected functional areas depending
whether the facility is in a construction, pre-operational or operating
phase. Each functional area normally represents an area significant to
nuclear safety and the environment, and is a normal programmatic area.
Some functional areas may not be assessed because of little or no licensee
activities or lack of meaningful observations.
Special areas may be added
to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area.
A.
Management involvement in assuring quality.
B.
Approach to resolution of technical issues from a safety standpoint.
C.
Responsiveness to NRC initiatives.
D.
Enforcement history.
E.
Reporting and analysis of reportable events.
F.
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 definition of
these performance categories is:
Category 1: Reduced IEC 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 or construction 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 such that satisfactory performance with respect to operational
safety or construction 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
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strained or not effectively used so that minimally satisfactory performance
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with respect to operational safety or construction is being achieved.
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III. SUMMARY OF RESULTS
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The overall regualtory performance of the Prairie Island Plant has
continued at a satisfactory high level during the assessment period.
Rating Last Period
Rating This Period
Functional Area
07/01/83 - 11/30/84
12/01/84 - 05/31/86
A.
Plant Operations
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2
B.
Radiological Controls
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C.
Maintenance
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D.
Surveillance
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2
E.
Fire Protection
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2
F.
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G.
Security
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H.
Outages
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1.
Quality Programs and
Administrative Controls
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Licensing Activities
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K.
Training and Qualification
Effectiveness
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- Not Rated (new functional area for SALP 6)
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IV. PERFORMANCE ANALYSIS
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A.
Plant Operations
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1.
Analysis
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Evaluation of this functional area is based on the results of
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routine inspections conducted by the resident' inspectors. The
inspections included direct observation of activities, review of
logs and records, verification of selected equipment lineup and
operability, followup of significant operating events, and
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verification that facility operations were in conformance with
the Technical Specifications, administrative procedures, and
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commitments. Five violations were identified during the rating
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period as follows:
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Severity Level V - The boric acid storage tank inventory
a.
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fell below the minimum permitted by Technical Specifica-
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tions with a reactor coolant system temperature above
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200*F. This was a minor violation with no safety
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significance.
(Inspection Report No. 50-282/84-18(DRP)).
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b.
Severity Level IV - A diesel-driven cooling water pump
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control switch was inadvertently left in manual for about
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six hours. The error was detected during a control board
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walkdown and was prontly corrected.
(Inspection Report
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No. 50-282/85003(DRP)).
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c.
Severity Level IV - The level in the Unit 2 caustic addition
tank fell below the required level for about one hour. This
was the result of inadvertently leaving an overflow valve
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open.
(Inspection Report No. 50-306/85003(DRP)).
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d.
Severity Level V - An up-to-date alarm response procedure
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was not available in the control room. This is a relatively
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minor matter which was promptly corrected when pointed out
by the inspector.
(Inspection Report No. 50-282/85014(DRP);
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50-306/85011(DRP)).
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e.
Severity Level IV - This violation is for failure to
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promptly log the discovery of a potentially inoperable
limitorque valve and the correction of the potential
problem.
(Inspection Report No. 50-282/86007(DRP)).
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See also Section I, Quality Programs and Administrative
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Controls, for discussion of an additional violation
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related to this limitorque valve.
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Violations
a.,
b., and c. were the result of errors in
judgement by the operating staff. Violation d. was the result
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of an administrative oversight.' Violation e. seems to have
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been caused by a misunderstanding of what needs to be, recorded
in the permanent plant logs. Appropriate corrective action has
been or is being taken by the licensee.
During the assessment period,.the licensee took corrective
actions tc reduce the number and severity of violations noted
in the last SALP report. The status of these corrective
actions and additional measures being taken to improve plant
operation is reviewed below:
1.
Positive Discipline _ Program - The disciplinary
aspects of this program are being used for hunun
errors involving gross negligence or deliberate
actions. The positive aspects of the program, such
as the Employee-of-the-Quarter awards, are being
used for high level performance.
2.
Study of personnel / procedural errors - An Error
Reduction Program has been instituted which relates
to many different aspects of plant operation. No
significant reduction in violations is yet noted.
3.
Outside management audit by Delian Corp. - Delian
reported their findings to the licensee in April
1985. The findings focus principally'on areas where
management, both in plant _and corporate, can signifi-
cantly improve their roles. Action is being taken by
NSP in the identified areas.
There were six reactor trips during the assessment period:
two
were < 15% power; four were > 15% power. The first four trips
were on Unit I and the last two on Unit 2.
The first trip was
the result of a broken instrument air line which occurred
during Appendix R work. This caused a main feedwater valve to
close, resulting in a low steam generator level trip. During
recovery from that trip, a second trip resulted when a feedwater
valve malfunctioned. This time, a feedwater pump motor-operated
discharge valve tripped off while being opened. The third
reactor trip occurred while troubleshooting instabilities in the
main generator regulator. A generator lockout during trouble-
shooting caused the generator trip-reactor t' rip. The fourth trip
on Unit 1 occurred from low power as a result of mismatch of
feedwater flow and steam flow while in manual operation.
The Unit 2 trips occurred late in the assessment period. The
first of these was the result of a technician error during
surveillance testing and was the first trip on Unit 2 in nearly
three years.
(Also discussed in Section D. Surveillance). The
second trip resulted from steam generator level control problems
during the subsequent startup.
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There were six LERs involving personnel errors by operations
personnel during the assessment period; four of these errors
were made by licensed operators.
The six errors included two
valving mistakes, an error in interpreting technical specifica-
tions, two switching mistakes, and a computational error. None
of these had any major safety significance.
In addition to the
LERs, there was one Significant Operating Event (SOE) during
the period which is of particular note because of its poter,tial
safety significance. This SOE was the contamination of crankcase
lube oil in one diesel generator because of improperly marked
oil drums. The contaminated lube oil made a diesel-generator
inoperable. Though the investigation failed to disclose the
specific source of contamination, controls instituted by the
licensee over oil drums should prevent future problems from this
source. Unlicensed operators were involved in this SOE.
Despite the difficulties discussed above, the plant operating
record is outstanding.
Cumulative availabilities were more
than 80% for Unit I and more than 85% for Unit 2.
For the
period 1983-85, the Unit I capacity factor was the best in
the nation at 84.1% and Unit 2 was fifth best at 80.2%.
2.
Conclusion
The licensee continues to be rated Category 2 in this area.
3.
Board Recommendations
The board notes that since the end of the SALP rating period,
NRC has become aware of a matter which should be mentioned.
That matter involves the request for transfer away from Prairie
Island of about two-thirds of the licensed operators on the
operating crews. The immediate plant loss will only involve
three operators since a limited number of other jobs are
available. Management attention is being focussed on the
causes of operator dissatisfaction.
Plans to replace the
personnel being transferred are also being discussed.
B.
Radiological Controls
1.
Analysis
Three inspections were conducted during this assessment period
by region based inspectors. These inspections included
operational and outage radiation protection, radiological
waste management, and transportation activities. The resident
inspectors also reviewed this area during_ routine inspections.
One violation was identified as follows:
Severity Level IV - Failure to follow procedures requiring valve
restoration to normal position following maintenance and
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requiring valve position verification before making a liquid
radwaste release which resulted in an inadvertent release from
a radwaste tank.
(50-282/85019-01;50-306/85018-01)
The licensee was responsive to the violation; corrective actions
were timely and appear to be effective. The violation appears to
be an isolated incident and not indicative of a programmatic
weakness.
Staffing continued to be a licensee strength. The staff is
stable and well organized with no significant turnover other
than career progression.
Management involvement in this functional area is evident. There
is consistent evidence that managers and supervisors are involved
in the day-to-day activities of the plant.
Procedures and
policies are adhered to and records are complete, well maintained,
and available. Corrective actions, when necessary are prompt and
consistently recognize and address concerns. Annual audits of
this functional area are conducted by both onsite and corporate
groups. The audits of radiation protection, chemistry and
transportation activities completed in 1985 were comprehensive,
timely and thorough.
A conservative approach to resolution of radiological control
issues is routinely exhibited. Personal radiation exposures for
this assessment period, which included refueling outages for both
units and a 10 year ISI for Unit I were 136 person-rem in 1984
and 390 person-rem for 1985. This was well below the average of
U.S. pressurized water reactors. An effective ALARA program,
with good management and worker support, contributes to the low
exposures. Several improvements were made during this assessment
period which helped reduce radiation exposures, including
underwater replacement of the antivibration bars (AVB) in the
steam generators which reduced the radiation level to the workers
by a factor of about 15, mockup training for AVB work, and mockup
training for reactor head modifications.
Total liquid and airborne radioactive releases and solid
radioactive waste volume and ' activity remained well below the
average for U.S. pressurized water reactors. No radioactive
material transportation problems were reported. The liquid
radwaste release referenced in the above violation, although
unplanned, was within technical specification radioactivity
limits.
Examination of the Radiological Environmental Monitoring Program
(REMP) was limited'to a review of the licensee's 1984 annual
report. This program continuts to be acceptable with'no signi-
ficant anomalies noted.
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2.
Conclusion
The licensee is. rated Category 1 in this area. Licensee
performance has remained essentially constant over the course
of the SALP assessment period.
3.
Board Recommendations
None.
C.
Maintenance
1.
Analysis
Evaluation in this area is based on routine inspections by the
resident inspectors. Areas examined during these inspections
included: major and minor plant modifications, calibrations,
repairs, equipment overhauls, preventative maintenance, and
maintenance organization and administration. No viola' ions
were identified in this area.
During the assessment period there was one LER attributed to
personnel error. This event involved a reactor trip which
occurred during troubleshooting work being done on the Unit 1
main generator voltage regulator. The error was the pulling
of a regulator card without adequate review of the possible
consequences.
The licensee's preventative maintenance program shows consistent
evidence of prior planning and assignment of priorities; it is
well-defined, controlled, and has explicit procedures for
control of preventative maintenance activities which is
evidenced by the plant's high availability factor. Records of
maintenance activities are well maintained and readily available.
Special maintenance work continues to be performed in a very
impressive manner.
An example of this high level of performance
was the removing and. replacing of the Unit I reactor upper
internals. This job required careful planning and attention to
details because of the size of the internals packages and the
radiation levels associated with the old internals. The job
was performed smoothly and without significant delay even though
this had not been done previously at Prairie Island.
Other significant mainienance efforts during the period included
rebuilding of the safeguards traveling screens, upgrading of the
caustic addition systems, installation of'new level indicators on
boric acid storage tanks, and rebuilding of a heater drain tank
and pump.
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An organizational change made during the period involved the
replacement of the Maintenance Superintendent, who has retired,
with one of the Lead Production Engineers. Since the new
Superintendent is also a long time Prairie Island employee, and
since the maintenance group remains extremely stable with very
little attrition, the experience level continues to be very high.
2.
Conclusion
The licensee continues to be rated Category 1 in this area.
3.
Board Recommendations
None.
D.
Surveillance
1.
Analysis
Evaluation of this functional area is based on routine assessments
by the resident inspector during implementation of the resident
inspection program and four inspections by region based special-
ists. Six violations were identified as follows:
a.
Severity Level IV - Containment Integrated Leak Rate Test
(CILRT) procedures were not a
(Inspection
50-282/85011(DRS))ppropriate.
Report No.
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b.
Severity Level IV - CILRT supplemental verification test
not long enough.
(Inspection Report No. 50-282/85011(DRS)).
c.
Severity Level V - Failure to add pre and post-repair
differential leakage to CILR.
(Inspection Report
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No. 50-282/85011(DRS)).
d.
Severity Level V - Pump not allowed to run five minutes
before taking data. Pump speed not measured.
(Inspection-
Reports No. 50-282/85012(DRS); 50-306/85009(DRS)).
e.
Severity Level V - Failure to use controlled, traceable
instruments for vibration testing.
(Inspection Report
No. 50-282/85012(DRS); 50-306/85009(DRS)).
f.
Severity Level IV - During performance of the surveillance
associated with the Nuclear. Power Range Daily Calibration
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Procedure a calculational error was made; consequently,
the required recalibration of the nuclear power range
instruments was not performed and, as a result, the
licensed power level was exceeded by approximately three
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megawatts thermal (0.16%) based on a calculation of
average power level during an eight-hour shift (Inspection
Report No. 282/85008).
Violations
a.,
b., and c. were the result of a Region III
specialist inspection of data accumulated during the Unit 1
CILRT. While the three violations represent difficulties
with the licensee's performance of the CILRT, the CILRT itself
was, in fact, found to have acceptably low containment leakage.
With regard to Violation c., the inspection noted that the
licensee was unaware of the Type A CILRT as found requirements
and in their response NSP noted that these requirements were
different from what had been NSP's long-standing practice.
NSP has taken corrective actions for all three violations.
Containment Integrated Leak Rate Testing is a unique
specialized area and as such is not necessarily reflective of
the plant's surveillance program as a whole.
Violations d. and e. were also the result of a Region III
specialist inspection. Prompt and appropriate action was taken
by the licensee; in the case of Violation d., corrective action
was taken prior to the exit meeting. Violation f. appeared to
be an isolated occurrence.
The number of violations in this assessment period shows a slight
increase as compared to the previous period. However, severity
levels and safety significance are reduced.
The number of LERs attributed to personnel error has been reduced
from tive in SALP 4 to four in SALP 5 to two in the current
period. The first one involved a surveillance test on the
turbine overspeed system which was performed two days late.
The other event was a Unit 2 reactor trip because of technician
error during surveillance testing.
Approximately 8,000 surveillance. tests are performed annually
at Prairie Island. This extensive program is coordinated by
one of the more experienced Lead Production Engineers in the
Operations Engineering group. A variety of computer generated
lists are distributed to the plant forces responsible for test
. performance. Many different groups are involved in performing
the tests. The test procedures themselves are generally
written by the engineers or others to whom the system being
tested is assigned. Review of test results is performed by
several individuals including the test author. A cover page on
each test identifies the individuals who performed the test and
who reviewed and approved the test results. After the reviews
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are complete, the entire test document is reduced to microfilm
for permanent storage. This system of administering the
surveillance test system works quite well as evidenced by
the extremely low rate of missed or late surveillances.
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During this period the licensee paid considerable attention to
performance in the surveillance area. This is evidenced by the
following activities:
a.
A computer program has been developed for trending leakage
through "Section XI valves." This subject had been
addressed by a Region III inspector.
b.
An independent (out-of pl nt) review was conducted of
selected surveillance procedures examining clarity of
intent, conformance to technical specifications, and
adequacy of communications.
c.
Specific improvements were made in the procedures for
caustic standpipe and component cooling system; areas in
which regulatory difficulties have been experienced in the
past.
d.
The Procedures Committee has been reactivated and currently
is involved in a major ongoing effort aimed at improving
all procedures.
It appears that as a result of the licensee's special efforts
in the Surveillance area, improvements in performance are being
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seen.
2.
Conclusion
The licensee continues to be rated Category 2 in this area.
An improving trend in performance has been noted by NRC.
3.
Board Recommendations
None.
E.
Fire Protection
1.
Analysis
Evaluation of this functional area is based on routine assess-
ments by the resident inspectors. No violations were identified.
Similarly, no LERs were filed in this area.
Work required to be performed per 10 CFR 50, Appendix R, Fire
Protection Program, was completed within the time schedule
approved by NRR. This job was a massive effort requiring careful
' scheduling and the employ of many tradesmen from outside the
plant. At one time during this effort, approximately 70 people
at the plant were working solely to meet the Appendix R
requirements.
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One small fire occurred during the assessment period. This was
caused by a hot electrical connection which ignited a plastic
sheet in contact with it. No significant damage resulted.
All operators and shift supervisors are members of the Fire
Brigade.
In order to maintain an active status in the Brigade,
each member must attend 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of classroom training and
participate in eight hours of hands-on " smokehouse" training
every year. The Brigade members learn to fight all types of
fires which conceivably could occur at the plant. Quarterly
fire drills are performed by each of the six crews. These
drills have demonstrated the ability to mobilize within seconds
and the general preparedness of Brigade members to handle
unannounced emergencies.
In the area of housekeeping, licensee performance is judged to
be about average. Although the licensee has expended considerable
effort in painting, cleaning, and general organization of storage
areas, much more needs to be done, particularly in the auxiliary
building. As noted by the Regional Administrator during his
recent plant tour, the turbine building appears reasonably good
but the auxiliary building is cluttered, has graffiti on the
walls, and needs improvement in the identification of equipment.
Observers from NRR have commented favorably on the clean and
well ordered appearance of the plant simulator, training
facilities and the control room. These same observers also
noted that in-plant laboratories, tool rooms and storage areas
were clean, bright, and well laid out. The Licensee is
continuing his effort to improve housekeeping where further
improvement is necessary.
2.
Conclusion
The licensee is rated Category 2 in this area. This is a
decline from the last assessment period rating of Category 1,
due primarily to housekeeping practices at the plant.
3.
Board Recommendations
None.
F.
1.
Analysis
Two inspections were performed during the assessment period.
One
of these was an evaluation of the annual emergency preparedness
(EP) exercise conducted on May 14, 1985. The other was a routine
inspection, resulting in no violations, that included a review of
training, changes to the program, license audits, maintenance of
emergency preparedness, and activations of the emergency plan.
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No weaknesses were identified during the exercise. The scenario
was somewhat unique in that a simulated radioactive release never
occurred outside the plant and the emergency never exceeded the
Alert level throughout the exercise. The quality of scenario
data was much improved over the 1984 scenario. All nine objec-
tives of the exercise were met by the licensee. While it was a
good exercise and well performed, it was not a very challenging
scenario.
It was recommended that the licensee use more alter-
nates in filling key emergency positions in the Technical Support
Center (TSC) and the Emergency Operations Facility (EOF) to
expand the emergency experience level of the staff and provide
a broader base of qualified emergency response personnel.
The routine inspection involved a finding relating to the lack
of required training for four individuals with emergency response
positions. The licensee identified this omission and took
appropriate corrective action to prevent a violation from being
issued. Licensee management was advised to periodically review
the number of individuals assigned emergency functions, particu-
larly for lower echelon support positions, to ensure that all
will be trained annually as required.
A computerized list of emergency preparedness issues has been
incorporated into the training lesson plans. This list includes
items from NRC inspection reports, audit findings, and drill and
exercise critiques. Documentation for individual participation '
in drills, exercises and table-top discussions has been improved
and is included as part of the training records. This had been
identified as a weak area in the previous SALP report. Overall,
training related items have improved during this SALP period.
Shift augmentation drill records were reviewed and found to be
satisfactory. The tone alert radio system used to notify
off-duty emergency response personnel, has had some operating
problems, and was being replaced by the Automatic Dialing Alert
System (ADAS). The ADAS should be in operation by the Fall of
1986; and it is expected to be a more effective communications
system than the present one.
Management involvement in decision making has been consistently
at a level which ensures adequate management review.
Responsiveness to NRC initiatives has been technically sound,
and where noted, acceptable resolutions have been provided in a
professional and timely manner. Events that have resulted in
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the activation of the emergency plan have been properly identi-
fied, classified, and resulting notifications made within the
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required times. Staffing of key emergency personnel is well
identified and described adequately in both corporate and plant
implementing procedures.
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In summary, the licensee is continuing its effort to improve the
emergency preparedness program. Corporate and plant management
are continuing to demonstrate their concern by being involved in
emergency preparedness policy making and making improvements in
the program, whether suggested by the Region III inspection teams
or by their own initiatives.
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2.
Conclusion
The licensee continues to be rated Category 1 in this area.
3.
Board Recommendations
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None.
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G.
Security
1.
Analysis
During the assessment period, one routine inspection was
performed by region-based inspectors in the early part of the
assessment period. The resident inspectors made periodic
observations of security activities. Three violations were
identified.
Severity Level IV - The licensee failed to adequately
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implement' compensatory measures for a failed security
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system.
(Inspection Reports No. 50-282/85009;
50-306/85007.)
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b.
Severity Level IV - The licensee's assessment aids were not
adequate in providing surveillance of the protected area
perimeter barrier.
(Inspection Reports No. 50-282/85009;
50-306/85007.)
c.
Severity Level IV - The protected area intrusion detection
system failed to detect attempted penetrations in one zone.
(Inspection Reports No. 50-282/85009; 50-306/85007.)
The number and severity level of the violations remain
essentially unchanged from the previous SALP assessment period.
Although the violation noted in Item a. was the only specific
instance observed of the licensee's failure to meet minimum
requirements for compensatory measures, the quality of
implemented compensatory measures, in general, was not
representative of above average performance.
Item b. was
indicative of a deteriorating security system that had not
been adequately maintained.
Item c. represented a design
deficiency in the protected area intrusion alarm system which
.
had existed since the inception of the program. During the one
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inspection conducted by region based inspectors, weaknesses or
concerns were noted in several areas including managment's
role in assuring quality (lack of an in-depth audit program),
Access Control - Packages (marginally acceptable equipment);
and Safeguards Contingency Plan Implementation Review (limited
security drill program). Based on the violations and the
observed weaknesses during that specific inspection, the
licensee's representatives were informed that their performance
,
had declined.
'
In response to the referenced inspection findings, corporate
security conducted a comprehensive team audit of the security
program. Additionally, the licensee contracted with another
experienced nuclear utility's security organization to conduct
an independent in-depth audit of the design and implementation
of all aspects of their security program. Site security manage-
ment enhanced the Quality Assurance (QA) audit program by
developing and implementing a program of security officers
performing specific and periodic internal audits on a continuing
basis. The above noted reviews were thorough and technically
sound, and were indicative of increased attention by management
in assuring quality in the security program. Management's
support for the security program was evidenced by the procurement
and installation of state-of-the-art search equipment; improve-
ments in the Protected Area intrusion detection system; the
employment of both a full and part-time engineer to work on
security modifications; the employment of a full time security
specialist to administrative 1y assist the Supervisor of Security
in order that he will be more able to provide more direct manage-
ment of tha program; and the installatien of new state-of-the-art
assessment aids and the replacement of other deteriorating
equipment. These measures have clearly demonstrated a more
effective role of managers in~ assuring quality.
The licensee took prompt action in resolving the issues which
were noted during the region-based security inspection. The
licensee has been cooperative in providing the resi<'
.t inspector
with periodic updates concerning the progress in rewiving NRC
initiated issues; however, the licensee should also communicate
more frequently with the region based safeguards staff. The
licensee's approach to resolving identified weaknesses / concerns
has been comprehensive.
Solutions to technical safeguards problems were sound, timely and
conservative, indicating a clear understanding of the issues, as
demonstrated by the high quality and scope of specific equipment
replacement.
The multiple minor violations and security concerns / weakness
identified in the early security inspection were indicative of
a program that had regressed from the previous SALP evaluation.
Since the identification of these issues by the NRC, they have
16
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been resolved in a timely and extremely extensive manner during
the remainder of the assessment period.
The licensee's perfor-
mance significantly improved during the second half of the
assessment period.
During this period, there were nine safeguards events that were
reported as required. Most of the reportable events were
attributable to causes not under the licensee's control such as
equipment failures during the early part of the SALP period.
Only one reported event was under the licensee's control and
involved a plant staff member badged without a formal background
check. The event was promptly and completely reported.
Security organization positions and responsibilities are well
defined. The size of the security staff and the contract
security force was increased during the assessment period to
provide improved efficiency. The security force is considered
to be ample to implement the facility's physical protection
program.
The occurrence of only a few personnel errors shows that security
training and qualification program has made a positive contribu-
tion to the security organization's understanding of their duties
and responsibilities. The training program is well defined and
administered by a dedicated and resourceful staff.
2.
Conclusion
The licensee's performance is considered to be Category 1 in this
area. Although performance declined during the first quarter
of the evaluation period, the licensee's corporate and site
security management team significantly improved their system
and performance. The current trend of performance is improving.
3.
Board Recommendations
None.
H.
Outages
1.
. Analysis
Inspections of outage activities were conducted by the resident
inspectors during the following refueling outages:
Unit 1
January 11 - March 10, 1985
March 4 - April 10, 1986
Unit 2
September 6 - November 1, 1985
During the assessment period, there were also six inspections
of outage activities conducted by region based inspectors.
Inspection activities during the period included:
review of
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procedures, tests, and surveillances involving refueling tools
and equipment; witnessing core unloading and loading operations,
review of cutage inservice inspection results and modification
QA, review of reload safety evaluations, and witnessing of many
other outage activities. A few of the major activities witnessed
were:
a.
Replacement of Unit I upper internals
b.
Replacement of boric acid lines
c.
Control board modifications
d.
Installation of Reactor Vessel Level Indication
System (RVLIS)
e.
Steam generator snubber testing and rebuilding
f.
Limitorque EQ inspections and modifications
Two violations were noted during these inspections:
a.
Severity Level IV - Failure to investigate snubber seal
deterioration and possible fluid contamination.
(Inspection
Reports No. 50-282/85015(DRS); 50-306/85012(DRS)).
b.
Severity Level IV - Failure to. submit LER on snubber
performance.
(Inspection Reports No. 50-282/85015(DRS);
50-306/85012(DRS)).
These two violations related to performance of the large-bore
steam generator snubbers. The licensee has committed to and
initiated corrective action on these items. These violations
are not repetitive of violations identified during the previous
assessment period and they do not appear to have generic or
programmatic implications.
One LER is assigned to the Outage category. This event was the
accidental actuation of one train of safety injection during
simultaneous electrical and instrument maintenance. Thaugh this
potential problem had been recognized in the planning phase,
administrative controls over the work were not adequate.
Refueling activities generally are conducted in a well-organized
and efficient manner, however, some problems have been
experienced. A delay of several days during the Fall 1985
refueling outage was the result of mispositioning 11 fuel
assemblies on the grid plate during core reloading. These
assemblies had been positioned such that they straddled the
grid plate alignment pins.rather than being positioned on the
,
pins. As a result of the mispositioning, an assembly being
reloaded later became stuck and was damaged while being
extracted. Two other assemblies were also damaged during the
removal effort. These damaged assemblies were replaced. The
root cause of this problem was inadequate lighting in the
,
reactor vessel because of burned-out underwater lights.
Appropriate corrective action has been taken.
18
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At the end of each outage comprehensive testing is performed
to assure that the unit has been returned to a satisfactory
operating condition. Adequate time is scheduled to permit
this testing. This testing is generally detailed in the work
requests and also is followed personally by the individual
who requested the outage work. This personal attention by the
plant technical support staff assures project continuity from
design to testing and represents a strength in-the management
of the plant.
Scheduling of outage activities receives high priority at Prairie
Island. These planning efforts make possible_the performance of
outage tasks on a very compressed schedule.
For example, the
Unit I refueling outage in 1986, which-included replacement of
reactor upper internals, 100% eddy-current inspection of steam
generator tubes, antivibration bar replacement in both steam
generators, and major overhaul of the turbine-generator, in
addition to removal and reinstallation of all feel assemblier,
was completed in only 36 days.
Detailed planning is accomplished by a three person full-time
scheduling group. This group spends manths working on detailed
agenda to assure that critical paths are properly identified
and that other work can be accomplished althin the confines
1
which exist in time and space. During the actual performance
of outage work, this scheduling group supervises the outage,
conducts daily status and work planning seetings, and adjusts
the scheduled work as necessary to assure that the outage does
not become bogged down in any way. Meinbers of the planning
group have been selected for their ccmprehensive knowledge of
the facility and their extensive experience at Prairie Island.
2.
Conclusion
The licensee continues to be rated Category 1 in this area.
3.
Board Recommendations
None.
I.
Quality Programs and Administrative Controls
1.
Analysis
Quality programs (QA and QC) and administrative controls were
routinely assessed by the resident inspectors. 'In addition, one
routine and three special inspections were conducted durirg the
period by region-based inspectors.
i
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Three violations were noted during these inspections:
a.
Severity Level IV - Violation of 10 CFR 50.59 as a
result of inverter upgrading.
(Inspection Reports
No. 50-282/85024(DRP); 50-306/85022(DRP)).
b.
Severity level IV - Unplanned start of a diesel generator
because of failure to follow relay testing procedures.
(Inspection Reports No. 50-282/86007(DRP);
50-306/86007(DRP)).
i
c.
Severity Level IV - Electrical cover left off motor-operated
containment isolation valve and failure to adequately
control modification work in the control room.
(Inspection
Report No. 50-282/86007(DRP)).
All of these violations are indicative of weaknesses in plant
'
administrative controls. The number of violations has increased
to three from the two noted in the last SALP report.
'
One LER submitted during the report period is assigned to this
area. This LER discussed the diesel generator start reviewed
in Violation b. above.
An area of safety concern, related to Violations c. and d., was
identified by the resident inspectors during the assessment
period. This concern addressed the control of facility
modifications.
(Inspection Reports No. 50-282/85014(DRP);
50-306/85011(DRP)). Plant events which occurred and which
illustrate the concern are as follows:
a.
During Appendix R work in May 1985, an instrument air line
solder joint failed because of the line being moved. This
instrument air failure caused a reactor trip.
b.
In July 1985 a temporary cable splice failed thus disabling
many diesel generator auxiliaries. The splice may have been
stepped on during modification work.
c.
In August 1985 breaker 228, which provides safety-related
loads, was tripped accidentally by construction forces
working in the area.
d.
In October 1985 breaker 12 M, which supplies a large number
of safety-related motor control centers, was accidentally
tripped by personnel working on a plant modification.
e.
In May 1986 an electrical cover was left off a
motor-operated containment isolation valve.
(See
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Violation c. above). The conditions which resulted in
-
this error currently are being investigated and are
probably related to modifications made to the valve.
f.
Also in May 1986, during electrical work in the control
room, damage was done to the Unit I contrql rod step
'
counter wiring.
(See Violation d. above). This matter
.
was being investigated at the end of the assessment period.
A special inspection in the modification process area was
requested by the resident inspectors and was conducted by
,
region based specialists in October and November 1985. Their
inspection report (50-282/85021(DRS); 50-306/85019(DRS))
contained six specific recommendations for the licensee.
Although the licensee has devoted much management attention,
including corporate attention, to the reconnendations, final
resolution had not been achieved at the end of the report period.
t.
The NRC considers this subject to be a matter of continuing
high priority, and notes that management of modifications has
- '
also been highlighted by licensee's consultant, Delian Corp.,
as an area needing some improve. ment.
l-
As a result of questions raised at the Kewaunee Plant regarding
environmental qualification of Limitorque valve wiring, the
resident inspectors notified the licensee in a meeting on
December 13, 1985 of the concerns which had been raised. The
i
licensee promptly made plans for visual inspection of all valve
operators during upcoming outages.
(Licensee considered and
q
rejected the approach of taking safety-related valves out of
service for inspections during plant operation.) As of the end
'
of the appraisal period, all Unit I valves had been inspected
and wiring of questionable qualification had been replaced.
Unit 2 inspections are scheduled to be performed during the
next outage. Region based inspectors reviewed the status
of this subject during a special inspection on February 6 and 7,
1986.
Potential enforcement action remains under NRC review.
,
During this assessment period the licensee instituted a program
to help shift supervisors obtain their college degrees. As of
the end of the period, two supervisors had been degreed and three
1
others were well along in their studies. When adequate numbers
have been so trained, the licensee plans to assign Shift Managers
to each shift. These Managers would supervise the operating
crews and by virtue of their technical degrees, would simultan-
eously satisfy the Shift Technical Advisor requirements. These
changes should significantly strengthen the Operations staff.
Two other areas in which licensee has taken special efforts to
improve plant safety are:
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a.
Review of Davis-Besse event - NSP formed a special task
force to study the event and to develop lessons-learned for
application to NSP plants. This is a continuing effort.
b.
Reliability Study of Auxiliary Feedwater System - In
cooperation with a number of consultants, licensee used
Probabilistic Risk Assessment (PRA) methods to evaluate the
reliability of the Prairie Island AFW system. The report of
this study was provided to for NRR review in April 1986.
General conclusions from the report are favorable.
2.
Conclusion
The liceasee continues to be rated Category 2 in this area.
3.
Board Recommendations
None.
J.
Licensing Activities
1.
Analysis
This evaluation represents the integrated inputs of the Project
Manager (PM) and those technical reviewers who expended signifi-
cant amounts of effort on PINGP licensing actions during the
assessment period.
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 activity 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 requests,
exemption requests, responses to generic letters, TMI items, 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 (MPA B-60)
'
Control of Heavy Loads Phase II (MPA C-15)
<
Instrumentation to follow the course of an accident
i
Reg Guide 1.97 (MPA A-17)
Many Salem ATWS items (i.e., Items 4.3, 4.2.1, 4.2.2, 3.2.1,
etc.)
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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
ECCS Error and Core Height Fq (Kz curve verification only)
Rod Cluster Control Guide Thimble Plug Removal
Capsule Surveillance Summary Report Exemption
11 TMI (KUREG-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.I.2
This appraisal also considers the remaining number of backlog
licensing issues that are carried over to the next assessment
period. The remaining backlog reflects all existing issues for
which the review effort has not yet been completed by the staff
and may need additional input by the 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:
6
Plant Specific
3
TMI (issues)
4
Total
13
There has been a 52.2% reduction in the backlog of licensing
issues during this assessment period. 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
'
.
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operating plants in the country. The low number of remaining
open issues demonstrates the company wide aggressive
participation with the NRC Project Manager to resolve safety
issues.
a.
Management Involvement and Control in Assuring Quality
During this assessment period, the licensee's management
actively participated in licensing activities and kept
abreast of all current and anticipated licensing actions.
Management participation was evident in the response to
our Generic Letter 83-28 and the scheduling and planning
of the plant modifications associated with this issue.
In
addition, management involvement in licensing activities
assured timely response to the Commission'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 contractors and has maintained
effective communication with the NRC staff. This was
exemplified in the manner in which the verification of
the K(Z) curve was handled.
In addition, the licensee's
management actively participated with the NRC Project
Manager to reduce the backlog of licensing actions within
NRR. The 33 actions completed attest to the licensee's
management. involvement and represent 72% of the total
number of PINGP licensing actions in force during the
period. The licensee's management maintained effective
communication 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 submittals for amendment requests
that are tied to plant restart after a refueling outage.
The amendment request dated January 13, 1986 which was
tied to the Unit No. 1 startup scheduled for the first
week in April 1986 is the case in point; two months were
available for the staff and licensee to review, interact,
notice and prepare documentation. A minimum lead time of
five months should be allowed to permit adequate processing.
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 licensing actions. Sound
technical approaches are taken by the licensee when
meeting with the NRC. These attributes were demonstrated
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in the resolutions of issues related to the authorization
of steam generator tube sleeving, the safety evaluation of
the reload analysis method for control rod drop and the
environmental qualification of safety-related electrical
equipment.
When the licensee deviated from the staff guidance as in
the implementation of the inadequate core cooling instru-
mentation and the review of the 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 associated with steam
generator tube sleeving, the submittal was complete and
required only telephonic discussions for clarifying minor
staff comments 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 licensee's efficiency in processing
such actions.
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
actions). When the NRC desired clarification or additional
information 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 performances occurred
when the NRC expressed concern with the preparation of
amendment package dealing with upgrading the technical
specification and the upper Plenium Injection Evaluation
Model to meet the requirement of 10 CFR 50.46 Appendix K.
In these examples, the licensee gave oral presentations
that exhibited thoroughocss and sound technical judgement.
25
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The licensee is waiting for NRC to take positions on most
j
submittals related to the remaining open issues at the end
of the assessment period. The licensee committed to
reasonable schedules for those open issues where additional
information is needed in order to complete the NRC review.
d.
Staffing
The licensee has a sufficient staff to provide adequate and
timely 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 are rarely
missed. This is an indication that adequate staffing
exists.
2.
Conclusion
The licensee continues to be rated Category 1 in this area.
3.
Board Recommendations
None.
K.
Training and Qualification Effectiveness
1.
Analysis
During the assessment period, examinations were administered to
six Reactor Operator and six Senior Reactor Operator candidates.
Five Reactor Operators and three Senior Reactor Operators passed
the examinations. This passing rate is below the national
passing average. Also, in March 1985, a requalification exami-
nation was conducted by Region III at Prairie Island. Five of
the ten Senior Reactor Operators and two of the three Reactor
Operators examined failed the written requalification examination.
As a result of these failures, Region III issued a Confirmatory-
Action Letter dated April 26, 1985, to Northern States Power
Company stating that the individuals who failed the requalifica-
tion examination would be prohibited from independently performing
licensed duties until they have satisfactorily completed an
accelerated requalification program and passed a written
, examination approved by the Nuclear Regulatory Commission.
)
At a June 12, 1985, meeting, NSP personnel presented the results
of their review of the retraining program and the measures they
-
planned to take to improve it.
26
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.
.
In September 1985, Region III Operator Licensing Section staff
reviewed the final results of the accelerated requalification
efforts for those who failed the Region III examination in
March 1985 and found that effort to be acceptable.
In the previous assessment period, 23 Senior Reactor Operators
and 11 Reactor Operators were examined. Of these, 15 Senior
Reactor Operators and 6 Reactor Operators passed. The current
trend in this area is unchanged.
Based on this history of examination results, the operator
licensing training and retraining program at Prairie Island
would be considered marginal. However, since the events of 1985,
the licensee has instituted a set of actions intended to address
the NRC concerns. These actions include:
a.
Requiring all licensed personnel to attend eight to 12
requalification lectures per year.
b.
Requiring quizzes each training cycle (every six weeks) and
providing feedback to all trainees regarding their quiz
results.
c.
Tailoring the annual requalification exams in a format
similar to the NRC requalification exam format.
d.
Updating the reference systems descriptions (B Sections),
e.
Improving the effectiveness of feedback from the plant
forces to the training forces.
f.
Updating the simulator to reflect plant changes.
g.
Improving training methods and instructor qualifications.
Progress has been made in these areas to improve the
effectiveness of training efforts.
In addition, NSP has been participating in the INP0 accreditation
process for their training program. At the end of the assessment
period, INP0 had accredited the Prairie Island Maintenance and
Operations training programs.
A good measure of training effectiveness and the qualification
.
of the operating crew is the superb operating record at Prairie
Island. As noted in Section A above, Unit I was the best in
the nation in capacity factor for the period 1983-85 and Unit 2
was fifth best for the same period. The operating crews
represented by the shift supervisors, lead operators, other
licensed operators, and unlicensed outplant operators, plus the
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support groups have demonstrated their ability to get the job
done and to handle all problems, both routine and unexpected,
in exemplary fashion. This ability is a reflection of both
pride of work and qualification to do the job.
2.
Conclusion
The licensee is rated Category 2 in this functional area. The
trend during the assessment period clearly has been toward
improvement.
3.
Board Recommendations
None.
,
.
4
28
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V.
SUPPORTING DATA AND SUMMARIES
,
A.
Licensee Activities
1.
On January 12, 1985, Unit I was shut down for the ten year
in-service inspection and refueling outage. Major activities
performed during the outage included:
reactor vessel weld
inspection, steam generator tube eddy current inspection,
refueling, reactor vessel level indicating system (RVLIS)
installation, and control room panel modifications. Unit I
was restarted on March 10, 1985.
2.
On May 8, 1985, with Unit I at 100% power, an instrument air
line joint separated and the resulting loss of air caused a steam
generator feedwater regulating valve to close. This resulted in
a reactor trip. The unit was off-line for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
3.
On May 9, 1985, with Unit I restarting after tripping on May 8,
Unit I again experienced a reactor trip. This second trip was
caused by low steam generator level plus feedwater flow / steam
flow mismatch. Return to the power grid was delayed an
additional four hours.
4.
Extensive 10 CFR 50 Appendix R work was completed during this
SALP period. This work involved wrapping cable trays and
conduits in certain fire areas with an approved one-hour fire
barrier. This work was completed on June 14, 1985.
5.
On September 6, 1985, Unit 2 was shut down for the ten year
in-service inspection and refueling outage. Major activities
performed during the outage included:
reactor vessel weld
inspection, steam generator antivibration bar (AVB) installation,
steam generator snubber removal testing and reinstallation,
reactor vessel level indication system (RVLIS) installation,
boric acid line replacement, and control room panel modifications.
Unit 2 was restarted on November 1, 1985.
6.
On September 15, 1985, with Unit 1 at 100% power, troubleshooting
activities in the main generator voltage regulator produced a
voltage transient which resulted in a reactor trip. Cause of the
trip was incorrect troubleshooting techniques. The unit was
off-line for approximately 14 hours1.62037e-4 days <br />0.00389 hours <br />2.314815e-5 weeks <br />5.327e-6 months <br />.
7.
On March 4, 1986, Unit I was shut down for a routine refueling
outage. Major activities performed during the outage included:
steam generator tube eddy current inspection; refueling; replace-
ment of upper internals; steam generator snubber removal, testing,
and reinstallation; and steam generator antivibration bar
installation. Unit I was restarted on April 10, 1986.
29
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8.
On April 10, 1986, during a restart of Unit 1 after refueling,
a reactor trip occurred at low power level caused by low steam
generator level plus feedwater flow / steam flow mismatch. The
reactor was restarted and the generator was placed on line
approximately six hours later.
9.
Improvements made to facilities and plant systems during this
assessment period included:
Phase 2 expansion of spent fuel
storage capacity; reactor vessel level indicating system (RVLIS)
installation; relocated steam inlet valves for 11 and 22
auxiliary feedwater pumps; modernization of main steam reheaters;
turbine generator emergency and auto stop trip DC power separa-
tion; and upgrading of plant protected area security equipment
including main vehicle gate, personnel screening, and
surveillance cameras.
.
B.
Inspection Activities
1.
During the period of August 19 through August 23, 1985, a special
security regulatory effectiveness review (RER) was conducted to
evaluate and analyze the effectiveness of the licensee's safe-
guards program.
2.
A special safety inspection was conducted during the period of
October 28 to November 15, 1985 by region based specialists.
This inspection was an in-depth assessment of the licensee's
modification program and related activities and was prompted
when modification activities began impacting plant operating
equipment.
3.
A special reactive inspection was conducted on February 6 and 7,
1986 by region-based specialists to investigate the use of
non qualified wires in 10 CFR 50.49 designated environmentally
qualified (EQ) limitorque valve operators identified in IE
)
1
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30
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s>
~
INSPECTION ACTIVITY AND ENFORCEMENT
PRAIRIE ISLAND NUCLEAR GENERATING PLANT DOCKET NOS. 50-282 AND 50-306
Inspection Reports
Unit 1 - 84013, 84016-18, OL-85001-02, 85001-05, 85007-24, 86002-05,
86007
Unit 2 - 84015, 84017-19, 85001, 85003-22, 86002-05, 86007
FUNCTIONAL
NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA
I
II
III
IV
V
DEV.
.
Plant Operations
3
2
Radiological Controls
1
Maintenance
'
Surveillance
3
3
Fire Protection
Security
3
Outages
2
Quality Programs and
Administrative Controls
3
Licensing Activities
Training and Qualification
Effectiveness
'
Totals
0
0
0
15
5
0
1
1
4
+
b
31
_ _ _ _ _ - . _
_
. - _ _ . _ .
'.
C.
Investigations and Allegation Review
An allegation was made in an anonymous call to the Region III office
on April 23, 1986. A letter has been sent requesting the licensee
to review this matter.
,
D.
Escalated Enforcement Actions
-
1.
Civil Penalties
No civil penalties were issued during this assessment period.
2.
Orders
A confirmatory Action Letter (CAL) was issued by the NRC on
April 26, 1985 after the poor performance on the NRC administered
operator annual requalification examination. The licensee
removed the affected operators from performing licensed duties
and placed them on an accelerated training program. The NRC
reviewed and approved the June 14 and July 1 re-examinations
prior to administration by the licensee. A review of the
examination grading resulted in passing grades for all the
individuals and the CAL is considered closed.
E.
Licensee Conferences Held During Appraisal Period
1.
On February 25, 1985, a management conference was held at
Region III to present the licensee with the findings
of the SALP 5 report.
2.
On June 12, 1985, a management meeting was held at Region III
to discuss the poor performance exhibited during the annual
licensed operator requalification examination and the measures
the licensee planned to take to ensure improved performance in
this area.
3.
On April 18, 1986, the NRC Region III Regional Administrator,
the NRC Director of BWR Licensing, and the NRC Region III
Director of Division of Reactor Projects met with plant and
corporate officials at Corporate Headquarters to discuss the
modified inspection program.
Prairie Island was one of three
plants selected in Region III by virtue of exceptional past
performance and SALP ratings for this program.
32
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_ -.
_ _ _ _ _
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F.
Review of Licensee Event Reports and 10 CFR 21 Reports
1.
Licensee Event Reports (LERs)
New LER reporting requirements have been implemented since the
previous SALP period which incorporated changes in the proximate
cause codes and definitions of the proximate causes. Therefore,
be aware that a comparison of the number and proximate cause
codes of LERs submitted during this assessment period with the
submittals during previous periods would not provide meaningful
comparative information.
a.
The LERs for this evaluation period include 1-85-01 through
1-86-05 for Unit 1 and 2-85-01 through 2-86-02 for Unit 2.
PROXIMATE CAUSE*
SALP 6
Personnel Error
12 (0.67)**
Design, Manufacturing,
Construction / Installation
7 (0.39)
External
0
Defective Procedure
1 (0.06)
Management / Quality
Assurance Deficiency
3 (0.17)
Other
3 (0.17)
TOTAL
26 (1.44)
- Proximate Cause is the cause assigned in accordance with
NUREG-1022, " Licensee Event Report System."
- Numbers in parenthesis are the average number of events
per month,
b.
Evaluation
The monthly rate of LERs is slightly reduced from 1.88 in
the previous SALP rating period to 1.44 in the current
period.
In addition, those events attributed to personnel
error have been reduced in rate from 0.82 to 0.67.
These
improvements are due in part to licensee efforts at error
reduction during the rating period. We encourage the
licensee to continue efforts to reduce the number of LERs
'
especially those related to personnel errors.
.
4
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33
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.
Review of the LERs indicated that the information given,
particularly later in the assessment period, generally
provided a clear and adequate description of,each event;
the entries reviewed were correct and the codes agreed
with the information in the narrative. The. licensee
voluntarily submitted three reports (LERs 1-85-03, 1-85-16,
1-86-2) that were not required by reporting requirements
of 10 CFR 50.73 but which are included in the table above.
The NRC Office for Analysis and Evaluation of Operational
Data (AE0D), reviewed several LERs early in the SALP
period and noted a number of deficiencies. The principle
identified weaknesses' involve lack of adequate discussion
of root cause, lack of adequate safety assessment,
inadequate discussion of corrective actions and personnel
errors, and failure to reference previous similar events.
Discussions have been held with the licensee on this
,
matter and improvements in LERs have already been seen.
2.
10 CFR 21 Reports
a.
In an April 15, 1985 letter to the licensee, Chicago Tube
and Iron (CT&I) transmitted Part 21 notifications that CT&I
had received from their suppliers Hub, Inc. and Phoenix
Steel Corporation. The problem related to the identification
of a small length (21'7") of 8" Schedule 120 pipe as being
1
Schedule 160. Reanalysis of the support constructed of this
pipe was done by Teledyne Engineering Services who concluded
that Schedule 120 pipe was adequate for the service.
b.
In a letter dated November 26, 1985, Region III informed the
licensee of the results of an inspection of the implementa-
tion of Exo-Sensors, Inc., Quality Assurance program that
was conducted by the Vendor Program Branch. This inspection
was initiated as a result of allegations that Exo-Sensors,
Inc., had failed to report a deficiency under 10 CFR Part 21
and that serious deficiencies existed with their Quality
Assurance program. The licensee responded in a letter dated
December 10, 1985 indicating that hydrogen analyzers had
been purchased from Exo-Sensors, Inc. A maintenance history.
for the instruments was also provided.
It was concluded by
licensee and resident inspectors that the Exo-Sensors, Inc.,
equipment is meeting procurement requirements and technical
specifications and that the equipment maintenance history is
<
also acceptable.
G.
Licensing Actions
.
1.
NRR/ Licensee Meetings
Upper Plenum Injection - Evaluation Model
January 10, 1985
Reactor Upper Internal (Top Hat Design)
June 26, 1985
,
34
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4
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'
.
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
Site Visit / Meeting / Resident Inspector
Unit 2 Refueling Outage
October 7-10, 1985
Site Visit / Meeting / Resident Inspector
March 11-14, 1985
Unit 1 Refueling Outage
3.
Commission Meetings
None.
4.
Schedular Extensions Granted
Fire Protection Appendix R 10 CFR 50.48c
May 7, 1985
Surveillance Capsule Summary Report
Extension
.
March 17, 1986
i
Confirmatory Order Supplement 1
February 5, 1986
5.
Reliefs Granted
None.
6.
Exemptions Granted
None.
7.
License Amendments Issued
Amendment No.
Title
Date.
72/65
Operability period of
February 15, 1985
cooling H2O header
73/66
Thirteen chanc% i)
June 25, 1985
technical 94 ifb . tion
74/67
Spent Fue; anip,...aj
June 26, 1985
Cask Movement over
Spent Fuel Pool No. 1
75/68
Shunt trip and Manual
June 26, 1985
reactor trip circuitry
GL 83-28 Item 4.3
35
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76/69
Steam Generator Tube
October 11, 1985
. ,
Sleeving
1 ,
77/70,'
Fuel Reload Technical
April 3, 1985
Specification Change
8.
Emergency Technical Specification
-
None.
}
,
9.
Orders Issued
'
,
None.
'
10.
NRR/ Licensee Management Conference
None.
.
%
i
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4
6
8
1
f
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6
3
_ . . . .
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